CRMBitrix24 and the GDPR: agreement, role and data location.
Bitrix24 is a crm tool. Most customers use it as a processor, it explains how to get 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
- CRM
- Usual role
- Usually a processor
- Data location
- Often EU (Frankfurt) or United States, by account domain, check your account
- Agreement
- Obtained through the vendor
What does Bitrix24 do with personal data?
Manage prospect and customer relationships and sales activities. That is how Privacyboard describes a typical use of Bitrix24, as a starting point you can edit.
The data usually involved: business contact names, email addresses, company details and sales communications.
Is Bitrix24 a processor or a controller?
Most customers use Bitrix24 as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for crm tools and it is what Privacyboard suggests.
As a processor, it needs a written agreement with you under Article 28, and you should know which subprocessors it uses. Confirm the role against your own agreement, because the way you use a tool can change it.
Where does Bitrix24 store personal data?
Bitrix24 is usually associated with EU (Frankfurt) or United States, by account domain, but the location can depend on your plan or settings. Privacyboard prefills it as a starting point that you should check in your account.
What Bitrix24 says (read on 2026-11-05): EU-domain accounts hosted in Frankfurt on AWS; .com and other domains hosted in the US Source: https://bitrix24.com/gdpr/
How to find yours: Check account settings → data hosting, or the provider’s documentation.
If the data is processed outside the European Economic Area, Articles 44 to 49 require a transfer mechanism, such as standard contractual clauses, an adequacy decision or the EU-US Data Privacy Framework. Your privacy policy should name it.
Which legal basis usually applies to Bitrix24?
For the usual use of Bitrix24, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). Customer records support the contract; following up business contacts is a common legitimate interest.
The interest you would state: “Managing our relationships with customers and with business contacts who may be interested in our services.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Cold messages to individuals (not professionals) need consent. The balancing test is yours to do: the interest must be real, the processing necessary for it, and people’s rights must not outweigh it.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Sources: CNIL: rules for prospecting by email, EDPB Guidelines 1/2024 on legitimate interest
Does Bitrix24 have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Bitrix24 does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy.
What we noted when we opened the page: GDPR page says EU customers are provided a digitally signed Data Processing Agreement plus infrastructure and sub-processor info. Hosting depends on account domain: AWS Frankfurt for EU domains, US for .com and others, relying on the EU-U.S. DPF.
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.
Open the Bitrix24 reference pageHow to declare Bitrix24
- 1
In your privacy policy
Name Bitrix24 as a recipient, say what it is used for (manage prospect and customer relationships and sales activities) 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 Bitrix24 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 Bitrix24 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 Bitrix24
- Define a retention period for inactive leads and contacts.
- Make sure you can find, export and delete one contact across the CRM.
- Record the legal basis for outreach, and respect objections to marketing.
- Record the region and any transfer outside the EEA.
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Questions, answered.
Is Bitrix24 GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Bitrix24 is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it explains how to get a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does Bitrix24 have a DPA?
Bitrix24 does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy. The reference page is https://bitrix24.com/gdpr/.
Is Bitrix24 a data processor?
Usually, yes. Most customers use Bitrix24 as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Which legal basis applies when I use Bitrix24?
For the usual use of Bitrix24, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). Customer records support the contract; following up business contacts is a common legitimate interest. The interest you would state: “Managing our relationships with customers and with business contacts who may be interested in our services.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Bitrix24 store data?
Bitrix24 is usually associated with EU (Frankfurt) or United States, by account domain, but the location can depend on your plan or settings. Privacyboard prefills it as a starting point that you should check in your account. What Bitrix24 says (read on 2026-11-05): EU-domain accounts hosted in Frankfurt on AWS; .com and other domains hosted in the US Source: https://bitrix24.com/gdpr/
Do I need to mention Bitrix24 in my privacy policy?
Yes, if Bitrix24 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 Bitrix24 to my vendor list?
In Privacyboard, pick Bitrix24 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 Bitrix24. 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.