Provision record
Revolut · Revolut Terms of Service (Superseded URL) · View original document ↗

Privacy and Data Use — Incorporation by Reference

Medium severity Common · 294 of 352 platforms
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Document Record

What it is

Revolut's Privacy Policy is incorporated into these Terms and governs how your personal and financial data is collected, used, and shared — you agree to it by using the service.

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)

By incorporating multiple documents by reference, this clause creates a unified contractual framework where obligations, restrictions, and disclosures are distributed across several documents rather than consolidated in a single instrument. This structure requires users to consult multiple sources to understand the full scope of their rights and obligations.

Recent Activity

This document changed recently

Medium Mar 23, 2026

The updated Terms of Service no longer document the Move Money Rules feature, which previously allowed users to set up automatic fund transfers across account pockets or currency exchanges based on custom conditions. The removal of this documentation means users cannot point to the terms as a reference for how this feature operates, what limits apply, or what fees may be charged. If the feature remains available in the app, its operational parameters are no longer formally described in the binding terms document.

View change record →

Clause Stability Stable

0
Changes
4
Months Monitored
Apr 3, 2026
First Seen
Apr 17, 2026
Last Seen
This clause type exists across 4545 other provisions on other platforms.

Consumer impact (what this means for users)

Consumers' financial and personal data is governed by a separate Privacy Policy they must independently review, meaning the full scope of data use is not visible in the Terms alone.

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.
  • Delete Your Data
    To request deletion of your personal data, visit Revolut's Privacy Policy page for instructions on submitting a data deletion request, or use the in-app support chat to initiate a request.

How other platforms handle this

Google Gemini Medium

The Gemini Apps Privacy Notice does not apply, and your Opal data, including feedback you provide, is processed per the Google Privacy Policy.

FanDuel Medium

Recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as your country.

Squarespace Medium

Each payment processor uses and processes your complete payment information in accordance with its applicable privacy policy (Stripe and PayPal).

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Monitoring

Revolut has changed this document before.

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▸ View Original Clause Language DOCUMENT RECORD
"
These terms and conditions, along with the Cardholder Agreement, Fees pages, Privacy Policy and any other terms and conditions that apply to your account and our services, form a legal agreement (the Agreement) between you and Revolut Technologies Inc.

Excerpt from Revolut's Terms of Service (Superseded URL)

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

Incorporation by reference of a privacy policy raises compliance considerations under GLBA, applicable state privacy laws (including CCPA for California residents), and FinCEN data retention requirements. Legal teams should review both documents together to assess the full data governance framework.

Full institutional analysis

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

Applicable agencies

  • FTC
    The FTC oversees consumer data privacy practices and enforcement of privacy policies in consumer financial services under Section 5 of the FTC Act and the Gramm-Leach-Bliley Act.
    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 Terms of Service (Superseded URL)
Entity
Revolut
Document last updated
May 5, 2026
Tracking information
First tracked
March 24, 2026
Last verified
March 24, 2026
Record ID
CA-P-001395
Document ID
CA-D-00267
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
0ed57cafc9ea03db52a3574cff930a1f72c68e1972a9e764f2f1b8fa595652c7
Analysis generated
March 24, 2026 08:03 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Revolut
Document: Revolut Terms of Service (Superseded URL)
Record ID: CA-P-001395
Captured: 2026-03-24 08:03:08 UTC
SHA-256: 0ed57cafc9ea03db…
URL: https://conductatlas.com/platform/revolut/revolut-terms-of-service-superseded-url/provision/CA-P-001395/privacy-and-data-use-incorporation-by-reference/
Accessed: July 25, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

Related Analysis

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Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.

Frequently Asked Questions

What does Revolut's Privacy and Data Use — Incorporation by Reference clause do?

By incorporating multiple documents by reference, this clause creates a unified contractual framework where obligations, restrictions, and disclosures are distributed across several documents rather than consolidated in a single instrument. This structure requires users to consult multiple sources to understand the full scope of their rights and obligations.

How does this clause affect you?

Consumers' financial and personal data is governed by a separate Privacy Policy they must independently review, meaning the full scope of data use is not visible in the Terms alone.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 294 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.