Provision record
Synthesia · Synthesia Privacy Policy · View original document ↗

Dual Role as Data Controller and Data Processor

Medium severity High confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

Synthesia acts as the data controller for individual users and as a data processor for business customers who use the platform on behalf of their own users or employees, with a separate legal agreement governing each relationship.

This analysis describes what Synthesia'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)

The distinction between controller and processor determines who is ultimately responsible for your data rights; if you are an employee or end user of a business that uses Synthesia, your data rights may need to be exercised through that business rather than directly with Synthesia.

Consumer impact (what this means for users)

If your employer or organization uses Synthesia and you interact with the platform through them, the business customer is likely the data controller and bears primary responsibility for your data, which may affect who you need to contact to exercise rights like access or deletion.

How other platforms handle this

ZipRecruiter Medium

Where ZipRecruiter processes your Personal Data in the capacity of a service provider (data processor), and you seek access, or want to correct, amend, or delete your Personal Data...we will provide you with the data controller's contact information, so you can contact them directly.

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
In some cases, we act as a data controller in respect of your personal data. In other cases, particularly where we process data on behalf of our business customers, we act as a data processor. Where we act as a data processor, our processing activities are governed by a Data Processing Agreement with the relevant business customer.

Excerpt from Synthesia's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: GDPR Articles 26, 28, and 29 govern the controller-processor relationship, requiring a written Data Processing Agreement that specifies the subject matter, duration, nature, and purpose of processing, as well as the obligations …

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Applicable regulations

EU AI Act
European Union
CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
EU AI Act - High Risk Provisions
EU
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

Provision details

Document information
Document
Synthesia Privacy Policy
Entity
Synthesia
Document last updated
May 5, 2026
Tracking information
First tracked
April 30, 2026
Last verified
May 10, 2026
Record ID
CA-P-009277
Document ID
CA-D-00470
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
7648d9071447f69ed848238281e6ab982ee2d650c8e20eb74c961b356314a183
Analysis generated
April 30, 2026 07:49 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Synthesia
Document: Synthesia Privacy Policy
Record ID: CA-P-009277
Captured: 2026-04-30 07:49:32 UTC
SHA-256: 7648d9071447f69e…
URL: https://conductatlas.com/platform/synthesia/synthesia-privacy-policy/provision/CA-P-009277/dual-role-as-data-controller-and-data-processor/
Accessed: Sept. 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 Synthesia's Dual Role as Data Controller and Data Processor clause do?

The distinction between controller and processor determines who is ultimately responsible for your data rights; if you are an employee or end user of a business that uses Synthesia, your data rights may need to be exercised through that business rather than directly with Synthesia.

How does this clause affect you?

If your employer or organization uses Synthesia and you interact with the platform through them, the business customer is likely the data controller and bears primary responsibility for your data, which may affect who you need to contact to exercise rights like access or deletion.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Synthesia?

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