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
This commitment limits the risk of fully automated, high-stakes decisions being made about individuals without human oversight.
The updated policy changes the legal mechanism used to protect personal data when it crosses borders, but does not change where data is transferred or fundamentally alter protection levels. For EEA and Swiss users, data transfers between Shopify entities now rely on Shopify's Binding Corporate Rules (which have been approved by European data protection authorities), rather than adequacy decisions. For UK users, transfers use Standard Contractual Clauses and may rely on the adequacy decision for Canada. For transfers to third-party subprocessors, contractual commitments in the form of Standard Contractual Clauses now replace prior language referencing comparable protections. The policy states these mechanisms reflect Shopify's commitment to adequate protection, but the shift in legal instruments may have implications for how disputes or compliance issues would be evaluated under GDPR or UK data protection law.
View change record →Shopify's machine learning processes will not be both fully automated and legally or similarly significantly consequential to you.
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"When we use machine learning, we either: (1) still have a human being involved in the process (and so are not fully automated); or (2) use machine learning in ways that don't have legal or similarly significant effects.— Excerpt from Shopify's Shopify Privacy Policy
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This commitment limits the risk of fully automated, high-stakes decisions being made about individuals without human oversight.
Shopify's machine learning processes will not be both fully automated and legally or similarly significantly consequential to you.
ConductAtlas has identified this type of provision across 210 platforms. See the full comparison.
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