Consent managementCCM19 and the GDPR: agreement, role and data location.
CCM19 is a consent management tool. Most customers use it as a processor, it publishes its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
Prefilled for you · Free to set up · No credit card
In short
- Category
- Consent management
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does CCM19 do with personal data?
Show cookie notices, record visitors’ consent choices and manage privacy documents. That is how Privacyboard describes a typical use of CCM19, as a starting point you can edit.
The data usually involved: visitor consent choices, consent identifiers, IP address and device details, and the pages where consent was given.
Is CCM19 a processor or a controller?
Most customers use CCM19 as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for consent management 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 CCM19 store personal data?
CCM19 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 your account settings or the provider’s 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.
Does CCM19 have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Yes. CCM19 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 processing agreement identifies Papoo Software & Media GmbH and explains returning the completed document by email. No agreement version date or single hosting region is established.
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 CCM19 agreementHow to declare CCM19
- 1
In your privacy policy
Name CCM19 as a recipient, say what it is used for (show cookie notices, record visitors’ consent choices and manage privacy documents) 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 CCM19 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 CCM19 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 CCM19
- Check that the banner blocks non-essential tags until the visitor agrees.
- Keep consent records for as long as you may need to prove them, and no longer.
- Link your privacy policy and cookie list from the banner.
- Test the banner after any change to your site or tools.
Questions, answered.
Is CCM19 GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how CCM19 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 CCM19 have a DPA?
Yes. CCM19 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://www.ccm19.de/en/contract-processing-contract-ccm19.html.
Is CCM19 a data processor?
Usually, yes. Most customers use CCM19 as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Where does CCM19 store data?
CCM19 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 your account settings or the provider’s data processing terms.
Do I need to mention CCM19 in my privacy policy?
Yes, if CCM19 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 CCM19 to my vendor list?
In Privacyboard, pick CCM19 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.
Privacyboard is not affiliated with CCM19. 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.