Provision record
Revolut · Revolut Privacy Policy · View original document ↗

Multi-Entity Data Controller Structure

Medium severity High confidence Explicitdocumentlanguage Common · 295 of 352 platforms
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Document Record

What it is

This single privacy policy covers three separate Revolut companies, meaning your data may be handled by different legal entities depending on which products you use, each potentially subject to different regulatory frameworks.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Understanding which legal entity controls your data matters because different entities are subject to different regulators and regulatory obligations, and your rights may vary depending on which Revolut company holds your information.

Clause Stability Stable

0
Changes
3
Months Monitored
May 9, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5260 other provisions on other platforms.

Consumer impact (what this means for users)

Your personal data may be held or processed by Revolut Technologies Inc., Revolut Securities Inc., or Revolut Wealth Inc. depending on which services you use, and knowing which entity is responsible for your data helps you direct data rights requests and regulatory complaints correctly.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Export Your Data
    Contact dpo@revolut.com to request clarification on which Revolut entity holds your personal data for each product you use, and to submit any data access or deletion request.

How other platforms handle this

Skillshare Medium

In certain circumstances, the right to data portability, which means that you can request that we provide certain Personal Data we hold about you in a machine-readable format

Discord Medium

If you want to see what information we have collected about you, you can request a copy of your data in the Data & Privacy section of your User Settings. You should receive your data packet within 30 days.

Baseten Medium

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

See all platforms with this clause type →

Monitoring

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▸ View Original Clause Language DOCUMENT RECORD
"
This Privacy Policy covers Revolut Technologies Inc., Revolut Securities Inc., and Revolut Wealth Inc.'s services in the United States.

Excerpt from Revolut's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: The three-entity structure creates a multi-regulator exposure landscape. Revolut Securities Inc. as a broker-dealer is subject to SEC and FINRA customer data protection rules. Revolut Wealth Inc. as an investment adviser is subject to SEC investment adviser regulations. Revolut Technologies Inc. as the technology and platform entity is subject to FTC oversight and state consumer protection laws. Each entity's data handling obligations are shaped by its regulatory classification, and a single privacy policy covering all three must accurately reflect each entity's distinct obligations. GOVERNANCE EXPOSURE: Medium. A single privacy policy covering multiple regulated entities is common in financial services groups but requires careful drafting to ensure that entity-specific obligations are accurately disclosed and that consumers can identify which entity is the relevant data controller for their products. Inaccurate or ambiguous attribution of data controller status could create disclosure compliance issues under GLBA Regulation P and CCPA. JURISDICTION FLAGS: SEC and FINRA regulation applies to Revolut Securities Inc. at the federal level. SEC investment adviser regulations apply to Revolut Wealth Inc. State money transmission and financial services laws apply to the broader group depending on product and state. California CCPA and CPRA obligations apply to all three entities with respect to California residents. CONTRACT AND VENDOR IMPLICATIONS: Inter-entity data sharing arrangements within the Revolut group should be documented with appropriate data processing agreements or intragroup data transfer agreements that accurately reflect the controller-processor or joint controller relationships. This is particularly important for compliance with GLBA affiliate sharing rules and CCPA affiliate disclosure requirements. COMPLIANCE CONSIDERATIONS: Each entity should have a clear data map documenting what data it holds, under what regulatory framework, and under which sections of the shared privacy policy. Consumer-facing disclosures should clearly identify which entity is responsible for which product and data set. Legal teams should review whether the single-policy approach adequately satisfies entity-specific regulatory disclosure requirements for the broker-dealer and investment adviser entities.

Full institutional analysis

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

Applicable agencies

  • SEC
    The SEC has oversight of Revolut Securities Inc. as a broker-dealer and Revolut Wealth Inc. as an investment adviser, including their customer data protection obligations.
    File a complaint →
  • CFPB
    The CFPB has oversight of financial privacy practices under GLBA Regulation P applicable to the financial products offered by Revolut entities.
    File a complaint →

Applicable regulations

Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
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

Provision details

Document information
Document
Revolut Privacy Policy
Entity
Revolut
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 9, 2026
Record ID
CA-P-007483
Document ID
CA-D-00268
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
5b1da235e3ef773ab4e412f9de7a6bf3e5b88cf622f80575afcd49e6541d72fb
Analysis generated
May 7, 2026 07:48 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Revolut
Document: Revolut Privacy Policy
Record ID: CA-P-007483
Captured: 2026-05-07 07:48:41 UTC
SHA-256: 5b1da235e3ef773a…
URL: https://conductatlas.com/platform/revolut/revolut-privacy-policy/provision/CA-P-007483/multi-entity-data-controller-structure/
Accessed: July 25, 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 Revolut's Multi-Entity Data Controller Structure clause do?

Understanding which legal entity controls your data matters because different entities are subject to different regulators and regulatory obligations, and your rights may vary depending on which Revolut company holds your information.

How does this clause affect you?

Your personal data may be held or processed by Revolut Technologies Inc., Revolut Securities Inc., or Revolut Wealth Inc. depending on which services you use, and knowing which entity is responsible for your data helps you direct data rights requests and regulatory complaints correctly.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 295 platforms. See the full comparison.

Is ConductAtlas affiliated with Revolut?

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