TermsGuard corpus | Taiwo Alabi

Company	Risk	Score	Flagged	Cleared	Uncertain	Last fetched	Prior	Change
Google Big Tech	Medium	0.53	173	84	224	2026-10-29	·	.
Apple Big Tech	Medium	0.58	2	1	4	2026-10-29	·	.
Microsoft Big Tech	Medium	0.52	286	372	804	2026-10-29	·	.
Amazon Big Tech	Medium	0.48	14	15	25	2026-10-29	·	.
TikTok Big Tech	Medium	0.53	78	54	136	2026-10-29	·	.
Deutsche Bank Banking	Medium	0.55	12	20	41	2026-10-29	·	.
UniCredit Banking	Medium	0.56	3	2	8	2026-10-29	·	.
Rabobank Banking	Medium	0.53	36	35	88	2026-10-29	·	.
Allianz Insurance	Medium	0.53	20	20	59	2026-10-29	·	.
AXA Insurance	Medium	0.44	3	5	15	2026-10-29	·	.
IKEA Retail	Medium	0.55	73	63	285	2026-10-29	·	.
Inditex Retail	Medium	0.37	1	0	6	2026-10-29	·	.
Decathlon Retail	Medium	0.59	33	18	37	2026-10-29	·	.
SAP Tech & SaaS	Medium	0.54	72	74	170	2026-10-29	·	.
Spotify Tech & SaaS	Medium	0.52	86	55	138	2026-10-29	·	.
Deutsche Telekom Telecom	Medium	0.54	51	30	94	2026-10-29	·	.
Vodafone Telecom	Medium	0.56	16	26	40	2026-10-29	·	.
Booking.com Travel	Medium	0.51	131	72	257	2026-10-29	·	.
Telefónica Telecom	Low	0.57	12	35	40	2026-10-29	·	.
Adyen Payments	Medium	0.51	28	14	50	2026-10-29	·	.

Google Big Tech

policy source

0.53 score

Medium risk

173 flagged

84 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium risk policy with purpose limitation concerns, cookie and consent issues, and disputed claims about international transfers and territorial scope. The dominant matches are Article 5(1)(b) Purpose Limitation, with 53 flagged clauses, followed by no basis match in 43 clauses and ePrivacy Directive combinations with Article 5(1)(b) or Article 7 Conditions for Consent. The engine also flags Article 44 International Transfers and Article 3 Territorial Scope.

How this was scored

How this was scored: 481 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 173 flagged clauses , most of them under Art.5(1)(b) Purpose Limitation violation. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 173 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

We don’t share information that personally identifies you with advertisers, such as your name or email, unless you ask us to.

Art.5(1)(b) Purpose Limitation confidence 0.72

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

Data protection laws vary among countries, with some providing more protection than others.

Art.44 International Transfers confidence 0.72

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

This Privacy Policy doesn’t apply to services that have separate privacy policies that do not incorporate this Privacy Policy.

Art.3 Territorial Scope unlawful claim confidence 0.72

Retrieved context: [GDPR Art. 3] Territorial scope 1. This Regulation applies to the processing of personal data in the context of the activities of an establishment of a controller or a processor in the Union, regardless of whether the processing takes place in the Union or not. 2. This Regulation applies to the proc...

For example, we use cookies to analyze how people interact with our services.

ePrivacy Directive violation + Art.7 Consent confidence 0.72

Retrieved context: [GDPR Recital 58] The Principle of Transparency 1. The principle of transparency requires that any information addressed to the public or to the data subject be concise, easily accessible and easy to understand, and that clear and plain language and, additionally, where appropriate, visualisation be...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 84 by confidence. These are the clauses the engine read as GDPR-compliant.

To delete your information, you can:

Art.17 Right to Erasure confidence 0.77

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

And some data we retain for longer periods of time when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping.

Art.5(1)(e) Storage Limitation confidence 0.76

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

However, some website features or services may not function properly without cookies.

ePrivacy Directive + Art.5(1)(b) confidence 0.76

Retrieved context: [GDPR Recital 64] Identity Verification 1. The controller should use all reasonable measures to verify the identity of a data subject who requests access, in particular in the context of online services and online identifiers. 2. A controller should not retain personal data for the sole purpose of b...

We change this Privacy Policy from time to time.

Art.7 Conditions for Consent + Art.13 confidence 0.74

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

Overall analysis

Of 481 clauses analysed, 173 were flagged and 84 were cleared, so the policy contains valid privacy controls alongside a larger set of detected concerns. The flagged examples cover advertiser sharing, cookie analytics, a statement that data protection varies between countries, and exclusion of services with separate privacy policies. The cleared examples cover deletion requests, longer retention for stated business or legal purposes, cookie-related service limits

Notes and caveats

224 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Meta Big Tech

policy source

No snapshot yet.

Apple Big Tech

policy source

0.58 score

Medium risk

2 flagged

1 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This policy presents a medium risk of consent and access compliance problems. The engine flagged a general privacy commitment under Article 7 Conditions for Consent and an instruction to visit Manage your Apple account under Article 15 Right of Access. The flagged clauses have a mean confidence of 0.58.

How this was scored

How this was scored: 7 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 2 flagged clauses , most of them under Art.7 Conditions for Consent violation. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 2 of 2 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

Apple is committed to your privacy.

Art.7 Conditions for Consent confidence 0.59

Retrieved context: [GDPR Art. 7] Conditions for consent It shall be as easy to withdraw as to give consent. 8. When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the proc...

To access and manage your Apple data please visit Manage your Apple account.

Art.15 Right of Access confidence 0.58

Retrieved context: [GDPR Art. 15] Right of access by the data subject 1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:...

Cleared clauses · what TermsGuard reads as protective

Top 1 of 1 by confidence. These are the clauses the engine read as GDPR-compliant.

For corrections or general enquiries, please Contact Privacy.

Art.15 Right of Access confidence 0.49

Retrieved context: [GDPR Art. 15] Right of access by the data subject 1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:...

Overall analysis

Of seven clauses analysed, two were flagged and one was cleared. The flagged set covers one clause under Article 7 and one under Article 15, while the cleared clause also concerns Article 15 and directs users to Contact Privacy for corrections or general enquiries. This shows mixed treatment of access-related language, with the account-management instruction flagged and the contact instruction cleared. Four analysed clauses are not represented in the supplied flagged or cleared lists.

Notes and caveats

4 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Microsoft Big Tech

policy source

0.52 score

Medium risk

286 flagged

372 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium-risk policy with data-use, cookie-consent, purpose-limitation, and international-transfer concerns. The engine most often flagged Article 5(1)(b) Purpose Limitation, followed by no basis matches, and also identified ePrivacy Directive and Article 7 Conditions for Consent issues. It also flagged an Article 44 International Transfers clause, with a mean confidence of 0.52 across flagged clauses.

How this was scored

How this was scored: 1462 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 286 flagged clauses , most of them under Art.5(1)(b) Purpose Limitation violation. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 286 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

Browsing activity includes your browse history, favourites, usage data, and web content.

ePrivacy Directive violation + Art.5(1)(b) confidence 0.79

Retrieved context: [GDPR Recital 18] Not Applicable to Personal or Household Activities 1. This Regulation does not apply to the processing of personal data by a natural person in the course of a purely personal or household activity and thus with no connection to a professional or commercial activity. 2. Personal or ...

We transfer personal data from the country of origin to other countries, including those that may not offer the same level of data protection as determined by the European Commission or your local data protection authority.

Art.44 International Transfers confidence 0.78

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

We use cookies to store your preferences and settings, help with sign-in, provide personalised ads and analyse site operations.

ePrivacy Directive violation + Art.7 Consent confidence 0.77

Retrieved context: [GDPR Recital 30] Online Identifiers for Profiling and Identification 1. Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identi...

We use cookies and similar technologies to store and honour your preferences and settings, enable you to sign-in, provide personalised advertising, combat fraud, analyse how our products perform, and fulfil other legitimate purposes described below.

ePrivacy Directive violation + Art.7 Consent confidence 0.76

Retrieved context: [GDPR Recital 64] Identity Verification 1. The controller should use all reasonable measures to verify the identity of a data subject who requests access, in particular in the context of online services and online identifiers. 2. A controller should not retain personal data for the sole purpose of b...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 372 by confidence. These are the clauses the engine read as GDPR-compliant.

Because these needs can vary for different data types and the context of our interactions with you or your use of our products, actual retention periods can vary significantly.

Art.5(1)(e) Storage Limitation + Art.13 confidence 0.77

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

You provide some of this data directly, and we get other data by collecting information about your interactions, use, and experiences with our products.

Art.5(1)(a) Transparency confidence 0.75

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

Parents can change or revoke consent at any time.

Art.7(3) Right to Withdraw Consent confidence 0.74

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

Parents or guardians (“parents”) can change or revoke consent at any time.

Art.7(3) Right to Withdraw Consent confidence 0.74

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

Overall analysis

Of 1,462 clauses analysed, 286 were flagged and 372 were cleared. The flagged examples describe browsing activity collection, cookies used for settings, sign-in, personalised advertising, fraud prevention, and analysis, plus transfers to countries that may not provide the same level of protection. The cleared examples describe variable retention periods, data provided directly or collected from product interactions, and parents' ability to change or revoke consent. The shape is mixed: the policy contains provisions the engine reads as transparent or consent-supporting, alongside broader data-use and transfer language that contributes to the medium score.

Notes and caveats

804 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Amazon Big Tech

policy source

0.48 score

Medium risk

14 flagged

15 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This policy presents a medium risk of purpose limitation and consent problems, especially around cookies, identifiers, browsing history, legal compliance, and third-party providers. The flagged set is dominated by Article 5(1)(b) Purpose Limitation, ePrivacy Directive violations, and Article 7 Consent, with one Article 5(1)(a) Transparency violation and five clauses with no basis match.

How this was scored

How this was scored: 54 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 14 flagged clauses . No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 14 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

You can edit Your Browsing History, as well.

ePrivacy Directive violation + Art.5(1)(b) confidence 0.65

Retrieved context: [GDPR Recital 66] Right to be Forgotten 1. To strengthen the right to be forgotten in the online environment, the right to erasure should also be extended in such a way that a controller who has made the personal data public should be obliged to inform the controllers which are processing such perso...

Amazon Services, we use cookies and other identifiers.

ePrivacy Directive violation + Art.7 Consent confidence 0.63

Retrieved context: [GDPR Recital 30] Online Identifiers for Profiling and Identification 1. Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identi...

In certain cases, we collect and use your personal information to comply with laws.

Art.5(1)(b) Purpose Limitation confidence 0.59

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf.

Art.5(1)(b) Purpose Limitation confidence 0.48

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (6) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organ...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 15 by confidence. These are the clauses the engine read as GDPR-compliant.

Information from Other Sources: We might receive information about you from other sources.

Art.15 Right of Access confidence 0.68

Retrieved context: [GDPR Art. 15] Right of access by the data subject 1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:...

You provide information to us when you:

Art.15 Right of Access confidence 0.68

Retrieved context: [GDPR Art. 15] Right of access by the data subject 1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:...

See examples of information we collect or receive.

Art.5(1)(a) Transparency confidence 0.61

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

You may adjust your personalized advertising preferences by visiting Your Ads Privacy Choices.

Art.25 Privacy by Design & Default confidence 0.59

Retrieved context: [GDPR Art. 25] Data protection by design and by default The controller shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed. 2. That obligation applies to the ...

Overall analysis

The engine flagged 14 of 54 analysed clauses and cleared 15. Flagged clauses describe editing browsing history, using cookies and other identifiers, collecting information to comply with laws, and using third-party service providers; cleared clauses describe information sources, user-provided information, collection examples, and advertising preference controls. The cleared set therefore covers access, transparency, and preference controls, while the flagged set concentrates on processing purposes and consent. The score is 0.48, based on the mean confidence of flagged clauses.

Notes and caveats

25 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

TikTok Big Tech

policy source

0.53 score

Medium risk

78 flagged

54 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium risk profile centered on tracking, consent, and broad information sharing. The dominant signal is Article 5(1)(b) Purpose Limitation, including clauses also mapped to Article 28, with additional flags for Article 7 Conditions for Consent and the ePrivacy Directive. The engine reads the policy as allowing collection through the in-app browser and cookies, and sharing information with service providers, partners, and other third parties.

How this was scored

How this was scored: 268 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 78 flagged clauses , most of them under Art.5(1)(b) Purpose Limitation violation. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 78 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

We also collect information about your interactions with websites when you use our in-app browser.

ePrivacy Directive violation + Art.5(1)(b) confidence 0.76

Retrieved context: [GDPR Recital 71] Profiling Automated decision-making and profiling based on special categories of personal data should be allowed only under specific conditions. * This title is an unofficial description....

We use cookies and similar tracking technologies to operate and provide the Platform.

ePrivacy Directive violation + Art.7 Consent confidence 0.73

Retrieved context: [GDPR Recital 30] Online Identifiers for Profiling and Identification 1. Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identi...

We share “What Information We Collect” with service providers, partners and other third party entities, as described in “How We Share Your Information”.

Art.5(1)(b) Purpose Limitation + Art.28 confidence 0.72

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

We share Information You Provide, Automatically Collected Information, and Information From Other Sources with these service providers as necessary to enable them to provide their services.

Art.5(1)(b) Purpose Limitation + Art.28 confidence 0.69

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 54 by confidence. These are the clauses the engine read as GDPR-compliant.

Your rights: Whenever we use your information based on your consent, you can withdraw your consent at any time.

Art.7(3) Right to Withdraw Consent confidence 0.84

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

However, your withdrawal of consent will not affect the lawfulness of processing your information based on your consent prior to your withdrawal of consent.

Art.7(3) Right to Withdraw Consent confidence 0.77

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

You can delete or ask us to delete your information.

Art.17 Right to Erasure confidence 0.77

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

The retention periods will be different depending on the type of information and the purposes for which we use the information.

Art.5(1)(e) Storage Limitation + Art.13 confidence 0.77

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Overall analysis

The flagged clauses describe collection and sharing practices, while the cleared clauses describe consent withdrawal, erasure, and retention periods. Of 268 clauses analysed, 78 were flagged and 54 were cleared, with a mean flagged-clause confidence of 0.53. The policy therefore combines stated user rights and retention disclosures with clauses the engine associates with purpose limitation, consent, and tracking concerns. [auto-filed as T-0038 - pass --task next time to group it]

Notes and caveats

136 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Deutsche Bank Banking

policy source

0.55 score

Medium risk

12 flagged

20 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium-risk privacy policy with potential consent, cookie purpose, and data security concerns. The engine primarily flags ePrivacy Directive requirements and GDPR Article 7 Consent, followed by Article 5(1)(b) Purpose Limitation and one clause linked to Article 32 and Article 5(1)(f). It reads the policy as describing cookies that activate on visits and persist after browsing, while leaving questions about how information is retained, protected, and used.

How this was scored

How this was scored: 73 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 12 flagged clauses , most of them under ePrivacy Directive violation + Art.7 Consent. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 12 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

Some cookies allow you to take full advantage of the functionality of our website.

ePrivacy Directive violation + Art.7 Consent confidence 0.74

Retrieved context: [GDPR Recital 64] Identity Verification 1. The controller should use all reasonable measures to verify the identity of a data subject who requests access, in particular in the context of online services and online identifiers. 2. A controller should not retain personal data for the sole purpose of b...

They are activated each time you visit the website that created that particular cookie.

ePrivacy Directive violation + Art.7 Consent confidence 0.61

Retrieved context: [GDPR Recital 30] Online Identifiers for Profiling and Identification 1. Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identi...

How is information retained, protected, and used?

Art.32 + Art.5(1)(f) confidence 0.60

Retrieved context: [GDPR Art. 32] Security of processing (1) the pseudonymisation and encryption of personal data; (2) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; (3) the ability to restore the availability and access to personal data in...

So-called “persistent cookies” remain on your device even after you close your internet browser.

ePrivacy Directive violation + Art.7 Consent confidence 0.60

Retrieved context: [GDPR Recital 66] Right to be Forgotten 1. To strengthen the right to be forgotten in the online environment, the right to erasure should also be extended in such a way that a controller who has made the personal data public should be obliged to inform the controllers which are processing such perso...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 20 by confidence. These are the clauses the engine read as GDPR-compliant.

You can set your web browser to disable cookies.

ePrivacy Directive + Art.5(1)(b) confidence 0.71

Retrieved context: [GDPR Recital 64] Identity Verification 1. The controller should use all reasonable measures to verify the identity of a data subject who requests access, in particular in the context of online services and online identifiers. 2. A controller should not retain personal data for the sole purpose of b...

What information is collected and how is it used?

Art.5(1)(a) Transparency confidence 0.67

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Marketing cookies and other cookies requiring your consent are not used on this site.

ePrivacy Directive + Art.5(1)(b) confidence 0.67

Retrieved context: [GDPR Recital 42] Burden of Proof and Requirements for Consent Consent should not be regarded as freely given if the data subject has no genuine or free choice or is unable to refuse or withdraw consent without detriment. <div...

Please note that if you disable cookies in this way, you will not be able to set new cookies.

ePrivacy Directive + Art.5(1)(b) confidence 0.65

Retrieved context: [GDPR Recital 66] Right to be Forgotten 1. To strengthen the right to be forgotten in the online environment, the right to erasure should also be extended in such a way that a controller who has made the personal data public should be obliged to inform the controllers which are processing such perso...

Overall analysis

The policy contains 12 flagged clauses and 20 cleared clauses among 73 analysed, with a mean flagged-clause confidence of 0.55. The flagged clauses describe cookies used for website functionality, activation on visits, and persistence after the browser closes; the cleared clauses describe browser controls, transparency about collection and use, and the stated absence of marketing cookies requiring consent. This gives the policy a mixed profile, with cookie and information-handling language triggering concerns while several disclosure and control statements are read as compliant.

Notes and caveats

41 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

ING Banking

policy source

No snapshot yet.

UniCredit Banking

policy source

0.56 score

Medium risk

3 flagged

2 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This policy presents a medium consent and cookie compliance risk, centered on profiling cookies, third-party cookies, and advertising based on user preferences. The dominant basis is the ePrivacy Directive and Article 7 Consent, with two flagged clauses stating that profiling cookie installation requires prior consent. A separate purpose statement received no basis match.

How this was scored

How this was scored: 13 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 3 flagged clauses , most of them under ePrivacy Directive violation + Art.7 Consent. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 3 of 3 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

This website uses technical, analytics and profiling Cookies, also installed by third parties (so called Third-Party Cookies).

ePrivacy Directive violation + Art.7 Consent confidence 0.63

Retrieved context: [GDPR Recital 30] Online Identifiers for Profiling and Identification 1. Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identi...

Profiling Cookies are used in order to offer you advertising messages in line with your preferences; their installation requires your prior consent.

ePrivacy Directive violation + Art.7 Consent confidence 0.62

Retrieved context: [GDPR Art. 4] Definitions ‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, ec...

Our purpose is to empower communities to progress, delivering the best-in-class for all stakeholders, unlocking the potential of our clients and our people across Europe.

no basis match confidence 0.43

Retrieved context: ...

Cleared clauses · what TermsGuard reads as protective

Top 2 of 2 by confidence. These are the clauses the engine read as GDPR-compliant.

If you want to know more or refuse consent click on the link below.

Art.7(3) Right to Withdraw Consent confidence 0.63

Retrieved context: [GDPR Art. 7] Conditions for consent It shall be as easy to withdraw as to give consent. 8. When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the proc...

By clicking on the X at the top right, your navigation will continue without profiling cookies.

ePrivacy Directive + Art.5(1)(b) confidence 0.62

Retrieved context: [GDPR Recital 72] Guidance of the European Data Protection Board Regarding Profiling 1. Profiling is subject to the rules of this Regulation governing the processing of personal data, such as the legal grounds for processing or data protection principles. 2. The European Data Protection Board establ...

Overall analysis

The engine flagged three clauses and cleared two of the 13 analysed clauses. The flagged set describes technical, analytics, and profiling cookies, profiling-based advertising, and a broad stakeholder purpose statement. The cleared clauses describe refusing consent through a link and continuing navigation without profiling cookies by clicking the X. This pattern shows that the policy contains stated consent and refusal mechanisms, while the cookie and profiling language still triggered the main risk signals.

Notes and caveats

8 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Rabobank Banking

policy source

0.53 score

Medium risk

36 flagged

35 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This policy presents a medium risk of broad or insufficiently bounded data use and sharing. The engine primarily identified Article 5(1)(b) Purpose Limitation violations, including disclosures to external parties, direct transfers, and use based on legitimate interest, with additional matches involving Article 7 Conditions for Consent, Article 28, and Articles 44 and 13 Right to be Informed.

How this was scored

How this was scored: 159 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 36 flagged clauses , most of them under Art.5(1)(b) Purpose Limitation violation. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 36 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

If you ask us to transfer data directly to another party, we will only be able to do this if it is technically feasible.

Art.5(1)(b) Purpose Limitation confidence 0.71

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

Additionally, we might share your data with parties outside of Rabobank Group, such as the Government/Regulatory bodies or third parties who assist us in the provision of services and where we are legally obliged to do so.

Art.5(1)(b) Purpose Limitation confidence 0.69

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

In that case, we may also use your data based on legitimate interest.

Art.5(1)(b) Purpose Limitation confidence 0.65

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

Who do we share your personal data with?

Art.5(1)(b) Purpose Limitation confidence 0.65

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 35 by confidence. These are the clauses the engine read as GDPR-compliant.

We do not sell your personal data.

Art.5(1)(b) Purpose Limitation confidence 0.83

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

We process your data for various purposes.

Art.5(1)(a) Transparency confidence 0.73

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

For example, we may receive your data from:

Art.15(3) Right of Access confidence 0.69

Retrieved context: [GDPR Art. 15] Right of access by the data subject 1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:...

You may request that we erase data concerning yourself that we have recorded.

Art.17 Right to Erasure confidence 0.69

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

Overall analysis

The engine flagged 36 of 159 analysed clauses and cleared 35, with a mean flagged-clause confidence of 0.53. The flagged set is led by 15 Article 5(1)(b) Purpose Limitation violations and includes 9 clauses with no basis match. The cleared clauses state that Rabobank does not sell personal data and describe processing purposes, data sources, and erasure requests. The policy therefore contains both clear rights and transparency language and clauses that the engine reads as leaving data-sharing purposes or legal grounds insufficiently bounded. [auto-filed as T-0039 - pass --task next time to group it]

Notes and caveats

88 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Allianz Insurance

policy source

0.53 score

Medium risk

20 flagged

20 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium-risk policy with a mixed compliance profile involving tracking controls, purpose limitation, retention, international transfers, and controller liability. The engine most often flags ePrivacy Directive issues paired with Article 5(1)(b) Purpose Limitation, along with clauses with no basis match. It also identifies Article 44 to 49 International Transfers, Article 82 Controller Liability, Article 5(1)(e) Storage Limitation, and Article 17 Right to Erasure concerns.

How this was scored

How this was scored: 99 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 20 flagged clauses , most of them under ePrivacy Directive violation + Art.5(1)(b). No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 20 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

We will not retain your personal data for longer than is necessary and we will hold it only for the purposes for which it was obtained.

Art.5(1)(e) Storage Limitation + Art.17 confidence 0.79

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

In many cases you can also control tracking technologies using your browser.

ePrivacy Directive violation + Art.5(1)(b) confidence 0.66

Retrieved context: [GDPR Recital 24] Applicable to Controllers/Processors Not Established in the Union if Data Subjects Within the Union are Profiled 1. The processing of personal data of data subjects who are in the Union by a controller or processor not established in the Union should also be subject to this Regulat...

For the stated purposes, we may also share your personal data with the following parties who operate as data processors under our instruction:

Art.5(1)(b) Purpose Limitation confidence 0.66

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Even if both sender and receiver are located in the same country, information sent via the Internet may be transmitted across international borders and be forwarded to a country with a lower data protection level than in your country of residence.

Art.44-49 International Transfers confidence 0.64

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 20 by confidence. These are the clauses the engine read as GDPR-compliant.

Delete your personal data from our records if it is no longer needed for the purposes indicated above;

Art.17 Right to Erasure confidence 0.81

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

Withdraw your consent at any time where your personal data is processed with your consent;

Art.7(3) Right to Withdraw Consent confidence 0.80

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

We will not disclose your personal data to parties who are not authorized to process them.

Art.5(1)(b) Purpose Limitation confidence 0.74

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

What are your rights in respect of your personal data?

Art.17 Right to Erasure confidence 0.73

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

Overall analysis

Among 99 clauses analysed, 20 were flagged and 20 were cleared, with a mean flagged-clause confidence of 0.53. The flagged set covers retention language, browser-based tracking controls, processor sharing, and the possibility that internet transfers cross borders to countries with lower protection. The cleared set includes deletion when data is no longer needed, withdrawal of consent, limits on [auto-filed as T-0040 - pass --task next time to group it]

Notes and caveats

59 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

AXA Insurance

policy source

0.44 score

Medium risk

3 flagged

5 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium-risk policy with a concentrated governance and consent-related risk pattern. The engine flagged joint-controller language under Article 5(1)(b) Purpose Limitation and Article 28, AI principles under Article 7(4) Conditional consent prohibition, and a CNIL contact clause with no matched basis.

How this was scored

How this was scored: 23 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 3 flagged clauses , most of them under Art.5(1)(b) Purpose Limitation + Art.28. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 3 of 3 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

In some cases, GIE AXA and AXA SA (excluding these subsidiaries) a Société Anonyme, organized under French laws, having its registered office at 25 Avenue Matignon, 75008 Paris, registered with the Registry of Commerce and Companies of Paris under number 572 093 920, act as joint data controllers in the context of the processing of your personal data (i.e., they jointly determine the purposes and means of the processing of your information).

Art.5(1)(b) Purpose Limitation + Art.28 confidence 0.47

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (6) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organ...

When we use artificial intelligence (AI), we are committed to comply with the following principles, which are intended to help ensure that artificial intelligence is trustworthy and ethically sound (see Responsible Usage of Artificial Intelligence): purpose; technical robustness and safety; non-discrimination and fairness; transparency and interpretability; human agency and accountability; privacy and data governance; sustainability.

Art.7(4) Conditional consent prohibition confidence 0.45

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

In France, the data protection authority is the Commission Nationale de l'Informatique et des Libertés, or “CNIL” whose postal address is 3 place de Fontenoy - TSA 80715 – 75334 Paris CEDEX 07.

no basis match confidence 0.41

Retrieved context: ...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 5 by confidence. These are the clauses the engine read as GDPR-compliant.

Based on the legal basis for the processing of your personal data, you have also the right to:

Art.17 Right to Erasure confidence 0.69

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

If you wish to know more about the processing of your personal data and you are:

Art.5(1)(a) Transparency confidence 0.65

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

These systems, based on objectives, analyse the data they receive to deduce the best way to produce results such as predictions, recommendations, or content, which can influence physical or virtual environments.

Art.5(1)(a) Transparency confidence 0.55

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (3) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’); (4) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure t...

Request the limitation of the processing of your personal data, you have the right to ask AXA to limit the processing of your personal data.

Art.5(1)(c) Data Minimisation confidence 0.53

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Overall analysis

Of 23 clauses analysed, 3 were flagged and 5 were cleared, with a mean flagged-clause confidence of 0.44. The flagged clauses concern controller roles, AI governance principles, and regulatory contact information. The cleared clauses cover erasure rights, transparency, descriptions of AI systems, and limits on processing. The policy therefore contains both targeted flagged provisions and clauses that the engine read as addressing transparency and data subject rights. [auto-filed as T-0041 - pass --task next time to group it]

Notes and caveats

15 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

IKEA Retail

policy source

0.55 score

Medium risk

73 flagged

63 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium-risk policy with signals of broad-purpose data sharing, tracking through cookies, and retention tied to account activity rather than a stated end point. The dominant issues concern Article 5(1)(b) Purpose Limitation, Article 7 Consent, and Article 17 Right to Erasure, with the flagged set also including Article 28 processor provisions. Of 421 clauses analysed, 73 were flagged, with a mean flagged-clause confidence of 0.55.

How this was scored

How this was scored: 421 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 73 flagged clauses , most of them under Art.5(1)(b) Purpose Limitation violation. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 73 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

To provide our services to you, we may share your data with third parties providing services to us.

Art.5(1)(b) Purpose Limitation confidence 0.78

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

Together with our partners, we use these cookies to collect information about how you interact with our websites—such as time spent, pages visited, geolocation, audience size, usage patterns, and video usage .

ePrivacy Directive violation + Art.7 Consent confidence 0.76

Retrieved context: [GDPR Recital 30] Online Identifiers for Profiling and Identification 1. Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identi...

Your account data is kept as long as your profile is active.

Art.5(1)(e) Storage Limitation + Art.17 confidence 0.76

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

When you visit our websites (cookie statement)

ePrivacy Directive violation + Art.7 Consent confidence 0.73

Retrieved context: [GDPR Recital 64] Identity Verification 1. The controller should use all reasonable measures to verify the identity of a data subject who requests access, in particular in the context of online services and online identifiers. 2. A controller should not retain personal data for the sole purpose of b...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 63 by confidence. These are the clauses the engine read as GDPR-compliant.

You can withdraw your consent at any time.

Art.7(3) Right to Withdraw Consent confidence 0.98

Retrieved context: [GDPR Art. 7] Conditions for consent It shall be as easy to withdraw as to give consent. 8. When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the proc...

You may withdraw your consent at any time.

Art.7(3) Right to Withdraw Consent confidence 0.96

Retrieved context: [GDPR Art. 7] Conditions for consent It shall be as easy to withdraw as to give consent. 8. When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the proc...

When your personal data is needed for us, for example to meet legal obligations or to perform an agreement with you, we cannot erase your data.

Art.17 Right to Erasure confidence 0.84

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

You can ask us whether we process your personal information and if so receive a copy of such data.

Art.15 Right of Access confidence 0.82

Retrieved context: [GDPR Art. 15] Right of access by the data subject 1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:...

Overall analysis

The highest-confidence flags concern sharing data with service providers, cookie-based tracking, active-profile retention, and a cookie statement. The 63 cleared clauses cover consent withdrawal, limits on erasure where legal or contractual needs apply, and access requests. The shape of the results shows a policy that states several individual rights clearly while still drawing flags for data use, tracking, consent, and retention practices

Notes and caveats

285 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

H&M Retail

policy source

No snapshot yet.

Inditex Retail

policy source

0.37 score

Medium risk

1 flagged

0 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium, low-specificity privacy risk centered on vague, non-operational language rather than a stated processing practice. The only flagged text is a community-oriented slogan, and the flagged set has no GDPR basis match, including no identified Article 6 Lawfulness of processing basis.

How this was scored

How this was scored: 7 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 1 flagged clauses . No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 1 of 1 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

A company can make things—but it takes a community to change things.

no basis match confidence 0.37

Retrieved context: ...

Cleared clauses · what TermsGuard reads as protective

Top 0 of 0 by confidence. These are the clauses the engine read as GDPR-compliant.

No clauses were cleared.

Overall analysis

Seven clauses were analysed, with one flagged and none cleared. The policy record therefore provides one flagged example and no cleared comparison set. The 0.37 score is the mean confidence of that single flagged clause.

Notes and caveats

6 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
No clauses were cleared. The corpus has no clauses that read as GDPR-compliant by the reference comparison.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Decathlon Retail

policy source

0.59 score

Medium risk

33 flagged

18 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium-risk policy with a concentration of purpose limitation concerns around marketing and promotional use, partner use under their own notices, and collection through cookies and similar technologies. The dominant finding is Article 5(1)(b) Purpose Limitation, with 20 flagged clauses and five combined with Article 28, alongside Article 44 International Transfers, the ePrivacy Directive with Article 7 Conditions for Consent, and Article 82 Controller Liability. The flagged material concerns expanded use, processing by partners, international processing, and consent-related collection.

How this was scored

How this was scored: 88 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 33 flagged clauses , most of them under Art.5(1)(b) Purpose Limitation violation. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 33 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

We use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you online advertisements for products or services on the Services or other websites, including based on items you previously have purchased or added to your cart and other activity on the Services.

Art.5(1)(b) Purpose Limitation confidence 0.76

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Our business and marketing partners will use your information in accordance with their own privacy notices.

Art.5(1)(b) Purpose Limitation + Art.28 confidence 0.69

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

Please note that we may transfer, store and process your personal information outside the country you live in.

Art.44 International Transfers confidence 0.68

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

Automatically through the Services including from your device when you use our products or services or visit our websites, and through the use of cookies and similar technologies;

ePrivacy Directive violation + Art.7 Consent confidence 0.67

Retrieved context: [GDPR Recital 30] Online Identifiers for Profiling and Identification 1. Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identi...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 18 by confidence. These are the clauses the engine read as GDPR-compliant.

You may have a right to request that we delete personal information we maintain about you.

Art.17 Right to Erasure confidence 0.79

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

Other than the Global Privacy Control, we do not recognize other "Do Not Track" signals that may be sent from your web browser or device.

Art.5(1)(b) Purpose Limitation + ePrivacy Directive confidence 0.73

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

We will post the revised Privacy Policy on this website, update the "Last updated" date and provide notice as required by applicable law.

Art.7 Conditions for Consent + Art.13 confidence 0.71

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

Please read this Privacy Policy carefully.

Art.7 Conditions for Consent + Art.13 confidence 0.69

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

Overall analysis

Of 88 clauses analysed, 33 were flagged and 18 were cleared, with a mean flagged-clause confidence of 0.59. The cleared examples cover the right to request erasure, treatment of Do Not Track signals, notice of policy changes, and a general instruction to read the policy. This contrast shows that the engine did not flag every rights or notice provision

Notes and caveats

37 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

SAP Tech & SaaS

policy source

0.54 score

Medium risk

72 flagged

74 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium-risk policy with compliance risk focused on international data transfers and use of personal data beyond clearly matched purposes. The engine flagged Article 44 International Transfers violations, Article 5(1)(b) Purpose Limitation violations, Article 82 Controller Liability violations, and clauses with no basis match. It also identified combined Article 5(1)(b) and Article 28 concerns.

How this was scored

How this was scored: 316 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 72 flagged clauses . No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 72 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

Your personal data may be processed globally.

Art.44 International Transfers confidence 0.77

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

In conducting our international business operations, we may transfer your Personal Data to countries outside of Malaysia for the purposes described in this Privacy Statement.

Art.44 International Transfers confidence 0.74

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

In conducting our international business operations, we may transfer your Personal Data to countries outside of Thailand for the purposes described in this Privacy Statement.

Art.44 International Transfers confidence 0.72

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

Your Personal Data may be stored and processed by the SAP Group in countries outside your jurisdiction for general business purposes.

Art.44 International Transfers confidence 0.69

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 74 by confidence. These are the clauses the engine read as GDPR-compliant.

Request for the deletion of your Personal Data, under certain lawful circumstances.

Art.17 Right to Erasure confidence 0.81

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

To the extent provided by applicable data protection laws, you have the right to:

Art.7 Conditions for Consent confidence 0.75

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

Withdraw your consent for the processing of your Personal Data at any time.

Art.17 Right to Erasure confidence 0.75

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

Delete your personal data we hold about you.

Art.17 Right to Erasure confidence 0.74

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

Overall analysis

The policy contains 72 flagged clauses and 74 cleared clauses out of 316 analysed, so its text presents both risk signals and recognised rights language. The flagged examples permit global processing and transfers or storage outside Malaysia, Thailand, or the reader's jurisdiction. The cleared examples state rights to deletion and erasure, and to withdraw consent. The score of 0.54 is the mean confidence of the flagged clauses, while the cleared set is not empty.

Notes and caveats

170 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Spotify Tech & SaaS

policy source

0.52 score

Medium risk

86 flagged

55 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium privacy compliance risk centered on secondary use and retention of personal data, tailored advertising and profiling of minors, international transfers, and consent conditions. The dominant signals are Article 5(1)(b) Purpose Limitation, Article 8 and Article 22 protections concerning profiling of minors, Article 44 International Transfers, and Article 7 Conditions for Consent. It also flags Article 5(1)(e) Storage Limitation and Article 17 Right to Erasure where data may be retained after account deletion.

How this was scored

How this was scored: 279 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 86 flagged clauses . No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 86 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

After your account is deleted, we keep some data for a longer time period but for very limited purposes.

Art.5(1)(e) Storage Limitation + Art.17 confidence 0.89

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Our partners may also combine the personal data we share with them with other data they collect about you, e.g. your use of their services.

Art.5(1)(b) Purpose Limitation confidence 0.80

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

Appropriate age for tailored advertising:

Art.8 + Art.22 profiling of minors (+ likely COPPA exposure) confidence 0.72

Retrieved context: [GDPR Art. 8] Conditions applicable to child's consent in relation to information society services 1. Where point (a) of Article 6(1) applies, in relation to the offer of information society services directly to a child, the processing of the personal data of a child shall be lawful where the child ...

You will not be able to 'opt-in' to Tailored Ads if you are under the appropriate age.

Art.8 + Art.22 profiling of minors (+ likely COPPA exposure) confidence 0.72

Retrieved context: [GDPR Art. 8] Conditions applicable to child's consent in relation to information society services 1. Where point (a) of Article 6(1) applies, in relation to the offer of information society services directly to a child, the processing of the personal data of a child shall be lawful where the child ...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 55 by confidence. These are the clauses the engine read as GDPR-compliant.

To withdraw your consent, you can:

Art.7(3) Right to Withdraw Consent confidence 0.92

Retrieved context: [GDPR Art. 7] Conditions for consent It shall be as easy to withdraw as to give consent. 8. When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the proc...

It's your right to request that we delete certain of your personal data.

Art.17 Right to Erasure confidence 0.89

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

Request that we erase certain of your personal data.

Art.17 Right to Erasure confidence 0.79

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

You’ll always have the option to change your mind and withdraw your consent at any time.

Art.7(3) Right to Withdraw Consent confidence 0.78

Retrieved context: [GDPR Art. 7] Conditions for consent It shall be as easy to withdraw as to give consent. 8. When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the proc...

Overall analysis

Across 279 clauses, 86 were flagged and 55 were cleared, with a mean flagged-clause confidence of 0.52. The highest-confidence flags describe retention after deletion and partners combining shared data with data from their services, while other flags address tailored ads for users under the appropriate age. The cleared clauses state that users can withdraw consent and request erasure, so the policy contains rights language alongside clauses the engine reads as purpose, retention, and profiling concerns.

Notes and caveats

138 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Deutsche Telekom Telecom

policy source

0.54 score

Medium risk

51 flagged

30 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium-risk policy with a compliance pattern centered on purpose expansion and secondary use, international transfers, and cookie or analytics consent. The dominant flagged bases are Article 5(1)(b) Purpose Limitation, the ePrivacy Directive with Article 7 Consent, and Article 44 International Transfers, with additional flags touching storage limitation and Article 17 erasure.

How this was scored

How this was scored: 175 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 51 flagged clauses , most of them under Art.5(1)(b) Purpose Limitation violation. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 51 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

The data can be used for the partners’ advertising purposes, processed further and combined with data from other sources.

Art.5(1)(b) Purpose Limitation confidence 0.84

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

In some cases, your data may also be processed in countries outside the European Union (so-called third countries), currently including:

Art.44 International Transfers confidence 0.75

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

We use cookies and analytics technologies to get a better understanding of how our digital service is used.

ePrivacy Directive violation + Art.7 Consent confidence 0.70

Retrieved context: [GDPR Recital 30] Online Identifiers for Profiling and Identification 1. Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identi...

This data is not used to create individual user profiles, nor is it shared with third parties, and it is deleted after a maximum of seven days.

Art.5(1)(e) Storage Limitation + Art.17 confidence 0.69

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 30 by confidence. These are the clauses the engine read as GDPR-compliant.

We want you to know what personal data we collect, how it is used, and what choices you have in the process.

Art.5(1)(a) Transparency confidence 0.72

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

The respective service provider will inform you about how your personal data is processed.

Art.5(1)(a) Transparency confidence 0.71

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

What data is collected and for what purpose is it processed?

Art.5(1)(a) Transparency confidence 0.68

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

Where is my data processed?

Art.5(1)(a) Transparency confidence 0.68

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (3) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’); (4) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure t...

Overall analysis

Of 175 clauses analysed, 51 were flagged and 30 were cleared. The flagged clauses describe partner advertising, further processing and data combination, processing outside the European Union, cookie and analytics use, and a deletion statement assessed under storage limitation and erasure. The cleared clauses mainly provide transparency about collected data, processing purposes, choices, service providers, and processing locations, so the policy explains its practices while the engine identifies concerns in how those practices are used and governed.

Notes and caveats

94 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Vodafone Telecom

policy source

0.56 score

Medium risk

16 flagged

26 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This policy presents a medium privacy and consent risk centered on using customer data for marketing, advertising, and personalised recommendations. The engine primarily flagged Article 5(1)(b) Purpose Limitation, Article 7(4) Conditional consent prohibition, and Article 7 Conditions for Consent issues, alongside ePrivacy Directive consent concerns.

How this was scored

How this was scored: 82 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 16 flagged clauses , most of them under Art.5(1)(b) Purpose Limitation violation. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 16 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

With customer permission, we will use customer data to market our products and services and for advertising to provide more accurate recommendations.

Art.5(1)(b) Purpose Limitation confidence 0.71

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

In order to provide these services, we need to use our customers’ personal information.

Art.5(1)(b) Purpose Limitation confidence 0.70

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

We can provide personalised advertisements you see online, if you have consented to cookies.

ePrivacy Directive violation + Art.7 Consent confidence 0.69

Retrieved context: [GDPR Recital 58] The Principle of Transparency 1. The principle of transparency requires that any information addressed to the public or to the data subject be concise, easily accessible and easy to understand, and that clear and plain language and, additionally, where appropriate, visualisation be...

Visit our Data Privacy and Cookie Policy for more information.

ePrivacy Directive violation + Art.7 Consent confidence 0.67

Retrieved context: [GDPR Recital 6] Ensuring a High Level of Data Protection Despite the Increased Exchange of Data 1. Rapid technological developments and globalisation have brought new challenges for the protection of personal data. 2. The scale of the collection and sharing of personal data has increased significan...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 26 by confidence. These are the clauses the engine read as GDPR-compliant.

We do not sell individual data to third-parties.

Art.5(1)(b) Purpose Limitation confidence 0.95

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

For example, customers can express their opt-in consent to the use of their communications metadata for marketing purposes or for receiving third party marketing messages, or they can opt-out from marketing entirely.

Art.7 Conditions for Consent confidence 0.74

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

All permissions can be revoked and choices can be changed at any time.

Art.7(3) Right to Withdraw Consent confidence 0.71

Retrieved context: [GDPR Art. 7] Conditions for consent It shall be as easy to withdraw as to give consent. 8. When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the proc...

We do not share customers’ personal data otherwise, unless required by law or with the consent of the customer.

Art.7 Conditions for Consent confidence 0.69

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

Overall analysis

The policy contains 16 flagged clauses and 26 cleared clauses among 82 analysed, with a mean flagged-clause confidence of 0.56. The flagged text permits marketing and personalised advertising based on customer data and cookie consent; the cleared text states that individual data is not sold, consent can be opted in or out, permissions can be revoked, and sharing is limited absent law or customer consent. The shape of the results is mixed. The engine saw specific concerns about purpose and consent conditions alongside stated limits and user controls.

Notes and caveats

40 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Booking.com Travel

policy source

0.51 score

Medium risk

131 flagged

72 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a medium risk policy centered on purpose limitation, tracking, and disclosure of personal data. The engine flagged cross-session and cross-device linking, broad sharing with third parties and business partners, and sharing with advertising partners. The dominant basis is Article 5(1)(b) Purpose Limitation, alongside ePrivacy Directive findings, Article 28 findings, and Article 44 International Transfers findings.

How this was scored

How this was scored: 460 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 131 flagged clauses . No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 131 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

If you have an account on our platform, we link your browsing activity across different sessions and devices to give you a continuous experience.

ePrivacy Directive violation + Art.5(1)(b) confidence 0.77

Retrieved context: [GDPR Recital 18] Not Applicable to Personal or Household Activities 1. This Regulation does not apply to the processing of personal data by a natural person in the course of a purely personal or household activity and thus with no connection to a professional or commercial activity. 2. Personal or ...

In certain circumstances, we’ll share your personal data with third parties.

Art.5(1)(b) Purpose Limitation confidence 0.77

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

We may share some of your personal data (such as identifiers) with advertising partners, as part of the marketing of our trip services through third parties (to ensure that relevant advertisements are shown to the right audience and to measure the effectiveness of different marketing activities).

Art.5(1)(b) Purpose Limitation confidence 0.74

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

We may share personal data in other instances with other business partners.

Art.5(1)(b) Purpose Limitation confidence 0.74

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 72 by confidence. These are the clauses the engine read as GDPR-compliant.

You can ask us for a copy of the personal data we hold about you.

Art.15 Right of Access confidence 0.89

Retrieved context: [GDPR Art. 15] Right of access by the data subject 1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:...

You can ask us to erase the personal data we hold about you when, for example, it is no longer needed or we have asked for your consent and you later withdraw it.

Art.17 Right to Erasure confidence 0.80

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

Where we have collected and processed your personal data on the basis of your consent, you can withdraw that consent at any time, subject to applicable law.

Art.7(3) Right to Withdraw Consent confidence 0.80

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

We use retention practices to keep and, where possible under applicable law, dispose of personal data.

Art.5(1)(e) Storage Limitation confidence 0.74

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Overall analysis

The flagged set contains 131 clauses, including 46 with no basis match and 38 marked as Article 5(1)(b) Purpose Limitation violations. The cleared set contains 72 clauses covering access, erasure, consent withdrawal, and storage limitation. The policy therefore combines stated data subject rights and retention practices with broader tracking and sharing provisions that the engine treats as insufficiently limited.

Notes and caveats

257 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Telefónica Telecom

policy source

0.57 score

Low risk

12 flagged

35 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This is a low, targeted international transfer compliance risk. The engine flags questions about recipients, transfers outside the EEA, and safeguards for those transfers, primarily under Article 44 International Transfers and Articles 44 to 49 International Transfers. Additional flagged clauses concern Article 5(1)(b) Purpose Limitation with Article 28, and Article 7 Conditions for Consent.

How this was scored

How this was scored: 87 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 12 flagged clauses , most of them under Art.44 International Transfers violation. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 12 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

Who is the recipient of the data? are there any international transfers of data?

Art.44 International Transfers confidence 0.78

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

In general, we will avoid international transfers of data and your data will be processed within the European Economic Area.

Art.44-49 International Transfers confidence 0.71

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

However, in the event that such international transfers are necessary, we will take the necessary organisational, technical and contractual measures to ensure the protection and security of your data, such as, for example, signing the European Commission’s Standard Contractual Clauses with the authorised subcontractor or third party recipient, carrying out impact assessments on the relevant international transfer to assess the risk and adopt measures to mitigate it, encryption of data in transit or at rest, pseudonymisation of the data transferred, the possibility for the data subject to claim damages directly against the authorised subcontractor or third party recipient, etc.

Art.44-49 International Transfers confidence 0.69

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

Where authorised subcontractors acting on behalf of Telefónica or such recipients are located or process your data outside the European Economic Area, we will be making an international transfer of your data in accordance with applicable data protection legislation.

Art.44 International Transfers confidence 0.63

Retrieved context: [GDPR Art. 44] General principle for transfers 1. Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of this Regulation, the condi...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 35 by confidence. These are the clauses the engine read as GDPR-compliant.

This is your right to ask us for details of the data we hold about you and how we process it, and to obtain a copy of it.

Art.15 Right of Access confidence 0.82

Retrieved context: [GDPR Art. 15] Right of access by the data subject 1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:...

This is your right to request deletion or suppression of your data and information in certain circumstances.

Art.17 Right to Erasure confidence 0.79

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

We are 100% transparent with you about the data we collect and/or process about you and explain why we use it and for what purposes.

Art.5(1)(a) Transparency + Art.13 Right to be Informed confidence 0.74

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

How long is the data retained?

Art.5(1)(e) Storage Limitation confidence 0.70

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (5) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data wi...

Overall analysis

The flagged clauses describe conditional transfers and related processing arrangements, while the cleared clauses recognise access, erasure, transparency, and storage limitation rights. Of 87 clauses analysed, 12 were flagged and 35 were cleared, with a mean flagged-clause confidence of 0.57. The policy therefore shows concentrated transfer concerns alongside clear statements about several individual rights and information duties. [auto-filed as T-0042 - pass --task next time to group it]

Notes and caveats

40 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

Orange Telecom

policy source

No snapshot yet.

Adyen Payments

policy source

0.51 score

Medium risk

28 flagged

14 cleared

1 snapshot

Last fetched 2026-10-29 · first snapshot

Analyst summary

TermsGuard's reading: This policy presents a medium compliance risk centered on broad disclosure and data-sharing practices. The engine primarily flags Article 5(1)(b) Purpose Limitation and Article 28 Processor concerns, with additional Article 7 Consent, Article 5(1)(a) Transparency, and Article 82 Controller Liability issues. It reads the policy as permitting sharing with third parties, service providers, advisers, and group companies without consistently limiting or explaining the purposes.

How this was scored

How this was scored: 92 clauses were extracted from the policy and matched against the 102 hand-labelled reference clauses (52 fair, 50 unfair). The top match for each clause was checked against the 550-chunk reference index of the actual GDPR text (99 articles + 173 recitals), and the matching article was attached to the flag. The score is the mean confidence of the 28 flagged clauses , most of them under Art.5(1)(b) Purpose Limitation + Art.28. No model verification on this run; cosine + GDPR retrieval only.

Flagged clauses · what TermsGuard thinks you should read

Top 4 of 28 by confidence. Each clause shows the matched GDPR article and the passage the engine used.

If you would like further details on any of the third parties your personal data is “sold” to or “shared” with, would like to know the purpose of their data processing, the manner in which data is processed, or how you can communicate with such third party to exercise your data privacy rights, please contact dpo@adyen.com, or lgpd@adyen.com if you are located in Brazil.

Art.5(1)(b) Purpose Limitation confidence 0.67

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

If you have enabled the Global Privacy Control mechanism on your browser, device, or platform, you will automatically be opted out of any “sharing” when you use our website.

Art.7 Consent + Art.5(1)(a) Transparency confidence 0.62

Retrieved context: [GDPR Art. 7] Conditions for consent It shall be as easy to withdraw as to give consent. 8. When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the proc...

Where necessary, we will disclose your information to our service providers and professional advisers (e.g.

Art.5(1)(b) Purpose Limitation + Art.28 confidence 0.62

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data (6) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organ...

We may also disclose information with your permission (such as if we wish to disclose your details with another group company for their recruitment purposes).

Art.5(1)(b) Purpose Limitation + Art.28 confidence 0.61

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

Cleared clauses · what TermsGuard reads as protective

Top 4 of 14 by confidence. These are the clauses the engine read as GDPR-compliant.

Right to deletion: You may be entitled to request that we delete the personal data that we have collected from you.

Art.17 Right to Erasure confidence 0.83

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

You may have the following rights regarding your personal data, subject to to certain exceptions:

Art.17 Right to Erasure confidence 0.76

Retrieved context: [GDPR Art. 17] Right to erasure (‘right to be forgotten’) (4) the personal data have been unlawfully processed; (5) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; (6) the personal data have been collected in...

In addition, where you have given your consent for us to process personal data, you can withdraw this consent at any time.

Art.7(3) Right to Withdraw Consent confidence 0.76

Retrieved context: [GDPR Art. 7] Conditions for consent 1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data. 1. If the data subject’s consent is given in the context of a written declaration which also concer...

The table below provides a summary of the categories of personal data that we collect and disclose to service providers and other third parties.

Art.5(1)(a) Transparency confidence 0.63

Retrieved context: [GDPR Art. 5] Principles relating to processing of personal data 1. Personal data shall be: (1) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’); (2) collected for specified, explicit and legitimate purposes and not furt...

Overall analysis

The engine analysed 92 clauses, flagged 28, and cleared 14, with a mean flagged-clause confidence of 0.51. The flagged clauses focus on third-party sharing, processing purposes, service providers, professional advisers, and recruitment disclosures. The cleared clauses cover deletion rights, consent withdrawal, and a table summarising data categories disclosed to service providers and third parties. The policy therefore states several data subject rights and disclosure categories, while the flagged set concentrates on the scope and conditions of those disclosures. [auto-filed as T-0043 - pass --task next time to group it]

Notes and caveats

50 clauses were left uncertain. They sit between the fair and unfair reference sets and the engine did not commit.
The verification model is not configured for this corpus run. Cosine similarity + GDPR-article retrieval are the only signals.
This is a measurement of the published policy text, not the company's actual data-handling practice. The policy can be more or less protective than the practice.

Latest diff

No diff yet (first snapshot).

How to read this

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