Smartsheet · Smartsheet Privacy Policy · View original document ↗

Smartsheet Liability for Onward Agent Transfers

High severity High confidence Explicitdocumentlanguage Common · 230 of 352 platforms
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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)

Smartsheet's ongoing liability for agent-processed data means users retain a direct line of accountability to Smartsheet even after their data has been passed to a third party.

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 →

Consumer impact (what this means for users)

If Smartsheet transfers your personal data to a third-party agent, Smartsheet remains liable for how that agent processes it.

How other platforms handle this

Instacart Medium

Any access to or use of the Services or goods through your account by others, including your spouse, dependents, Recipients, and any access by AI Agents you enable or that operate on your behalf...

Twilio Medium

Indemnifying Party will not settle any Claim for which it has an obligation to indemnify under this Section 6 admitting liability or fault on behalf of Indemnified Party, nor create any obligation on behalf of Indemnified Party without Indemnified Party's prior written consent...

Whatnot Medium

A complete release for Whatnot from any liability and/or damages related to your Promotion.

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▸ View Original Clause Language DOCUMENT RECORD
"
Smartsheet is and will remain liable for the processing of personal data it receives under the Data Privacy Framework and subsequently transfers to a third party acting as an agent on its behalf.

— Excerpt from Smartsheet's Smartsheet Privacy Policy

Applicable regulations

FTC Act Section 5
United States Federal

Provision details

Document information
Document
Smartsheet Privacy Policy
Entity
Smartsheet
Document last updated
May 5, 2026
Tracking information
First tracked
May 21, 2026
Last verified
May 21, 2026
Record ID
CA-P-056432
Document ID
CA-D-00712
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
d717d893d470babbacfab8ed42bd074a5a8061edd6082565059e2bf23c98555a
Analysis generated
May 21, 2026 05:48 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Smartsheet
Document: Smartsheet Privacy Policy
Record ID: CA-P-056432
Captured: 2026-05-21 05:48:10 UTC
SHA-256: d717d893d470babb…
URL: https://conductatlas.com/platform/smartsheet/smartsheet-privacy-policy/provision/CA-P-056432/smartsheet-liability-for-onward-agent-transfers/
Accessed: July 12, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Smartsheet's Smartsheet Liability for Onward Agent Transfers clause do?

Smartsheet's ongoing liability for agent-processed data means users retain a direct line of accountability to Smartsheet even after their data has been passed to a third party.

How does this clause affect you?

If Smartsheet transfers your personal data to a third-party agent, Smartsheet remains liable for how that agent processes it.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 230 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.