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The policy states that Notion may revise the privacy policy at its sole discretion and that material changes will be communicated as required by applicable law. Continued use of the Services after a new policy takes effect constitutes deemed acceptance of the updated terms.
This analysis describes what Notion'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
The deemed acceptance provision establishes that continued platform use after a privacy policy update constitutes agreement to the updated terms. The policy does not specify the advance notice period for material changes beyond the requirement to notify as required by applicable law, which may vary by jurisdiction.
Interpretive note: Whether deemed acceptance through continued use satisfies applicable consent requirements varies by jurisdiction, particularly under GDPR and UK GDPR where consent-based processing may require affirmative re-consent for material changes.
Under these terms, continued use of Notion's Services after a revised privacy policy takes effect constitutes acceptance of the updated policy. The agreement states that material changes will be communicated as required by applicable law, without specifying a standard advance notice period.
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"We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.Excerpt from Notion's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages GDPR requirements for re-consent or notification when data processing terms change materially, as deemed acceptance through continued use may not satisfy GDPR's consent standards where consent is the stated lawful basis for processing. The CCPA requires that material changes to privacy practices be disclosed, and the FTC has expressed interest in unilateral modification clauses in consumer contracts. 2) GOVERNANCE EXPOSURE: Low to Medium. Deemed acceptance clauses are commonly observed in SaaS privacy policies. However, for EU and UK users where GDPR consent is a lawful basis, deemed acceptance through continued use may not constitute valid consent for new or changed processing activities, requiring separate evaluation. 3) JURISDICTION FLAGS: EU and UK users face the most significant exposure, as GDPR and UK GDPR may require affirmative re-consent for material changes to processing activities rather than permitting deemed acceptance. California residents should note that CCPA disclosures of material changes may trigger updated opt-out rights. 4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise data processing agreements should specify the notice period and process for material changes to Notion's privacy practices, rather than relying on the policy's reference to applicable law requirements. This is particularly relevant for organizations subject to GDPR data processing agreements. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should monitor Notion's published privacy policy change notices and evaluate whether material changes require updated consent mechanisms, data processing agreement amendments, or user notifications under their own applicable obligations.
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The deemed acceptance provision establishes that continued platform use after a privacy policy update constitutes agreement to the updated terms. The policy does not specify the advance notice period for material changes beyond the requirement to notify as required by applicable law, which may vary by jurisdiction.
Under these terms, continued use of Notion's Services after a revised privacy policy takes effect constitutes acceptance of the updated policy. The agreement states that material changes will be communicated as required by applicable law, without specifying a standard advance notice period.
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