CollaborationCircle and the GDPR: agreement, role and data location.
Circle is a collaboration tool. Most customers use it as a processor, it publishes its data processing agreement, and it usually keeps data in United States. Below: what to check and how to declare it.
Prefilled for you · Free to set up · No credit card
In short
- Category
- Collaboration
- Usual role
- Usually a processor
- Data location
- Usually United States
- Agreement
- Published by the vendor
What does Circle do with personal data?
Support internal communication, document collaboration and team administration. That is how Privacyboard describes a typical use of Circle, as a starting point you can edit.
The data usually involved: employee names, work email addresses, messages, documents and other content shared by the team.
Is Circle a processor or a controller?
Most customers use Circle as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for collaboration 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 Circle store personal data?
Circle usually keeps data in United States for every customer on its standard service, so there is normally nothing to choose. Privacyboard prefills this and you can change it if your setup differs.
What Circle says (read on 2026-11-05): Cloud hosting via AWS and Google Cloud, location listed as USA Source: https://circle.so/dpa
How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
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 Circle?
For the usual use of Circle, companies most often rely on legitimate interests (GDPR Article 6(1)). Internal communication is a normal part of running a company.
The interest you would state: “Letting our team communicate and work together efficiently.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
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 Circle have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Circle 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, undated. Contracting entity CircleCo, Inc. Sub-processor schedule lists AWS and Google Cloud hosting in the USA; transfers under SCCs Module Two with UK and Swiss addenda.
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 Circle agreementHow to declare Circle
- 1
In your privacy policy
Name Circle as a recipient, say what it is used for (support internal communication, document collaboration and team administration) 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 Circle 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 Circle 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 Circle
- Decide which kinds of personal data may be pasted into the tool, and tell the team.
- Check the retention and deletion settings for messages and files.
- Review who has admin access and how guests are handled.
- Record the data region if the plan offers a choice.
Go online for free. Grow when you need to.
Free puts you online. Pro adds requests, domains and your team; Business, your brand only.
Free
$0 forever
No card, no time limit
For getting compliant and going online on your own.
Start for freeKey features:
- Privacy and cookie policies
- Vendor and processing registers
- Requests and breaches tracked
- Impact assessment screening
- Privacy center on privacyboard.io
- Cookie banner on 1 domain
- 1 person
No card needed
ProRecommended
$32 per month
Billed $384 a year Save $84
For taking requests, covering all your sites and working as a team.
Start with ProEverything in Free, plus:
- DPA for your clients
- PDF and Excel exports
- Email reminders
- Request form and replies
- Your own domain
- Banner on 3 domains, every choice logged
- Weekly site scan
- Complete DPIAs and TIAs
- AI assistant connector
- Up to 5 people, with roles
Cancel any time
Business
$109 per month
Billed $1,308 a year Save $240
For proving it to customers and auditors, under your brand only.
Start with BusinessEverything in Pro, plus:
- No Privacyboard mention
- Security section and vendor alerts
- Evidence pack in one click
- Banner on 10 domains, daily scan
- Up to 50 people
- Two-step verification required
- Activity log kept 3 years
Bank transfer on request
Questions, answered.
Is Circle GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Circle 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 Circle have a DPA?
Yes. Circle 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://circle.so/dpa.
Is Circle a data processor?
Usually, yes. Most customers use Circle 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 Circle?
For the usual use of Circle, companies most often rely on legitimate interests (GDPR Article 6(1)). Internal communication is a normal part of running a company. The interest you would state: “Letting our team communicate and work together efficiently.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Circle store data?
Circle usually keeps data in United States for every customer on its standard service, so there is normally nothing to choose. Privacyboard prefills this and you can change it if your setup differs. What Circle says (read on 2026-11-05): Cloud hosting via AWS and Google Cloud, location listed as USA Source: https://circle.so/dpa
Do I need to mention Circle in my privacy policy?
Yes, if Circle 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 Circle to my vendor list?
In Privacyboard, pick Circle 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.
Similar tools
Compare all collaboration tools
Privacyboard is not affiliated with Circle. 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.