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Clearbit and the GDPR: agreement, role and data location.

Clearbit is a crm 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
CRM
Usual role
Depends on the activity
Data location
Set per account or project
Agreement
Published by the vendor

What does Clearbit do with personal data?

Manage prospect and customer relationships and sales activities. That is how Privacyboard describes a typical use of Clearbit, as a starting point you can edit.

The data usually involved: business contact names, email addresses, company details and sales communications.

Is Clearbit a processor or a controller?

Depends on the activity

As a data provider Clearbit often acts as an independent controller for the enrichment data it supplies, and as a processor for customer-submitted data.

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 Clearbit store personal data?

Set per account or project

Clearbit 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 Clearbit’s data processing terms for where your data is stored.

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 Clearbit have a data processing agreement?

Checked on 1 November 2026. Vendors change their pages, so check the date.

Yes. Clearbit publishes the text of its data processing agreement as a PDF 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: Clearbit Data Processing Addendum, version last modified 1 Mar 2024; entity APIHub, Inc. dba Clearbit. Says data may be processed in the US and elsewhere. Clearbit now belongs to HubSpot, so check current status.

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 Clearbit agreement

How to declare Clearbit

  1. 1

    In your privacy policy

    Name Clearbit 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. 2

    In your vendor list

    Add Clearbit 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. 3

    In your processing register

    Link Clearbit 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 Clearbit

  • 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.
FAQ

Questions, answered.

Is Clearbit GDPR compliant?

Privacyboard does not certify vendors. Compliance depends on how Clearbit 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 Clearbit have a DPA?

Yes. Clearbit publishes the text of its data processing agreement as a PDF 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://clearbit.com/Clearbit_DPA_20MAR2024.pdf.

Is Clearbit a data processor?

It depends on the activity. As a data provider Clearbit often acts as an independent controller for the enrichment data it supplies, and as a processor for customer-submitted data.

Where does Clearbit store data?

Clearbit 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 Clearbit’s data processing terms for where your data is stored.

Do I need to mention Clearbit in my privacy policy?

Yes, if Clearbit 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 Clearbit to my vendor list?

In Privacyboard, pick Clearbit 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 Clearbit. 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.

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