Revolut states it transfers personal data internationally and uses Standard Contractual Clauses or other appropriate safeguards to protect data when it leaves the UK.
This analysis describes what Revolut'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
Your personal data may be processed in countries outside the UK with different levels of data protection, and the adequacy of the safeguards in place determines how well your data is protected internationally.
Interpretive note: The master notice references international transfers and safeguards at a high level without identifying specific destination countries or transfer mechanisms, creating uncertainty about the full scope of international data flows.
Your personal data held by Revolut may be transferred to and processed in countries outside the UK, including potentially the US or other jurisdictions with different privacy standards, though Revolut states it applies appropriate transfer safeguards.
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Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.
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"Our promises: we will always keep your personal data safe. We will never sell your personal data. We will always try to give you as much control as possible over how we use your personal data.— Excerpt from Revolut's Revolut Privacy Policy
(1) REGULATORY LANDSCAPE: UK GDPR Chapter V governs international transfers of personal data from the UK. Post-Brexit, the UK has its own adequacy decision framework operated by the Secretary of State for Digital, Culture, Media and Sport, separate from EU GDPR adequacy decisions. Standard Contractual Clauses under UK GDPR, known as the International Data Transfer Agreement or addendum to EU SCCs, are the primary mechanism for transfers to non-adequate countries. The ICO oversees compliance with UK international transfer requirements. (2) GOVERNANCE EXPOSURE: Medium. International data transfers in a multi-entity fintech group operating across multiple jurisdictions are complex and require ongoing monitoring of adequacy decisions and transfer mechanism validity. Revolut's group structure across the UK, EEA, and other jurisdictions creates multiple transfer pathways that each require documented mechanisms. (3) JURISDICTION FLAGS: Transfers to the US are subject to the UK-US Data Bridge adequacy framework or SCCs. Transfers to EEA countries benefit from UK adequacy decisions for the EEA. Transfers to other third countries require case-by-case assessment. The ICO's enforcement posture on international transfers has been active, and any gaps in transfer mechanisms could attract regulatory attention. (4) PROCUREMENT IMPLICATIONS: All third-party processors and sub-processors receiving UK personal data outside the UK must be covered by appropriate transfer mechanisms documented in data processing agreements. Regular reviews are needed as adequacy decisions and transfer frameworks can change. (5) COMPLIANCE CONSIDERATIONS: Legal teams should maintain a data transfer impact assessment register for all third-country transfers, ensure that transfer mechanisms are current and reflect the latest ICO-approved forms, and monitor changes to UK adequacy decisions that could affect existing transfer arrangements.
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Your personal data may be processed in countries outside the UK with different levels of data protection, and the adequacy of the safeguards in place determines how well your data is protected internationally.
Your personal data held by Revolut may be transferred to and processed in countries outside the UK, including potentially the US or other jurisdictions with different privacy standards, though Revolut states it applies appropriate transfer safeguards.
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