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
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.
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We may offer joint promotions or programs that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information...
We will disclose your personal information within the Adobe family of companies for the purposes identified above
we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...
"Where processing is undertaken by our affiliated companies, they are joint controllers with Smartsheet Inc. for your personal data.Excerpt from Smartsheet's Privacy Policy
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The clause states: “Where processing is undertaken by our affiliated companies, they are joint controllers with Smartsheet Inc. for your personal data.”
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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