Payments2Checkout and the GDPR: agreement, role and data location.
2Checkout is a payments tool. Its role depends on the activity, it publishes its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
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In short
- Category
- Payments
- Usual role
- Depends on the activity
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does 2Checkout do with personal data?
Manage customer payments, subscriptions where applicable, invoicing and billing. That is how Privacyboard describes a typical use of 2Checkout, as a starting point you can edit.
The data usually involved: customer names, email addresses, billing addresses, transaction identifiers and payment information handled by the provider.
Is 2Checkout a processor or a controller?
2Checkout states both it and the merchant are independent controllers of shopper data, acting as merchant of record/reseller.
Privacyboard does not prefill a role for this vendor on purpose. You are asked to choose, since the answer changes what your privacy policy says and which agreement matters.
Where does 2Checkout store personal data?
2Checkout does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.
How to find yours: Check the provider’s privacy center or data processing terms.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Which legal basis usually applies to 2Checkout?
For the usual use of 2Checkout, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Taking payment is part of the contract, and invoices must be kept as accounting and tax law requires.
Many payment providers also act as independent controllers for fraud prevention and legal checks, on their own basis.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Does 2Checkout have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. 2Checkout publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep.
What we noted when we opened the page: Data Privacy Provisions (current version; earlier v02 dated 1 Jan 2020). Parties Verifone Payments B.V. (formerly Avangate B.V.), 2Checkout.com Inc and Avangate Inc. No hosting location or specific transfer mechanism named.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Read the 2Checkout agreementHow to declare 2Checkout
- 1
In your privacy policy
Name 2Checkout as a recipient, say what it is used for (manage customer payments, subscriptions where applicable, invoicing and billing) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add 2Checkout with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link 2Checkout to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on 2Checkout
- Work out whether the provider acts as your processor, as an independent controller, or as both for different activities.
- Say in your privacy policy that payment data is handled by the provider and for what purpose.
- Record the provider as a recipient of customer names, emails and transaction data.
- Check retention rules the provider applies for legal and fraud reasons.
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Questions, answered.
Is 2Checkout GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how 2Checkout is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it publishes a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does 2Checkout have a DPA?
Yes. 2Checkout publishes the text of its data processing agreement on its own website. Article 28 of the GDPR requires a written contract with every processor, so this is the document to read and keep. You can read it at https://2checkout.com/legal/data-privacy-provisions.
Is 2Checkout a data processor?
It depends on the activity. 2Checkout states both it and the merchant are independent controllers of shopper data, acting as merchant of record/reseller.
Which legal basis applies when I use 2Checkout?
For the usual use of 2Checkout, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Taking payment is part of the contract, and invoices must be kept as accounting and tax law requires. Many payment providers also act as independent controllers for fraud prevention and legal checks, on their own basis.
Where does 2Checkout store data?
2Checkout does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. How to find yours: Check the provider’s privacy center or data processing terms.
Do I need to mention 2Checkout in my privacy policy?
Yes, if 2Checkout handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add 2Checkout to my vendor list?
In Privacyboard, pick 2Checkout from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
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Privacyboard is not affiliated with 2Checkout. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.