Smartsheet · Smartsheet Privacy Policy · View original document ↗

International Data Transfers

Medium severity Medium confidence Explicitdocumentlanguage Common · 48 of 325 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.

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

Mistral AI Medium

Customer authorized Mistral AI to transfer Personal Data to any country deemed to have an adequate level of data protection by the European Commission. Customer also authorizes Mistral AI to perform International Data Transfers to (a) on the basis of adequate safeguards in accordance with Applicable...

Unity Medium

Personal data collected by Unity may be transferred to and processed in countries outside of the European Economic Area, including the United States, where data protection laws may differ from those in your country. Where we transfer personal data from the EEA or the UK, we rely on appropriate safeg...

Upwork Medium

When we transfer personal data outside the European Economic Area, United Kingdom, or Switzerland, we use appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, to ensure your data is protected.

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▸ 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 Smartsheet Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & 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. The UK GDPR has parallel requirements. Following the Schrems II decision, SCCs must be accompanied by a transfer impact assessment (TIA) where required. The relevant enforcement authorities are EU national data protection authorities and the UK ICO. (2) GOVERNANCE EXPOSURE: Medium. Smartsheet's reliance on SCCs and adequacy decisions is consistent with standard industry practice for US-based SaaS providers, but the adequacy of those mechanisms depends on whether supplementary measures and TIAs have been conducted. Organizations in regulated sectors or those handling sensitive personal data face heightened exposure if Smartsheet's transfer documentation is incomplete. (3) JURISDICTION FLAGS: EU and EEA organizations face the primary exposure under GDPR Chapter V. UK organizations face parallel obligations under UK GDPR. Where Smartsheet relies on the EU-US Data Privacy Framework adequacy decision for certain transfers, organizations should monitor the legal status of that framework, which has been subject to legal challenge. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise customers should request Smartsheet's SCCs or data transfer documentation as part of vendor due diligence. Procurement teams should confirm which transfer mechanism applies to their specific data flows and whether Smartsheet has conducted TIAs for relevant transfers. (5) COMPLIANCE CONSIDERATIONS: Legal teams should document the transfer mechanisms applicable to their Smartsheet deployments and assess whether supplementary technical or organizational measures are needed. Any changes in the legal status of adequacy decisions or SCCs may require reassessment of transfer lawfulness.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • State AG
    EU and UK data protection authorities (not listed in the agency enum) have enforcement jurisdiction; US State AGs may be relevant for state-level privacy law compliance related to cross-border data flows
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Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
DMA
European Union
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/international-data-transfers/
Accessed: May 13, 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 48 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.