This analysis describes what Shopify'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 dual role designation determines Shopify's legal responsibilities and the scope of its independent decision-making authority regarding personal data. When operating as a controller, Shopify maintains independent authority over data handling decisions; when operating as a processor, Shopify's data processing activities are governed by Merchant directives, establishing a chain of responsibility between Merchant and Shopify for customer data.
For Visitors and Merchants using Shopify services directly, Shopify acts as controller with independent authority over personal data handling. For Customers of Merchants, Shopify processes their data according to instructions from the Merchant who collected it, meaning the Merchant bears primary responsibility for lawfulness of collection while Shopify operates under that Merchant's direction.
How other platforms handle this
Mixpanel acts as a data processor on behalf of its customers (the controllers) when processing end user data through the Mixpanel analytics platform, and as a data controller with respect to data it collects about its own website visitors and account holders.
When our business customers use certain Services, we generally process and store limited personal information on their behalf as a data processor. For certain products such as Docusign's Contract Lifecycle Management (CLM) and Identity products, we may act as a processor and as a controller in certa...
Amplitude acts as a data controller when we collect and use Personal Information for our own purposes, such as providing and improving our Services, marketing, and other business operations. When Amplitude processes Personal Information on behalf of our customers (for example, event data that our cu...
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"When you visit our websites or use our services as a Visitor or a Merchant, Shopify acts as the data controller. When Merchants use our services to run their business, and in doing so provide us with information about their Customers, Shopify generally acts as a data processor on behalf of those Merchants. In these cases, Shopify processes information as instructed by the Merchant.— Excerpt from Shopify's Shopify Privacy Policy
We read the privacy policies and terms of service of 38 AI platforms. Here is what they say about training, retention, arbitration, and liability.
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The dual role designation determines Shopify's legal responsibilities and the scope of its independent decision-making authority regarding personal data. When operating as a controller, Shopify maintains independent authority over data handling decisions; when operating as a processor, Shopify's data processing activities are governed by Merchant directives, establishing a chain of responsibility between Merchant and Shopify for customer data.
For Visitors and Merchants using Shopify services directly, Shopify acts as controller with independent authority over personal data handling. For Customers of Merchants, Shopify processes their data according to instructions from the Merchant who collected it, meaning the Merchant bears primary responsibility for lawfulness of collection while Shopify operates under that Merchant's direction.
ConductAtlas has identified this type of provision across 5 platforms. See the full comparison.
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