EmailClearout and the GDPR: agreement, role and data location.
Clearout is a email 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
- Usual role
- Usually a processor
- Data location
- Often North America, Europe or Asia-Pacific, check your account
- Agreement
- Published by the vendor
What does Clearout do with personal data?
Deliver transactional emails such as account notifications and password resets. That is how Privacyboard describes a typical use of Clearout, as a starting point you can edit.
The data usually involved: email addresses, Messages & support requests, delivery metadata
Is Clearout a processor or a controller?
Most customers use Clearout as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for email 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 Clearout store personal data?
Clearout is usually associated with North America, Europe or Asia-Pacific, 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 Clearout says (read on 2026-11-05): Processing regions are configured based on account requirements Source: https://clearout.io/clearout-data-processing-agreement/
How to find yours: Check your sending domain or account settings for the region.
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 Clearout?
For the usual use of Clearout, companies most often rely on performance of a contract (GDPR Article 6(1)). Transactional messages such as receipts and password resets are part of delivering the service.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Does Clearout have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Clearout 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 forming part of the Master Terms of Service; Clearout Inc., subsidiary of Datacept Technologies Private Limited. AWS hosting in North America, Europe or APAC per account; EU SCCs 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 Clearout agreementHow to declare Clearout
- 1
In your privacy policy
Name Clearout as a recipient, say what it is used for (deliver transactional emails such as account notifications and password resets) 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 Clearout 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 Clearout 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 Clearout
- Check the sending region and how message content and logs are retained.
- Avoid putting more personal data in messages than the message needs.
- Make sure bounce and complaint data is handled in line with your retention rules.
- Record the provider as a recipient of customer email addresses.
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Questions, answered.
Is Clearout GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Clearout 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 Clearout have a DPA?
Yes. Clearout 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://clearout.io/clearout-data-processing-agreement/.
Is Clearout a data processor?
Usually, yes. Most customers use Clearout 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 Clearout?
For the usual use of Clearout, companies most often rely on performance of a contract (GDPR Article 6(1)). Transactional messages such as receipts and password resets are part of delivering the service. This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Where does Clearout store data?
Clearout is usually associated with North America, Europe or Asia-Pacific, 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 Clearout says (read on 2026-11-05): Processing regions are configured based on account requirements Source: https://clearout.io/clearout-data-processing-agreement/
Do I need to mention Clearout in my privacy policy?
Yes, if Clearout 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 Clearout to my vendor list?
In Privacyboard, pick Clearout 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 Clearout. 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.