HostingHeroku and the GDPR: agreement, role and data location.
Heroku is a hosting 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
- Hosting
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Obtained through the vendor
What does Heroku do with personal data?
Host business websites, online services or other company systems. That is how Privacyboard describes a typical use of Heroku, as a starting point you can edit.
The data usually involved: website or service content, account identifiers, IP addresses and server logs where applicable.
Is Heroku a processor or a controller?
Most customers use Heroku as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for hosting 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 Heroku store personal data?
Heroku 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 Heroku’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 Heroku have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Heroku 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: Heroku Help article on getting the DPA. Says there is no Heroku-specific DPA; one Salesforce DPA covers all Salesforce services including Heroku, linked as a PDF. No date, entity or data-location statement on the 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 Heroku reference pageHow to declare Heroku
- 1
In your privacy policy
Name Heroku as a recipient, say what it is used for (host business websites, online services or other company systems) 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 Heroku 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 Heroku 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 Heroku
- Confirm the region of every service you use, since it is often chosen per project or per resource.
- If any region is outside the EEA, record the transfer safeguard (SCCs, adequacy decision or Data Privacy Framework).
- Check the provider’s subprocessor list and how it announces changes.
- Keep the agreement text you accepted and the date you accepted it.
Questions, answered.
Is Heroku GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Heroku 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 Heroku have a DPA?
Heroku 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://help.heroku.com/B4E5QFQQ/where-do-i-get-copy-of-dpa-from-heroku.
Is Heroku a data processor?
Usually, yes. Most customers use Heroku 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 Heroku store data?
Heroku 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 Heroku’s data processing terms for where your data is stored.
Do I need to mention Heroku in my privacy policy?
Yes, if Heroku 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 Heroku to my vendor list?
In Privacyboard, pick Heroku 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 Heroku. 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.