InfrastructureCloudflare and the GDPR: agreement, role and data location.
Cloudflare is a infrastructure 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
- Infrastructure
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Cloudflare do with personal data?
Provide DNS, content delivery and application security for enabled Cloudflare services. That is how Privacyboard describes a typical use of Cloudflare, as a starting point you can edit.
The data usually involved: iP addresses, HTTP request metadata, security logs and content passing through enabled services.
Is Cloudflare a processor or a controller?
Most customers use Cloudflare as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for infrastructure 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 Cloudflare store personal data?
Cloudflare does not have one fixed location for every customer. Global by default.
How to find yours: Cloudflare traffic is processed in the datacenter closest to the visitor. Check Data Localization options in your plan.
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 Cloudflare have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Yes. Cloudflare 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.
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 Cloudflare agreementHow to declare Cloudflare
- 1
In your privacy policy
Name Cloudflare as a recipient, say what it is used for (provide DNS, content delivery and application security for enabled Cloudflare services) 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 Cloudflare 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 Cloudflare 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 Cloudflare
- Check which services are enabled and what logs they keep.
- Review log retention and any regional processing options.
- Record IP addresses and request metadata in your policy where relevant.
- Record transfers outside the EEA and their safeguard.
Questions, answered.
Is Cloudflare GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Cloudflare 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 Cloudflare have a DPA?
Yes. Cloudflare 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://www.cloudflare.com/cloudflare-customer-dpa/.
Is Cloudflare a data processor?
Usually, yes. Most customers use Cloudflare 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 Cloudflare store data?
Cloudflare does not have one fixed location for every customer. Global by default. How to find yours: Cloudflare traffic is processed in the datacenter closest to the visitor. Check Data Localization options in your plan.
Do I need to mention Cloudflare in my privacy policy?
Yes, if Cloudflare 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 Cloudflare to my vendor list?
In Privacyboard, pick Cloudflare 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 Cloudflare. 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.