Mistral AI · Mistral AI Data Processing Addendum · View original document ↗

Customer Responsibility for Consents and Data Subject Rights

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Document Record

What it is

Business customers are responsible for obtaining all necessary consents from their users, providing required privacy notices, and responding to any data subject rights requests (such as access, deletion, or correction requests) related to the processing covered by this DPA.

This analysis describes what Mistral AI'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 places the full burden of consent management, privacy disclosure, and data subject rights handling on the business customer rather than on Mistral AI, which is consistent with the Controller-Processor framework but requires customers to have robust mechanisms in place for managing rights requests at the end-user level.

Consumer impact (what this means for users)

End users who want to exercise rights over their data (such as requesting deletion or access) must direct those requests to the business customer, not to Mistral AI directly. Mistral AI states it will not respond directly to end-user rights requests without customer consent, instead forwarding them to the customer.

How other platforms handle this

Runway Medium

In addition to the above rights, your local laws (including those in the EU, UK, Japan, California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Virginia, or Utah) may afford you f...

ADP Medium

If you are a California resident, you may have certain rights under the California Consumer Privacy Act (CCPA). These rights may include: the right to know about personal information collected, disclosed, or sold; the right to delete personal information collected from you; the right to opt-out of t...

TransUnion Medium

Depending on where you live, you may have certain rights with respect to your personal information. These rights may include: The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which we collected i...

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▸ View Original Clause Language DOCUMENT RECORD
"
Customer shall: Comply with its obligations under the Applicable Data Protection Law regarding the Processing and any instruction provided to Mistral AI, Provide notice and obtain all consents and rights required by the Applicable Data Protection Law for Mistral AI to Process Personal Data as part of the Processing, under this DPA. Customer shall (a) provide Data Subjects with the information required by the Applicable Data Protection Law and (b) respond to all Data Subjects requests to exercise their rights regarding the Processing.

— Excerpt from Mistral AI's Mistral AI Data Processing Addendum

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages GDPR Articles 12-22 (data subject rights) and Articles 13-14 (transparency obligations), as well as CCPA rights provisions including the right to know, delete, and opt-out. The customer-as-Controller framework means the customer bears primary accountability for rights fulfillment, with Mistral AI providing assistance as Processor. EU supervisory authorities enforce rights compliance against the Controller, making this provision a significant accountability assignment. (2) GOVERNANCE EXPOSURE: Medium. The exposure is primarily operational: customers must have functional processes for receiving, validating, and responding to data subject rights requests within regulatory timeframes (GDPR: one month, extendable to three; CCPA: 45 days, extendable to 90). The DPA commits Mistral AI to provide 'commercially reasonable assistance' for rights requests, but the customer bears ultimate responsibility. (3) JURISDICTION FLAGS: EU/EEA customers face the broadest data subject rights obligations under GDPR, including rights to access, rectification, erasure, restriction, portability, and objection. California residents have CCPA rights that the customer must be prepared to fulfill. Customers serving data subjects in other jurisdictions (UK, Brazil, Canada) face additional local law requirements not explicitly addressed in this DPA. (4) CONTRACT AND VENDOR IMPLICATIONS: Customers should assess whether their current privacy infrastructure can support timely rights request fulfillment for data processed by Mistral AI, including the ability to identify and retrieve or delete data processed through Mistral AI products. Downstream customer agreements should accurately allocate Controller responsibilities. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should map all data flows through Mistral AI products to ensure rights request fulfillment processes can reach data held or processed by Mistral AI. Privacy notices should accurately describe the processing relationship and identify the customer as the responsible party for rights requests. Internal procedures should address how to engage Mistral AI's commercially reasonable assistance for complex rights requests.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC enforces against unfair or deceptive data practices, including failures to honor privacy representations or consumer rights requests under applicable law.
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
EU AI Act - High Risk Provisions
EU
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

Provision details

Document information
Document
Mistral AI Data Processing Addendum
Entity
Mistral AI
Document last updated
May 11, 2026
Tracking information
First tracked
May 11, 2026
Last verified
May 11, 2026
Record ID
CA-P-010508
Document ID
CA-D-00771
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
665fdccf3892a6b79fd3e3a2e1761e63b0656d270450185360d4858313afcd0c
Analysis generated
May 11, 2026 11:22 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Mistral AI
Document: Mistral AI Data Processing Addendum
Record ID: CA-P-010508
Captured: 2026-05-11 11:22:45 UTC
SHA-256: 665fdccf3892a6b7…
URL: https://conductatlas.com/platform/mistral-ai/mistral-ai-data-processing-addendum/customer-responsibility-for-consents-and-data-subject-rights/
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 Mistral AI's Customer Responsibility for Consents and Data Subject Rights clause do?

This provision places the full burden of consent management, privacy disclosure, and data subject rights handling on the business customer rather than on Mistral AI, which is consistent with the Controller-Processor framework but requires customers to have robust mechanisms in place for managing rights requests at the end-user level.

How does this clause affect you?

End users who want to exercise rights over their data (such as requesting deletion or access) must direct those requests to the business customer, not to Mistral AI directly. Mistral AI states it will not respond directly to end-user rights requests without customer consent, instead forwarding them to the customer.

Is ConductAtlas affiliated with Mistral AI?

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