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

Clicky is a analytics 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
Analytics
Usual role
Usually a processor
Data location
Often the United States, check your account
Agreement
Published by the vendor

What does Clicky do with personal data?

Measure website or service usage and understand visitor interactions. That is how Privacyboard describes a typical use of Clicky, as a starting point you can edit.

The data usually involved: usage events, device and browser information, user identifiers and IP addresses where collected.

Is Clicky a processor or a controller?

Usually a processor

Most customers use Clicky as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for analytics 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 Clicky store personal data?

Often the United States, check your account

Clicky is usually associated with the United States, but the location can depend on your plan or settings. Privacyboard prefills it as a starting point that you should check in your account.

How to find yours: Check your account settings or Clicky’s data processing terms for where your data is stored.

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.

Does Clicky have a data processing agreement?

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

Yes. Clicky 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: Clicky Data Processing Agreement; no version or effective date shown. Provider referred to as Roxr (Roxr Software Ltd. in footer). States personal data may be transferred to and stored in the United States, with DPF and 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 Clicky agreement

How to declare Clicky

  1. 1

    In your privacy policy

    Name Clicky as a recipient, say what it is used for (measure website or service usage and understand visitor interactions) 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 Clicky 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 Clicky 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 Clicky

  • Check whether the tool sets cookies or reads device data, and what consent that requires.
  • Say in your privacy policy what is measured and for how long it is kept.
  • Review IP address handling, data retention and the data region settings.
  • Confirm whether the provider uses the data for its own purposes.
FAQ

Questions, answered.

Is Clicky GDPR compliant?

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

Yes. Clicky 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://clicky.com/terms/dpa.

Is Clicky a data processor?

Usually, yes. Most customers use Clicky as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.

Where does Clicky store data?

Clicky is usually associated with the United States, but the location can depend on your plan or settings. Privacyboard prefills it as a starting point that you should check in your account. How to find yours: Check your account settings or Clicky’s data processing terms for where your data is stored.

Do I need to mention Clicky in my privacy policy?

Yes, if Clicky 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 Clicky to my vendor list?

In Privacyboard, pick Clicky 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 Clicky. 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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