Provision record
Smartsheet · Smartsheet Privacy Policy · View original document ↗

International Data Transfers

Medium severity Medium confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

Your data may be transferred to and stored in the United States or other countries with different privacy laws. For EU and UK users, Smartsheet states it uses approved legal mechanisms like Standard Contractual Clauses to make that transfer lawful.

This analysis describes what Smartsheet'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)

Data transferred to the US is subject to US surveillance laws and may not receive the same legal protections as in the EU or UK, making the adequacy of transfer mechanisms a material compliance question for European organizations.

Interpretive note: The adequacy of Smartsheet's specific transfer impact assessments and supplementary measures is not disclosed in the notice, and the legal status of adequacy decisions may change, creating ongoing uncertainty about transfer lawfulness.

Recent Activity

This document changed recently

Medium Jun 5, 2026

The updated privacy policy states that only Smartsheet's U.S.-based affiliates participate in the EU-U.S., UK Extension, and Swiss-U.S. Data Privacy Framework. Previously, the policy referenced participation by Smartsheet and its affiliates without geographic qualification. This narrowed scope may affect the data transfer mechanisms available for processing personal data from EU, UK, and Swiss users if non-U.S. affiliates are involved in data handling. The policy does not explicitly describe alternative transfer mechanisms for non-U.S. affiliates.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
May 10, 2026
First Seen
May 20, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Change history

removed May 21, 2026

Removal of explicit international data transfer disclosure eliminates important notice about cross-border data flows and differences in data protection standards, which is particularly significant for non-U.S. users.

View full change record →

Consumer impact (what this means for users)

If you are located outside the US, including in the EU or UK, your personal data will be transferred to and processed in the United States, where data protection laws may provide fewer protections; Smartsheet states it uses Standard Contractual Clauses or adequacy decisions to authorize those transfers.

How other platforms handle this

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

Roblox Medium

Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Smartsheet is based in the United States, and personal data we collect is governed by U.S. law. If you are accessing our Site or Services from outside the United States, please be aware that information collected through the Site or Services may be transferred to, processed, stored, and used in the United States and other countries. Data protection laws in the U.S. and other countries may differ from those in your country of residence. Where required, we rely on approved transfer mechanisms such as Standard Contractual Clauses or adequacy decisions to transfer personal data from the EEA and UK.

Excerpt from Smartsheet's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly engages GDPR Chapter V on international data transfers, including requirements for adequate safeguards such as Standard Contractual Clauses (SCCs) or adequacy decisions.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Smartsheet Privacy Policy
Entity
Smartsheet
Document last updated
May 5, 2026
Tracking information
First tracked
May 7, 2026
Last verified
May 10, 2026
Record ID
CA-P-008060
Document ID
CA-D-00712
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
aa3e2b37314e800adf6f92513bffd0a54c2369282b4a03c0788838ef681cf41e
Analysis generated
May 7, 2026 16:22 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Smartsheet
Document: Smartsheet Privacy Policy
Record ID: CA-P-008060
Captured: 2026-05-07 16:22:45 UTC
SHA-256: aa3e2b37314e800a…
URL: https://conductatlas.com/platform/smartsheet/smartsheet-privacy-policy/provision/CA-P-008060/international-data-transfers/
Accessed: Aug. 11, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Smartsheet's International Data Transfers clause do?

Data transferred to the US is subject to US surveillance laws and may not receive the same legal protections as in the EU or UK, making the adequacy of transfer mechanisms a material compliance question for European organizations.

How does this clause affect you?

If you are located outside the US, including in the EU or UK, your personal data will be transferred to and processed in the United States, where data protection laws may provide fewer protections; Smartsheet states it uses Standard Contractual Clauses or adequacy decisions to authorize those transfers.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Smartsheet?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Smartsheet.