Reviews & loyaltyGrowSurf and the GDPR: agreement, role and data location.
GrowSurf is a reviews & loyalty tool. Most customers use it as a processor, it explains how to get its data processing agreement, and it usually keeps data in United States. Below: what to check and how to declare it.
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In short
- Category
- Reviews & loyalty
- Usual role
- Usually a processor
- Data location
- Usually United States
- Agreement
- Obtained through the vendor
What does GrowSurf do with personal data?
Collect customer reviews, run loyalty, referral or affiliate programs and send related messages. That is how Privacyboard describes a typical use of GrowSurf, as a starting point you can edit.
The data usually involved: names, Email addresses, Contract & billing data, reviews, points, rewards, referral, engagement data
Is GrowSurf a processor or a controller?
Most customers use GrowSurf as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for reviews & loyalty 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 GrowSurf store personal data?
GrowSurf usually keeps data in United States 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 GrowSurf says (read on 2026-11-05): Infrastructure in DigitalOcean SFO2 (San Francisco) and Google Cloud us-central1 (Iowa) Source: https://gdpr.growsurf.com
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.
If the data is processed outside the European Economic Area, Articles 44 to 49 require a transfer mechanism, such as standard contractual clauses, an adequacy decision or the EU-US Data Privacy Framework. Your privacy policy should name it.
Which legal basis usually applies to GrowSurf?
For the usual use of GrowSurf, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). A loyalty program the customer joined is a contract; a review request after a purchase usually rests on a legitimate interest.
The interest you would state: “Asking customers for a review of their purchase and rewarding loyal customers.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Publishing a review with the author’s name needs their agreement, and review requests must be easy to refuse. 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 GrowSurf have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
GrowSurf 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: GrowSurf GDPR portal page explaining that accepting the Terms of Service also accepts the DPA, with no separate signature; DPA text hosted externally. Portal says production runs on DigitalOcean SFO2 and Google Cloud us-central1, with SCCs and UK Addendum.
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 GrowSurf reference pageHow to declare GrowSurf
- 1
In your privacy policy
Name GrowSurf as a recipient, say what it is used for (collect customer reviews, run loyalty, referral or affiliate programs and send related messages) 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 GrowSurf 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 GrowSurf 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 GrowSurf
- Check which emails the tool sends and that each one offers an easy way to stop them.
- Decide how reviews are published: first name only, initials, or full name with agreement.
- Check how long points, reviews and referral data are kept.
- Record the region and any transfer outside the EEA.
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Questions, answered.
Is GrowSurf GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how GrowSurf 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 GrowSurf have a DPA?
GrowSurf 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://gdpr.growsurf.com/dpa.
Is GrowSurf a data processor?
Usually, yes. Most customers use GrowSurf 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 GrowSurf?
For the usual use of GrowSurf, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). A loyalty program the customer joined is a contract; a review request after a purchase usually rests on a legitimate interest. The interest you would state: “Asking customers for a review of their purchase and rewarding loyal customers.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does GrowSurf store data?
GrowSurf usually keeps data in United States 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 GrowSurf says (read on 2026-11-05): Infrastructure in DigitalOcean SFO2 (San Francisco) and Google Cloud us-central1 (Iowa) Source: https://gdpr.growsurf.com
Do I need to mention GrowSurf in my privacy policy?
Yes, if GrowSurf 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 GrowSurf to my vendor list?
In Privacyboard, pick GrowSurf 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 GrowSurf. 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.