Consent managementCookiebot and the GDPR: agreement, role and data location.
Cookiebot is a consent management tool. Most customers use it as a processor, it publishes its data processing agreement, and it usually keeps data in EU/EEA. Below: what to check and how to declare it.
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In short
- Category
- Consent management
- Usual role
- Usually a processor
- Data location
- Usually EU/EEA
- Agreement
- Published by the vendor
What does Cookiebot do with personal data?
Show cookie notices, record visitors’ consent choices and manage privacy documents. That is how Privacyboard describes a typical use of Cookiebot, as a starting point you can edit.
The data usually involved: visitor consent choices, consent identifiers, IP address and device details, and the pages where consent was given.
Is Cookiebot a processor or a controller?
Most customers use Cookiebot as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for consent management 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 Cookiebot store personal data?
Cookiebot usually keeps data in EU/EEA for every customer on its standard service, so there is normally nothing to choose. Privacyboard prefills this and you can change it if your setup differs.
What Cookiebot says (read on 2026-11-05): “The processing of the Controller data by the Processor takes place within the EU / EEA.” Source: https://www.cookiebot.com/en/data-processing-agreement/
How to find yours: Check your account settings or the provider’s data processing terms.
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 Cookiebot?
For the usual use of Cookiebot, companies most often rely on legal obligation (GDPR Article 6(1)). Asking for consent before using cookies, and being able to show it was given, are required by law (GDPR Article 7(1) and the ePrivacy rules).
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, CNIL: cookies and other trackers, questions and answers
Does Cookiebot have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Cookiebot 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: Usercentrics Contract – Data Processing Agreement, undated, tied to the terms of service. Processor is Usercentrics A/S (Copenhagen). Says processing takes place within the EU/EEA; generic reference to SCCs for third-country transfers.
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 Cookiebot agreementHow to declare Cookiebot
- 1
In your privacy policy
Name Cookiebot as a recipient, say what it is used for (show cookie notices, record visitors’ consent choices and manage privacy documents) 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 Cookiebot 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 Cookiebot 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 Cookiebot
- Check that the banner blocks non-essential tags until the visitor agrees.
- Keep consent records for as long as you may need to prove them, and no longer.
- Link your privacy policy and cookie list from the banner.
- Test the banner after any change to your site or tools.
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Questions, answered.
Is Cookiebot GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Cookiebot 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 Cookiebot have a DPA?
Yes. Cookiebot 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.cookiebot.com/en/data-processing-agreement/.
Is Cookiebot a data processor?
Usually, yes. Most customers use Cookiebot 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 Cookiebot?
For the usual use of Cookiebot, companies most often rely on legal obligation (GDPR Article 6(1)). Asking for consent before using cookies, and being able to show it was given, are required by law (GDPR Article 7(1) and the ePrivacy rules). This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Where does Cookiebot store data?
Cookiebot usually keeps data in EU/EEA for every customer on its standard service, so there is normally nothing to choose. Privacyboard prefills this and you can change it if your setup differs. What Cookiebot says (read on 2026-11-05): “The processing of the Controller data by the Processor takes place within the EU / EEA.” Source: https://www.cookiebot.com/en/data-processing-agreement/
Do I need to mention Cookiebot in my privacy policy?
Yes, if Cookiebot 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 Cookiebot to my vendor list?
In Privacyboard, pick Cookiebot 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 Cookiebot. 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.