MediaCloudinary and the GDPR: agreement, role and data location.
Cloudinary is a media 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
- Media
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Cloudinary do with personal data?
Store, process and deliver images and videos. That is how Privacyboard describes a typical use of Cloudinary, as a starting point you can edit.
The data usually involved: uploaded images and videos, which may show people, plus account details, file metadata and viewer IP addresses.
Is Cloudinary a processor or a controller?
Most customers use Cloudinary as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for media 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 Cloudinary store personal data?
Cloudinary does not have one fixed location for every customer. Cloudinary hosts on AWS in the US, EU and Asia-Pacific, with the US as the default.
How to find yours: Check your product environment settings or Cloudinary’s data processing agreement for the storage region.
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 Cloudinary have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Yes. Cloudinary 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: The link opens a PDF dated June 2026. The agreement takes effect when the customer signs an order form. Hosted on AWS with datacenters in the US, EU and Asia-Pacific; the US is the default.
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 Cloudinary agreementHow to declare Cloudinary
- 1
In your privacy policy
Name Cloudinary as a recipient, say what it is used for (store, process and deliver images and videos) 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 Cloudinary 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 Cloudinary 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 Cloudinary
- Get permission before uploading images or videos of identifiable people.
- Set who can view each file: private, unlisted or public.
- Check where files are stored and delivered from.
- Delete files when the reason for keeping them ends.
Questions, answered.
Is Cloudinary GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Cloudinary 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 Cloudinary have a DPA?
Yes. Cloudinary 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://cloudinary.com/gdpr/dpa.
Is Cloudinary a data processor?
Usually, yes. Most customers use Cloudinary 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 Cloudinary store data?
Cloudinary does not have one fixed location for every customer. Cloudinary hosts on AWS in the US, EU and Asia-Pacific, with the US as the default. How to find yours: Check your product environment settings or Cloudinary’s data processing agreement for the storage region.
Do I need to mention Cloudinary in my privacy policy?
Yes, if Cloudinary 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 Cloudinary to my vendor list?
In Privacyboard, pick Cloudinary 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 Cloudinary. 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.