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
Sensitive Personal Data is subject to a higher standard of justification for use or disclosure, requiring either specific consent where mandated or a lawful basis.
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 →Your sensitive Personal Data will only be used or disclosed by Shopify with your specific consent where required, or where the law otherwise permits it.
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we may use this information to make it easier for you to find the people you want to send payments to, for account and identity verification and fraud prevention purposes, to reduce the risk you will send payments to the wrong person, or to provide other personalized services.
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"For categories of sensitive Personal Data that we collect, we only use or disclose such information either with your specific consent when required, or as otherwise permitted by law.— Excerpt from Shopify's Shopify Privacy Policy
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Sensitive Personal Data is subject to a higher standard of justification for use or disclosure, requiring either specific consent where mandated or a lawful basis.
Your sensitive Personal Data will only be used or disclosed by Shopify with your specific consent where required, or where the law otherwise permits it.
ConductAtlas has identified this type of provision across 280 platforms. See the full comparison.
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