When enterprise customers submit data through Writer, Writer is acting as a data processor following the customer's instructions, while the customer remains legally responsible for that data under privacy law.
This analysis describes what Writer'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 allocation of legal roles has significant implications for enterprise compliance teams: it means the enterprise customer bears primary obligations under GDPR for lawful basis, data subject rights, and privacy notices related to the data they submit to Writer.
Interpretive note: The precise scope of what constitutes 'Customer Data' versus other data categories processed by Writer may vary by contract and use case, affecting the boundaries of the controller/processor allocation.
The updated policy removes detailed disclosures that previously explained five cookie categories (strictly necessary, functional, performance, targeting), their purposes, and user controls. The revised policy retains only a brief statement that Writer uses cookies to enhance navigation, analyze usage, personalize experience, and assist in advertising, but no longer provides the granular categories, opt-out procedures, or explanation of what data each type collects. Users can no longer reference specific cookie management options, targeting cookie opt-out procedures, or detailed functional descriptions within the policy itself.
View change record →Enterprise customers are responsible for ensuring their use of Writer complies with applicable privacy laws, including obtaining any necessary consents from employees or end users whose data is submitted to the platform.
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"With respect to Customer Data that enterprise customers submit to Writer's Services, Writer acts as a data processor on behalf of the customer, who acts as the data controller. The customer is responsible for ensuring they have the appropriate rights and permissions to submit such data to Writer.Excerpt from Writer's Privacy Policy
REGULATORY LANDSCAPE: This provision directly engages GDPR Article 28, which governs processor agreements and requires a written contract specifying the subject matter, duration, nature, and purpose of processing, as well as obligations and rights of …
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This allocation of legal roles has significant implications for enterprise compliance teams: it means the enterprise customer bears primary obligations under GDPR for lawful basis, data subject rights, and privacy notices related to the data they submit to Writer.
Enterprise customers are responsible for ensuring their use of Writer complies with applicable privacy laws, including obtaining any necessary consents from employees or end users whose data is submitted to the platform.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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