AuthenticationMemberful and the GDPR: agreement, role and data location.
Memberful is a authentication 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
- Authentication
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Memberful do with personal data?
Authenticate users and manage application sessions and access. That is how Privacyboard describes a typical use of Memberful, as a starting point you can edit.
The data usually involved: names, email addresses, user identifiers, IP addresses and authentication logs.
Is Memberful a processor or a controller?
Most customers use Memberful as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for authentication 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 Memberful store personal data?
Memberful 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 Memberful’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 Memberful have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Yes. Memberful 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: Memberful Data Protection Addendum; changelog shows updates of 27 Jun 2022 and 15 Mar 2024. Contracting entity is Memberful, LLC (San Francisco). Says European data is processed in data centers outside the EEA, UK and Switzerland, with SCCs for transfers.
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 Memberful agreementHow to declare Memberful
- 1
In your privacy policy
Name Memberful as a recipient, say what it is used for (authenticate users and manage application sessions and access) 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 Memberful 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 Memberful 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 Memberful
- Confirm where user records are stored and whether you can choose the region.
- Check how long sign-in logs are kept and how users are deleted.
- Keep the provider in your privacy policy as a recipient of account data.
- Review the provider’s security documentation for the controls you rely on.
Questions, answered.
Is Memberful GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Memberful 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 Memberful have a DPA?
Yes. Memberful 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://memberful.com/dpa/.
Is Memberful a data processor?
Usually, yes. Most customers use Memberful 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 Memberful store data?
Memberful 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 Memberful’s data processing terms for where your data is stored.
Do I need to mention Memberful in my privacy policy?
Yes, if Memberful 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 Memberful to my vendor list?
In Privacyboard, pick Memberful 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 Memberful. 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.