Reviews & loyaltyJudge.me and the GDPR: agreement, role and data location.
Judge.me is a reviews & loyalty 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
- Reviews & loyalty
- Usual role
- Usually a processor
- Data location
- Often United States, check your account
- Agreement
- Published by the vendor
What does Judge.me 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 Judge.me, as a starting point you can edit.
The data usually involved: customer names, email addresses, order details, reviews, points or rewards, referral and engagement data.
Is Judge.me a processor or a controller?
Most customers use Judge.me 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 Judge.me store personal data?
Judge.me is usually associated with United States, but the location can depend on your plan or settings. Privacyboard prefills it as a starting point that you should check in your account.
What Judge.me says (read on 2026-11-05): “Most Merchant Personal Data is stored in servers located within the US.” Source: https://judge.me/privacy/data-processing-addendum
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 Judge.me?
For the usual use of Judge.me, 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 Judge.me have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Judge.me 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: Data Processing Agreement, last updated 16 Oct 2026 (effective 15 Nov 2026), part of the Terms of Service. Contracting entity Judge.me Ltd (London). Says most merchant personal data is stored in the US; transfers under UK IDTA/Addendum or EU SCCs.
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 Judge.me agreementHow to declare Judge.me
- 1
In your privacy policy
Name Judge.me 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 Judge.me 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 Judge.me 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 Judge.me
- 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 Judge.me GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Judge.me 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 Judge.me have a DPA?
Yes. Judge.me 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://judge.me/privacy/data-processing-addendum.
Is Judge.me a data processor?
Usually, yes. Most customers use Judge.me 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 Judge.me?
For the usual use of Judge.me, 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 Judge.me store data?
Judge.me is usually associated with United States, but the location can depend on your plan or settings. Privacyboard prefills it as a starting point that you should check in your account. What Judge.me says (read on 2026-11-05): “Most Merchant Personal Data is stored in servers located within the US.” Source: https://judge.me/privacy/data-processing-addendum
Do I need to mention Judge.me in my privacy policy?
Yes, if Judge.me 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 Judge.me to my vendor list?
In Privacyboard, pick Judge.me 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 Judge.me. 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.