AnalyticsHeap and the GDPR: agreement, role and data location.
Heap is a analytics 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
- Analytics
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Obtained through the vendor
What does Heap do with personal data?
Measure website or service usage and understand visitor interactions. That is how Privacyboard describes a typical use of Heap, as a starting point you can edit.
The data usually involved: usage events, device and browser information, user identifiers and IP addresses where collected.
Is Heap a processor or a controller?
Most customers use Heap as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for analytics 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 Heap store personal data?
Heap 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 or Heap’s data processing terms for where your data is stored.
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 Heap have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Heap 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: Heap legal hub listing its contract documents, including a Data Processing Addendum link that points to a Contentsquare-hosted page. No date, contracting entity or hosting location is stated on the hub itself.
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 Heap reference pageHow to declare Heap
- 1
In your privacy policy
Name Heap as a recipient, say what it is used for (measure website or service usage and understand visitor interactions) 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 Heap 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 Heap 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 Heap
- Check whether the tool sets cookies or reads device data, and what consent that requires.
- Say in your privacy policy what is measured and for how long it is kept.
- Review IP address handling, data retention and the data region settings.
- Confirm whether the provider uses the data for its own purposes.
Questions, answered.
Is Heap GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Heap 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 Heap have a DPA?
Heap 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.heap.io/legal.
Is Heap a data processor?
Usually, yes. Most customers use Heap 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 Heap store data?
Heap 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 or Heap’s data processing terms for where your data is stored.
Do I need to mention Heap in my privacy policy?
Yes, if Heap 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 Heap to my vendor list?
In Privacyboard, pick Heap 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 Heap. 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.