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JFrog and the GDPR: agreement, role and data location.

JFrog is a development tool. Most customers use it as a processor, 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
Development
Usual role
Usually a processor
Data location
Set per account or project
Agreement
Published by the vendor

What does JFrog do with personal data?

Manage source code, software development and deployment workflows. That is how Privacyboard describes a typical use of JFrog, as a starting point you can edit.

The data usually involved: developer names, work email addresses, contribution metadata and information included in repositories or issues.

Is JFrog a processor or a controller?

Most customers use JFrog as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for development 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 JFrog store personal data?

JFrog 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 JFrog?

For the usual use of JFrog, companies most often rely on legitimate interests (GDPR Article 6(1)). Source code and deployment tools are needed to build and run the product.

The interest you would state: “Building, testing and deploying our software efficiently and securely.” 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 JFrog have a data processing agreement?

Checked on 5 November 2026. Vendors change their pages, so check the date.

Yes. JFrog publishes the text of its data processing agreement as a PDF 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: JFrog Cloud Data Processing Addendum (file dated Aug 2026), tied to the JFrog Cloud Terms; entity named only as JFrog. Customers choose hosting region on AWS, Azure or GCP. Relies on adequacy, DPF (JFrog, Inc.) and EU SCCs as fallback.

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 JFrog agreement

How to declare JFrog

  1. 1

    In your privacy policy

    Name JFrog as a recipient, say what it is used for (manage source code, software development and deployment workflows) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.

  2. 2

    In your vendor list

    Add JFrog 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. 3

    In your processing register

    Link JFrog 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 JFrog

  • Keep secrets and customer data out of repositories and issues.
  • Review who has access and how departures are handled.
  • Check the retention of issues, logs and deleted repositories.
  • Record the provider where personal data is processed through it.
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FAQ

Questions, answered.

Is JFrog GDPR compliant?

Privacyboard does not certify vendors. Compliance depends on how JFrog 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 JFrog have a DPA?

Yes. JFrog publishes the text of its data processing agreement as a PDF 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://media.jfrog.com/wp-content/uploads/2026/08/25122634/WD-JFROG-DPA-Online-08.11.2026.pdf.

Is JFrog a data processor?

Usually, yes. Most customers use JFrog 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 JFrog?

For the usual use of JFrog, companies most often rely on legitimate interests (GDPR Article 6(1)). Source code and deployment tools are needed to build and run the product. The interest you would state: “Building, testing and deploying our software efficiently and securely.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).

Where does JFrog store data?

JFrog 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 JFrog in my privacy policy?

Yes, if JFrog 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 JFrog to my vendor list?

In Privacyboard, pick JFrog 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 JFrog. 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.

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