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Neo4j and the GDPR: agreement, role and data location.

Neo4j is a database 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
Database
Usual role
Usually a processor
Data location
Set per account or project
Agreement
Published by the vendor

What does Neo4j do with personal data?

Store and manage application records in a managed database. That is how Privacyboard describes a typical use of Neo4j, as a starting point you can edit.

The data usually involved: personal data stored in application tables, account identifiers and database logs.

Is Neo4j a processor or a controller?

Usually a processor

Most customers use Neo4j as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for database 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 Neo4j store personal data?

Set per account or project

Neo4j 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 Neo4j’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 Neo4j have a data processing agreement?

Checked on 1 November 2026. Vendors change their pages, so check the date.

Yes. Neo4j 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: Neo4j data processing addendum, last updated March 18, 2026; contracting entity is the Neo4j entity under the governing agreement. Data is hosted in the location the customer selects or configures for the cloud offering.

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 Neo4j agreement

How to declare Neo4j

  1. 1

    In your privacy policy

    Name Neo4j as a recipient, say what it is used for (store and manage application records in a managed database) 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 Neo4j 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 Neo4j 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 Neo4j

  • Confirm the region chosen when the database was created.
  • Check backup retention, since deleted records can live on in backups.
  • Review who has access to production data and how that access is logged.
  • Record any transfer outside the EEA and its safeguard.
FAQ

Questions, answered.

Is Neo4j GDPR compliant?

Privacyboard does not certify vendors. Compliance depends on how Neo4j 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 Neo4j have a DPA?

Yes. Neo4j 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://neo4j.com/legal-terms/data-processing-addendum/.

Is Neo4j a data processor?

Usually, yes. Most customers use Neo4j 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 Neo4j store data?

Neo4j 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 Neo4j’s data processing terms for where your data is stored.

Do I need to mention Neo4j in my privacy policy?

Yes, if Neo4j 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 Neo4j to my vendor list?

In Privacyboard, pick Neo4j 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 Neo4j. 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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