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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.
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You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA or United Kingdom...
We may also transfer your information to a third country based on an exception provided for by the Swiss Federal Data Protection Act. An exception may apply in the event of legal proceedings abroad, in cases of overriding public interest or if the performance of a contract...
The Federal Trade Commission has jurisdiction over ZipRecruiter's compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.
"If you are in the UK, when we send your Personal Data to any other Shopify entity outside of the UK, EEA or Switzerland, it is transferred pursuant to Standard Contractual Clauses in place between Shopify entities.Excerpt from Shopify's Privacy Policy
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The clause states: “If you are in the UK, when we send your Personal Data to any other Shopify entity outside of the UK, EEA or Switzerland, it is transferred pursuant to Standard Contractual Clauses in place between Shopify entities.”
ConductAtlas has identified this type of provision across 267 platforms. See the full comparison.
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