Provision record
Vercel AI · Vercel AI SDK Privacy · View original document ↗

Dual Role: Data Controller and Data Processor

High severity High confidence Explicit document language Common · 289 of 352 platforms
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Document Record

What it is

When you build and run your own apps using Vercel, Vercel acts as a processor of your users' data, not the controller, meaning you as the developer are responsible for your users' privacy rights in that context.

This analysis describes what Vercel AI'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)

Developers deploying applications on Vercel need to understand that they, not Vercel, are legally responsible for their end users' data under GDPR and similar laws, and they must have their own privacy notices and legal bases for processing.

Recent Activity

This document changed recently

Medium Jun 2, 2026

The updated policy establishes a new mechanism for resolving privacy disputes related to Data Privacy Framework transfers. Users in the EU, UK, and EEA who have unresolved privacy complaints can now submit them to VeraSafe for independent review, which will be conducted free of charge. Additionally, the policy introduces an explicit Right to Restriction, permitting users to request that Vercel limit processing of their personal information or restrict further disclosures in certain instances, particularly for sensitive information. You can file a complaint with VeraSafe by submitting required information at https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
May 10, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 5149 other provisions on other platforms.

Consumer impact (what this means for users)

End users of applications hosted on Vercel should know their privacy rights in that context are determined by the developer who built the application, not by Vercel's privacy policy, meaning Vercel's policy does not directly protect them in that scenario.

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
"
When you use our Services to build and run your own applications, we act as a data processor on your behalf with respect to any personal information you collect and process using our Services. In these circumstances, you are the data controller.

Excerpt from Vercel AI's SDK Privacy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly engages GDPR Article 4(7) and Article 4(8) definitions of controller and processor, and Article 28 requirements for data processing agreements between controllers and processors.

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

Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
EU AI Act - High Risk Provisions
EU
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
Vercel AI SDK Privacy
Entity
Vercel AI
Document last updated
May 12, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 10, 2026
Record ID
CA-P-008977
Document ID
CA-D-00548
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
b1d2dff022f60b8295c54f46539cf51b85afa976a386ba9d7131838ae80fc81c
Analysis generated
May 8, 2026 01:04 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Vercel AI
Document: Vercel AI SDK Privacy
Record ID: CA-P-008977
Captured: 2026-05-08 01:04:59 UTC
SHA-256: b1d2dff022f60b82…
URL: https://conductatlas.com/platform/vercel-ai/vercel-ai-sdk-privacy/provision/CA-P-008977/dual-role-data-controller-and-data-processor/
Accessed: Aug. 11, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Vercel AI's Dual Role: Data Controller and Data Processor clause do?

Developers deploying applications on Vercel need to understand that they, not Vercel, are legally responsible for their end users' data under GDPR and similar laws, and they must have their own privacy notices and legal bases for processing.

How does this clause affect you?

End users of applications hosted on Vercel should know their privacy rights in that context are determined by the developer who built the application, not by Vercel's privacy policy, meaning Vercel's policy does not directly protect them in that scenario.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.

Is ConductAtlas affiliated with Vercel AI?

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