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

Controller and Processor Role Allocation

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Document Record

What it is

The policy establishes that enterprise customers (employers or other purchasing entities) act as data controllers for Customer Data submitted to the platform, while Synthesia acts as data controller for Other Information it independently collects. Synthesia processes Customer Data only on customer instructions.

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)

This provision allocates primary compliance responsibility for Customer Data governance to enterprise customers, establishing that those customers determine the purposes and conditions of processing for user-submitted content including avatar samples, scripts, and videos. Authorized users with questions about Customer Data handling are directed to their employer or the relevant enterprise customer rather than Synthesia.

Consumer impact (what this means for users)

Under this clause, individual users authorized by an enterprise customer have limited direct recourse against Synthesia regarding Customer Data processing, as the policy positions the enterprise customer as the data controller responsible for those processing decisions. Users seeking information about how their employer's Synthesia instance handles their data should contact the enterprise customer directly.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
Certain jurisdictions distinguish between a "controller" or "processor" of personal data. A controller is the decision-maker and exercises overall control over how and why personal data is collected and used. In general, the Customer is the controller of Customer Data. A processor acts on behalf of, and only on the instructions of, the relevant controller. In general, Synthesia is the processor of Customer Data and the controller of Other Information (which is described in the 'Personal data that we process' section below). Synthesia is the controller of Other Information and a processor of Customer Data.

Excerpt from Synthesia's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

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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 →

Provision details

Document information
Document
Synthesia Privacy Policy
Entity
Synthesia
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015744
Document ID
CA-D-00470
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
c48a575e2d96eda30f9d795d55b7e461edba6b3a934c98d2b8aa22e3fc6ec27f
Analysis generated
July 9, 2026 08:42 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Synthesia
Document: Synthesia Privacy Policy
Record ID: CA-P-015744
Captured: 2026-07-09 08:42:29 UTC
SHA-256: c48a575e2d96eda3…
URL: https://conductatlas.com/platform/synthesia/synthesia-privacy-policy/provision/CA-P-015744/controller-and-processor-role-allocation/
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 Controller and Processor Role Allocation clause do?

This provision allocates primary compliance responsibility for Customer Data governance to enterprise customers, establishing that those customers determine the purposes and conditions of processing for user-submitted content including avatar samples, scripts, and videos. Authorized users with questions about Customer Data handling are directed to their employer or the relevant enterprise customer rather than Synthesia.

How does this clause affect you?

Under this clause, individual users authorized by an enterprise customer have limited direct recourse against Synthesia regarding Customer Data processing, as the policy positions the enterprise customer as the data controller responsible for those processing decisions. Users seeking information about how their employer's Synthesia instance handles their data should contact the enterprise customer directly.

Is ConductAtlas affiliated with Synthesia?

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