Squarespace · Squarespace Privacy Policy · View original document ↗

Dual Controller and Processor Role Structure

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Squarespace plays two different privacy roles: it controls data when you are its direct customer, but when you visit a website that someone else built on Squarespace, the website owner controls your data and Squarespace is just processing it on their behalf.

This analysis describes what Squarespace'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)

This distinction determines who is legally responsible for protecting your data and who you can contact to exercise rights like deletion or access, which may not be obvious when visiting a Squarespace-powered site.

Consumer impact (what this means for users)

If you are a visitor to a third-party website built on Squarespace, your data access and deletion rights must be exercised with the website owner, not Squarespace, which may limit the practical remedies available to you depending on that owner's responsiveness.

How other platforms handle this

Egnyte Medium

Egnyte is a data controller with respect to personal data it collects from visitors to its website and through its marketing activities. Egnyte acts as a data processor with respect to the content and data that customers store within the Egnyte platform. In that capacity, Egnyte processes data on be...

Workday Medium

At Workday, we believe privacy is a fundamental right, regardless of where you live. When you connect with Workday, we understand you are trusting us to handle your personal information appropriately. That is why we are committed to transparency about how we collect, use, and share that information.

Mixpanel Medium

Mixpanel acts as a data processor on behalf of its customers (the controllers) when processing end user data through the Mixpanel analytics platform, and as a data controller with respect to data it collects about its own website visitors and account holders.

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▸ View Original Clause Language DOCUMENT RECORD
"
When you visit a website built on Squarespace, Squarespace acts as a service provider or data processor, meaning that we process your information on behalf of the website owner. In this case, the website owner is responsible for the information they collect through their website and you should contact them about their privacy practices. When we collect information directly from you in order to provide our services to you (such as when you create a Squarespace account or subscribe to a plan), we act as a data controller.

— Excerpt from Squarespace's Squarespace Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: This dual-role structure directly implicates GDPR Articles 4(7) and 4(8) defining controller and processor, and Article 28 governing processor agreements. The Irish Data Protection Commission serves as Squarespace's lead EU supervisory authority. The structure also engages CCPA and CPRA definitions of business versus service provider. Where this distinction is not clearly communicated to website visitors, it may engage GDPR Articles 13 and 14 transparency obligations at the website-owner level. GOVERNANCE EXPOSURE: High. The operational complexity of a dual controller/processor structure creates downstream compliance obligations for Squarespace's B2B customers, who bear controller responsibility for visitor data but may not have adequate data processing agreements or GDPR-compliant notice mechanisms in place. Squarespace's policy asserts this distinction but enforcement of it depends on whether customer-facing sites implement adequate privacy notices. JURISDICTION FLAGS: Heightened exposure in the EU/EEA and UK, where GDPR and UK GDPR impose strict controller/processor delineation and mandate written data processing agreements. California exposure exists under CPRA, which similarly distinguishes between businesses and service providers. The provision may affect any jurisdiction with statutory definitions of data controller versus processor. CONTRACT AND VENDOR IMPLICATIONS: Organizations using Squarespace to host customer-facing websites should confirm that a compliant data processing agreement is in place with Squarespace, and that their own privacy notices adequately disclose Squarespace's role as a processor. Procurement teams should audit whether existing DPAs address all relevant processing activities, data categories, and sub-processor arrangements. COMPLIANCE CONSIDERATIONS: Compliance teams at organizations using Squarespace should review their own privacy notices to ensure visitors are informed of the controller's identity and data practices. Data mapping exercises should reflect Squarespace as a sub-processor where applicable. Any data subject requests received by Squarespace-hosted site operators should be responded to within GDPR or CCPA timelines, and teams should confirm Squarespace's contractual commitments support this.

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive privacy practices, including inadequate disclosure of which entity controls consumer data.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
ePrivacy Directive
European Union
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal

Provision details

Document information
Document
Squarespace Privacy Policy
Entity
Squarespace
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 11, 2026
Record ID
CA-P-010301
Document ID
CA-D-00569
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
760bf733870bf1e90c2b2bf49c4348155254bff4634889f1fc7c14a16d9a81e0
Analysis generated
May 8, 2026 14:38 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Squarespace
Document: Squarespace Privacy Policy
Record ID: CA-P-010301
Captured: 2026-05-08 14:38:54 UTC
SHA-256: 760bf733870bf1e9…
URL: https://conductatlas.com/platform/squarespace/squarespace-privacy-policy/dual-controller-and-processor-role-structure/
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 Squarespace's Dual Controller and Processor Role Structure clause do?

This distinction determines who is legally responsible for protecting your data and who you can contact to exercise rights like deletion or access, which may not be obvious when visiting a Squarespace-powered site.

How does this clause affect you?

If you are a visitor to a third-party website built on Squarespace, your data access and deletion rights must be exercised with the website owner, not Squarespace, which may limit the practical remedies available to you depending on that owner's responsiveness.

Is ConductAtlas affiliated with Squarespace?

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