SearchClerk.io and the GDPR: agreement, role and data location.
Clerk.io is a search 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
- Search
- Usual role
- Usually a processor
- Data location
- Often EU/EEA, check your account
- Agreement
- Published by the vendor
What does Clerk.io do with personal data?
Provide search and discovery on a website or app. That is how Privacyboard describes a typical use of Clerk.io, as a starting point you can edit.
The data usually involved: search queries, indexed content, device and usage identifiers, and any personal data included in the indexed records.
Is Clerk.io a processor or a controller?
Most customers use Clerk.io as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for search 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 Clerk.io store personal data?
Clerk.io is usually associated with EU/EEA, 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 Clerk.io says (read on 2026-11-05): “The Service is generally provided from within the EU/EEA” Source: https://trust.clerk.io/gdpr/data-processing-agreement
How to find yours: Check the application or cluster settings: the region is usually chosen when it is created.
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 Clerk.io?
For the usual use of Clerk.io, companies most often rely on legitimate interests (GDPR Article 6(1)). On-site search is part of the service people use.
The interest you would state: “Helping visitors find content on our website or app.” 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 Clerk.io have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Clerk.io 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 on the Clerk.io Trust Center, updated 22 Dec 2025; parties not named beyond controller and processor (footer Clerk.io, Inc.). Says the service is generally provided from the EU/EEA; transfers may rely on SCCs.
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 Clerk.io agreementHow to declare Clerk.io
- 1
In your privacy policy
Name Clerk.io as a recipient, say what it is used for (provide search and discovery on a website or app) 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 Clerk.io 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 Clerk.io 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 Clerk.io
- Index only the fields you need to search.
- Decide whether queries are logged, and for how long.
- Check the region of each index or cluster.
- Remove a person’s records from the index when you delete them elsewhere.
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Questions, answered.
Is Clerk.io GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Clerk.io 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 Clerk.io have a DPA?
Yes. Clerk.io 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://trust.clerk.io/gdpr/data-processing-agreement.
Is Clerk.io a data processor?
Usually, yes. Most customers use Clerk.io 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 Clerk.io?
For the usual use of Clerk.io, companies most often rely on legitimate interests (GDPR Article 6(1)). On-site search is part of the service people use. The interest you would state: “Helping visitors find content on our website or app.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Clerk.io store data?
Clerk.io is usually associated with EU/EEA, 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 Clerk.io says (read on 2026-11-05): “The Service is generally provided from within the EU/EEA” Source: https://trust.clerk.io/gdpr/data-processing-agreement
Do I need to mention Clerk.io in my privacy policy?
Yes, if Clerk.io 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 Clerk.io to my vendor list?
In Privacyboard, pick Clerk.io 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 Clerk.io. 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.