Microsoft · Microsoft Privacy Statement (Legacy) · View original document ↗

Cross-Border Data Transfer Mechanisms

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Recent governance activity Microsoft recorded 3 documented changes in the last 30 days.
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This analysis describes what Microsoft'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)

This provision establishes that personal data of EU, UK, and Swiss users may be transferred internationally and describes the legal mechanisms Microsoft asserts as the basis for those transfers, which is material for GDPR compliance and regulatory scrutiny.

Recent Activity

This document changed recently

Medium Apr 19, 2026

The updated policy establishes additional grounds on which Microsoft may retain personal data. While the prior version tied retention to specific user expectations and available deletion controls, th…

Medium Apr 1, 2026

The updated policy now grounds data retention in five broad business purposes: operating the business, meeting contractual and legal obligations, improving and developing products and services, prote…

Medium Mar 13, 2026

The updated Privacy Statement removes previously stated language about additional rights available to European Economic Area users, narrowing the policy's explicit protections in that region. Simulta…

Consumer impact (what this means for users)

The statement authorizes Microsoft to collect a wide range of personal data including identifiers, location, voice and audio recordings, browsing and search history, and content created within Microsoft products, and to use this data for advertising, product personalization, and AI model improvement across its product portfolio. EU and UK users have GDPR-based rights including access, correction, deletion, and objection to processing, while California and other U.S. state residents have rights under applicable state privacy laws including the right to opt out of data sales or sharing for targeted advertising. You can access, review, download, or delete your personal data and adjust advertising and personalization settings at account.microsoft.com/privacy.

How other platforms handle this

Calm Medium

Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission's adequacy decisions, or executing Standard Contractual Clauses. Where relevant, you may request a copy of ...

Airtable Medium

We may transfer to and process your personal information in countries outside of the jurisdiction where you are located for the various purposes described above. When required by law, we will ensure that we rely on an appropriate legal mechanism for the transfer, such as your consent, standard contr...

OpenAI Medium

OpenAI is based in the United States and the information we collect is governed by U.S. law. If you are accessing our services from outside of the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities in the United States and by tho...

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▸ View Original Clause Language DOCUMENT RECORD
"
Personal data collected by Microsoft may be stored and processed in your region, in the United States, and in any other country where Microsoft or its affiliates, subsidiaries, or service providers operate facilities. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located. We transfer personal data from the European Economic Area, the United Kingdom, and Switzerland to other countries, some of which have not yet been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, such as the standard contractual clauses published by the European Commission, to help ensure your rights and protections travel with your data.

— Excerpt from Microsoft's Microsoft Privacy Statement (Legacy)

Applicable regulations

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

Provision details

Document information
Document
Microsoft Privacy Statement (Legacy)
Entity
Microsoft
Document last updated
March 5, 2026
Tracking information
First tracked
April 28, 2026
Last verified
May 12, 2026
Record ID
CA-P-010759
Document ID
CA-D-00001
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
9e697464d17b7148c787f07099c60e30370abb2b13a7f2a910f607e31ec13158
Analysis generated
April 28, 2026 08:11 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Microsoft
Document: Microsoft Privacy Statement (Legacy)
Record ID: CA-P-010759
Captured: 2026-04-28 08:11:57 UTC
SHA-256: 9e697464d17b7148…
URL: https://conductatlas.com/platform/microsoft/microsoft-privacy-statement-legacy/cross-border-data-transfer-mechanisms/
Accessed: May 13, 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 Microsoft's Cross-Border Data Transfer Mechanisms clause do?

This provision establishes that personal data of EU, UK, and Swiss users may be transferred internationally and describes the legal mechanisms Microsoft asserts as the basis for those transfers, which is material for GDPR compliance and regulatory scrutiny.

Is ConductAtlas affiliated with Microsoft?

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