Exa Labs and the GDPR: agreement, role and data location.
Exa Labs is a search tool. Its role depends on the activity, 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
- Search
- Usual role
- Depends on the activity
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Exa Labs do with personal data?
Provide search and discovery on a website or app. That is how Privacyboard describes a typical use of Exa Labs, as a starting point you can edit.
The data usually involved: account identifiers, website & device data, usage & activity data, search queries, indexed content, any personal data included in the indexed records
Is Exa Labs a processor or a controller?
Exa publishes a Data Processing Addendum for the data you send it, such as queries and content. The web results it returns come from its own search index, which you do not control. Check how you use it, then choose the role that fits.
Privacyboard does not prefill a role for this vendor on purpose. You are asked to choose, since the answer changes what your privacy policy says and which agreement matters.
Where does Exa Labs store personal data?
Exa Labs 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 the application or cluster settings: the region is usually chosen when it is created.
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 Exa Labs?
For the usual use of Exa Labs, companies most often rely on legitimate interests (GDPR Article 6(1)). On-site search is part of the service people use.
The interest you would state: “Helping visitors find content on our website or app.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
The balancing test is yours to do: the interest must be real, the processing necessary for it, and people’s rights must not outweigh it.
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, EDPB Guidelines 1/2024 on legitimate interest
Does Exa Labs have a data processing agreement?
Checked on 9 November 2026. Vendors change their pages, so check the date.
Yes. Exa Labs 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: Exa's Data Processing Addendum page with PDF and .docx downloads; Exa Labs Inc. Undated; no hosting location stated.
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 Exa Labs agreementHow to declare Exa Labs
- 1
In your privacy policy
Name Exa Labs as a recipient, say what it is used for (provide search and discovery on a website or app) 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 Exa Labs 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 Exa Labs 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 Exa Labs
- Index only the fields you need to search.
- Decide whether queries are logged, and for how long.
- Check the region of each index or cluster.
- Remove a person’s records from the index when you delete them elsewhere.
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Questions, answered.
Is Exa Labs GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Exa Labs 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 Exa Labs have a DPA?
Yes. Exa Labs 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://exa.ai/dpa.
Is Exa Labs a data processor?
It depends on the activity. Exa publishes a Data Processing Addendum for the data you send it, such as queries and content. The web results it returns come from its own search index, which you do not control. Check how you use it, then choose the role that fits.
Which legal basis applies when I use Exa Labs?
For the usual use of Exa Labs, companies most often rely on legitimate interests (GDPR Article 6(1)). On-site search is part of the service people use. The interest you would state: “Helping visitors find content on our website or app.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Exa Labs store data?
Exa Labs 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 the application or cluster settings: the region is usually chosen when it is created.
Do I need to mention Exa Labs in my privacy policy?
Yes, if Exa Labs 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 Exa Labs to my vendor list?
In Privacyboard, pick Exa Labs 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 Exa Labs. 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.