LearningDocebo and the GDPR: agreement, role and data location.
Docebo is a learning tool. Most customers use it as a processor, it explains how to get 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
- Learning
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Obtained through the vendor
What does Docebo do with personal data?
Host online courses, communities or training and manage learners. That is how Privacyboard describes a typical use of Docebo, as a starting point you can edit.
The data usually involved: names, email addresses, payment details, progress, completion data, community posts
Is Docebo a processor or a controller?
Most customers use Docebo as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for learning 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 Docebo store personal data?
Docebo does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.
How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
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 Docebo?
For the usual use of Docebo, companies most often rely on performance of a contract (GDPR Article 6(1)). Giving access to a course or community the person signed up for is the contract.
Marketing to learners and analytics beyond course progress need their own basis.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Does Docebo have a data processing agreement?
Checked on 12 November 2026. Vendors change their pages, so check the date.
Docebo does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy.
What we noted when we opened the page: Docebo Software Addendums Packs (last updated October 2026): processing of personal data through the Software Services is governed by Docebo's Data Processing Addendum, with Docebo acting as the customer's processor (stated for AI functionalities). The DPA is published separately on docebo.com; no hosting region or entity named on this page.
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.
Open the Docebo reference pageHow to declare Docebo
- 1
In your privacy policy
Name Docebo as a recipient, say what it is used for (host online courses, communities or training and manage learners) 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 Docebo 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 Docebo 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 Docebo
- Check what learners can see about each other in communities and forums.
- Set what happens to accounts and progress when access ends.
- Check the role of the payment provider built into the platform.
- Record the region and any transfer outside the EEA.
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Questions, answered.
Is Docebo GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Docebo is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it explains how to get a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does Docebo have a DPA?
Docebo does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy. The reference page is https://www.docebo.com/company/software-addendums-packs/.
Is Docebo a data processor?
Usually, yes. Most customers use Docebo 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 Docebo?
For the usual use of Docebo, companies most often rely on performance of a contract (GDPR Article 6(1)). Giving access to a course or community the person signed up for is the contract. Marketing to learners and analytics beyond course progress need their own basis.
Where does Docebo store data?
Docebo does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Do I need to mention Docebo in my privacy policy?
Yes, if Docebo 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 Docebo to my vendor list?
In Privacyboard, pick Docebo 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 Docebo. 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.