Provision record
Loom · Loom Privacy Policy · View original document ↗

Controller vs. Processor Dual Role

Medium severity Low confidence Inferred from context Common · 290 of 352 platforms
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Document Record

What it is

Atlassian acts as the data controller for account and usage data but acts as a data processor for content that enterprise customers upload or generate, meaning your employer (not Atlassian) may be the party legally responsible for certain decisions about your data.

This analysis describes what Loom's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

In enterprise Loom deployments, your employer controls key data decisions, which means your individual rights requests may need to go to your employer first rather than directly to Atlassian.

Interpretive note: The controller/processor distinction language could not be directly extracted from the truncated HTML; this provision is inferred from Atlassian's known enterprise privacy and DPA framework as applicable to Loom.

Clause Stability Stable

0
Changes
3
Months Monitored
May 10, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Consumer impact (what this means for users)

If you use Loom through your employer, your organization may be the data controller for your video recordings and workspace data, affecting where and how you can exercise deletion or access rights; individual employees should contact their IT or legal team to understand how Loom data is governed within their organization.

How other platforms handle this

ZipRecruiter Medium

Where ZipRecruiter processes your Personal Data in the capacity of a service provider (data processor), and you seek access, or want to correct, amend, or delete your Personal Data...we will provide you with the data controller's contact information, so you can contact them directly.

Tinder Medium

If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.

Skillshare Medium

When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services.

See all platforms with this clause type →
ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: The controller/processor distinction is foundational to GDPR compliance under Articles 4, 24, and 28.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Loom Privacy Policy
Entity
Loom
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 10, 2026
Record ID
CA-P-008506
Document ID
CA-D-00565
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8a1c5acb713e644f1bae9303aa9bc97bc64e447bd57ce9ec70ff0d9b296b971e
Analysis generated
May 7, 2026 20:02 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Loom
Document: Loom Privacy Policy
Record ID: CA-P-008506
Captured: 2026-05-07 20:02:17 UTC
SHA-256: 8a1c5acb713e644f…
URL: https://conductatlas.com/platform/loom/loom-privacy-policy/provision/CA-P-008506/controller-vs-processor-dual-role/
Accessed: Aug. 25, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Loom's Controller vs. Processor Dual Role clause do?

In enterprise Loom deployments, your employer controls key data decisions, which means your individual rights requests may need to go to your employer first rather than directly to Atlassian.

How does this clause affect you?

If you use Loom through your employer, your organization may be the data controller for your video recordings and workspace data, affecting where and how you can exercise deletion or access rights; individual employees should contact their IT or legal team to understand how Loom data is governed within their organization.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Loom?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Loom.