Get the weekly research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.
The policy states that collected user data may be transferred to and stored in the United States and other countries, and that continued use of the services constitutes acknowledgment that such transfers will occur.
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 provision relies on continued use of the services as acknowledgment of international data transfers. Under GDPR, transfer mechanisms must meet specific legal standards, and acknowledgment-by-use may require evaluation as a valid GDPR Chapter V transfer basis depending on the jurisdiction and regulatory interpretation.
Interpretive note: Whether acknowledgment-by-continued-use constitutes a valid GDPR transfer mechanism requires evaluation under applicable regulatory guidance; the policy's reference to DPF and SCCs as parallel mechanisms partially addresses this ambiguity but operational implementation would need to be confirmed.
Under this clause, personal data collected from users, including those in jurisdictions with stronger data protection laws than the United States, may be transferred to the U.S. or other countries, with continued service use treated as acknowledgment of such transfers.
Cross-platform context
See how other platforms handle International Data Transfer Consent by Continued Use and similar clauses.
Compare across platforms →Monitoring
Writer has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 25 platforms.
"The information we collect may be transferred to and stored in countries where we and our third-party service providers have operations, including the United States. The applicable data protection laws in these countries may differ from those in your country of residence. By using the Services, you acknowledge that these transfers will occur.Excerpt from Writer's Privacy Policy
REGULATORY LANDSCAPE: This provision engages GDPR Chapter V, which requires a valid legal basis for transferring personal data outside the EEA. GDPR does not recognize consent-by-continued-use as a valid transfer mechanism in most circumstances; valid mechanisms include adequacy decisions, standard contractual clauses, and binding corporate rules. The policy separately references DPF certification and standard contractual clauses as transfer mechanisms, which partially addresses this gap. Relevant enforcement authorities include EU national data protection authorities. GOVERNANCE EXPOSURE: Medium. The reliance on acknowledgment-by-use as a transfer basis creates potential tension with GDPR transfer requirements for EEA users. However, the policy's reference to DPF certification and standard contractual clauses as operative transfer mechanisms reduces practical exposure if those mechanisms are operationally implemented for EEA data flows. JURISDICTION FLAGS: EEA and UK users face the most significant exposure. EU data protection authorities in member states with active enforcement have scrutinized transfer mechanism adequacy. Swiss users are covered by the Swiss-U.S. DPF. CONTRACT AND VENDOR IMPLICATIONS: Legal teams should confirm that DPF certification or standard contractual clauses are operationally implemented for EEA and UK data flows and not solely reliant on the acknowledgment-by-use mechanism described in this clause. COMPLIANCE CONSIDERATIONS: Data transfer mapping should be conducted to confirm that all international transfer flows are covered by a valid GDPR Chapter V mechanism. The acknowledgment-by-use language should be reviewed for alignment with GDPR requirements, particularly in light of enforcement trends in the EU.
This provision relies on continued use of the services as acknowledgment of international data transfers. Under GDPR, transfer mechanisms must meet specific legal standards, and acknowledgment-by-use may require evaluation as a valid GDPR Chapter V transfer basis depending on the jurisdiction and regulatory interpretation.
Under this clause, personal data collected from users, including those in jurisdictions with stronger data protection laws than the United States, may be transferred to the U.S. or other countries, with continued service use treated as acknowledgment of such transfers.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Writer.