The policy distinguishes between Miro's role as a data controller for account, registration, and usage data, and its role as a data processor for content uploaded by enterprise customers to boards, with the latter governed by the Customer Data Processing Addendum.
This analysis describes what Miro'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
This provision establishes two distinct legal frameworks governing different categories of data, requiring enterprise customers to manage compliance obligations under both the privacy policy (for controller-level data) and the DPA (for processor-level board content).
Interpretive note: The precise language defining the controller/processor boundary was not available in the truncated document; this provision reflects Miro's known dual-role structure as described in its published legal framework.
New high-severity provision clarifies Miro's dual role as both data controller and processor in different contexts, affecting user rights and liability allocation.
View full change record →Under this framework, individual users are subject to the privacy policy for account and usage data, while enterprise customers' board content is governed by a separate DPA; the practical scope of each framework depends on how data is classified and how the DPA is executed.
How other platforms handle this
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.
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.
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.
1) REGULATORY LANDSCAPE: The controller/processor distinction is foundational to GDPR compliance (Articles 4, 24, 28) and is similarly recognized under UK GDPR.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision establishes two distinct legal frameworks governing different categories of data, requiring enterprise customers to manage compliance obligations under both the privacy policy (for controller-level data) and the DPA (for processor-level board content).
Under this framework, individual users are subject to the privacy policy for account and usage data, while enterprise customers' board content is governed by a separate DPA; the practical scope of each framework depends on how data is classified and how the DPA is executed.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Miro.