Expense managementNavan and the GDPR: agreement, role and data location.
Navan is a expense management 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
- Expense management
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Navan do with personal data?
Manage company cards, expense reports, receipts and business travel. That is how Privacyboard describes a typical use of Navan, as a starting point you can edit.
The data usually involved: employee names, contact details, card and transaction data, receipts and travel details.
Is Navan a processor or a controller?
Most customers use Navan as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for expense management 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 Navan store personal data?
Navan 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 Navan?
For the usual use of Navan, companies most often rely on legal obligation and legitimate interests (GDPR Article 6(1)). Receipts and expenses must be kept for accounting and tax purposes; managing company cards rests on a legitimate interest.
The interest you would state: “Controlling company spending and reimbursing employees for business expenses.” 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 Navan have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Navan 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 Addendum, revision September 2026, with Navan, Inc. and affiliates as processor. No hosting location; refers to the Trust Center sub-processor list. Transfers use SCCs Module 2, UK Addendum and Swiss amendments, with DPF taking precedence.
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 Navan agreementHow to declare Navan
- 1
In your privacy policy
Name Navan as a recipient, say what it is used for (manage company cards, expense reports, receipts and business travel) 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 Navan 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 Navan 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 Navan
- Limit who can see individual expenses, and review access when someone leaves.
- Check that receipts are kept only as long as accounting law requires.
- Check the role of the card issuer, which often acts as an independent controller for payment checks.
- Record the region and any transfer outside the EEA.
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Questions, answered.
Is Navan GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Navan 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 Navan have a DPA?
Yes. Navan 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://navan.com/dpa.
Is Navan a data processor?
Usually, yes. Most customers use Navan 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 Navan?
For the usual use of Navan, companies most often rely on legal obligation and legitimate interests (GDPR Article 6(1)). Receipts and expenses must be kept for accounting and tax purposes; managing company cards rests on a legitimate interest. The interest you would state: “Controlling company spending and reimbursing employees for business expenses.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Navan store data?
Navan 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 Navan in my privacy policy?
Yes, if Navan 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 Navan to my vendor list?
In Privacyboard, pick Navan 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 Navan. 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.