This analysis describes what Starbucks'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
This clause places the burden on Starbucks to prove non-responsibility when an agent violates DPF Principles, giving affected individuals a direct liability pathway against Starbucks rather than only against the agent.
If a Starbucks agent mishandles your personal information in violation of EU-U.S. DPF Principles, Starbucks remains liable unless it proves it is not responsible.
How other platforms handle this
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"Starbucks Corporation remains liable under the EU-U.S. DPF Principles...if an agent of Starbucks Corporation processes personal information in a manner inconsistent with the EU-U.S. DPF Principles...unless Starbucks Corporation proves that it is not responsible...— Excerpt from Starbucks's Starbucks Privacy Policy
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This clause places the burden on Starbucks to prove non-responsibility when an agent violates DPF Principles, giving affected individuals a direct liability pathway against Starbucks rather than only against the agent.
If a Starbucks agent mishandles your personal information in violation of EU-U.S. DPF Principles, Starbucks remains liable unless it proves it is not responsible.
ConductAtlas has identified this type of provision across 230 platforms. See the full comparison.
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