CommunicationsCharles and the GDPR: agreement, role and data location.
Charles is a communications 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.
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In short
- Category
- Communications
- Usual role
- Usually a processor
- Data location
- Often the European Union, check your account
- Agreement
- Published by the vendor
What does Charles do with personal data?
Send text messages, verification codes and notifications, and handle phone calls with customers. That is how Privacyboard describes a typical use of Charles, as a starting point you can edit.
The data usually involved: phone numbers, Messages & support requests, call metadata, delivery status
Is Charles a processor or a controller?
Most customers use Charles as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for communications 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 Charles store personal data?
Charles is usually associated with the European Union, 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 Charles says (read on 2026-11-05): Client data “shall primarily be processed within the EU/the EEA”; platform on GCP in the EU Source: https://www.hello-charles.com/en/dpa
How to find yours: Check the account’s region 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.
Which legal basis usually applies to Charles?
For the usual use of Charles, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). Verification codes and service notifications are part of delivering the service; keeping logs rests on a legitimate interest.
The interest you would state: “Keeping a record of our communications to resolve disputes and improve our service.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Marketing texts and calls to individuals 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: GDPR Article 6, lawfulness of processing, EDPB Guidelines 1/2024 on legitimate interest
Does Charles have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Charles 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 Addendum for the Charles Service, last updated 13 Jul 2026. Contracting entity Charles GmbH (Berlin). Data primarily processed in the EU/EEA; platform hosted on Google Cloud in the EU. Transfers via adequacy, EU SCCs or DPF per sub-processor.
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 Charles agreementHow to declare Charles
- 1
In your privacy policy
Name Charles as a recipient, say what it is used for (send text messages, verification codes and notifications, and handle phone calls with customers) 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 Charles 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 Charles 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 Charles
- Confirm the region and any transfer outside the EEA.
- Keep the agreement text you accepted and its date.
- List the provider in your privacy policy and your processing register.
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Questions, answered.
Is Charles GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Charles 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 Charles have a DPA?
Yes. Charles 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.hello-charles.com/en/dpa.
Is Charles a data processor?
Usually, yes. Most customers use Charles 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 Charles?
For the usual use of Charles, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). Verification codes and service notifications are part of delivering the service; keeping logs rests on a legitimate interest. The interest you would state: “Keeping a record of our communications to resolve disputes and improve our service.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Charles store data?
Charles is usually associated with the European Union, 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 Charles says (read on 2026-11-05): Client data “shall primarily be processed within the EU/the EEA”; platform on GCP in the EU Source: https://www.hello-charles.com/en/dpa
Do I need to mention Charles in my privacy policy?
Yes, if Charles 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 Charles to my vendor list?
In Privacyboard, pick Charles 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 Charles. 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.