EmailMailgun and the GDPR: agreement, role and data location.
Mailgun is a email 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
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Mailgun do with personal data?
Deliver transactional emails such as account notifications and password resets. That is how Privacyboard describes a typical use of Mailgun, as a starting point you can edit.
The data usually involved: recipient email addresses, message content and delivery metadata.
Is Mailgun a processor or a controller?
Most customers use Mailgun as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for email 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 Mailgun store personal data?
Mailgun 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 sending domain or account settings for the region.
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 Mailgun?
For the usual use of Mailgun, companies most often rely on performance of a contract (GDPR Article 6(1)). Transactional messages such as receipts and password resets are part of delivering the service.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Does Mailgun have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Yes. Mailgun 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: Linked as the Mailgun DPA from mailgun.com/gdpr: the Sinch Data Processing Agreement, version 8 of 29 October 2025. Transfers rely on standard contractual clauses and, for Sinch Email, the EU-U.S. Data Privacy Framework. No hosting region stated.
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 Mailgun agreementHow to declare Mailgun
- 1
In your privacy policy
Name Mailgun as a recipient, say what it is used for (deliver transactional emails such as account notifications and password resets) 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 Mailgun 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 Mailgun 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 Mailgun
- Check the sending region and how message content and logs are retained.
- Avoid putting more personal data in messages than the message needs.
- Make sure bounce and complaint data is handled in line with your retention rules.
- Record the provider as a recipient of customer email addresses.
Questions, answered.
Is Mailgun GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Mailgun 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 Mailgun have a DPA?
Yes. Mailgun 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://sinch.com/legal/terms-and-conditions/other-sinch-terms-conditions/data-protection-agreement/.
Is Mailgun a data processor?
Usually, yes. Most customers use Mailgun 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 Mailgun?
For the usual use of Mailgun, companies most often rely on performance of a contract (GDPR Article 6(1)). Transactional messages such as receipts and password resets are part of delivering the service. This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Where does Mailgun store data?
Mailgun 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 sending domain or account settings for the region.
Do I need to mention Mailgun in my privacy policy?
Yes, if Mailgun 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 Mailgun to my vendor list?
In Privacyboard, pick Mailgun 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 Mailgun. 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.