Expense managementPayhawk and the GDPR: agreement, role and data location.
Payhawk is a expense management tool. Its role depends on the activity, 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
- Depends on the activity
- Data location
- Often Belgium and Germany, check your account
- Agreement
- Published by the vendor
What does Payhawk do with personal data?
Manage company cards, expense reports, receipts and business travel. That is how Privacyboard describes a typical use of Payhawk, as a starting point you can edit.
The data usually involved: employee names, contact details, card and transaction data, receipts and travel details.
Is Payhawk a processor or a controller?
Cards are issued by Payhawk's regulated payment entities, which run their own compliance checks as controller.
Privacyboard does not prefill a role for this vendor on purpose. You are asked to choose, since the answer changes what your privacy policy says and which agreement matters.
Where does Payhawk store personal data?
Payhawk is usually associated with Belgium and Germany, 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 Payhawk says (read on 2026-11-05): Platform provider location: “Belgium and Germany (LLMs hosted on Google Cloud)” Source: https://payhawk.com/dpa
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 Payhawk?
For the usual use of Payhawk, 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 Payhawk have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Payhawk 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, last updated 26 Jun 2026, for customers signed from 18 Aug 2025, with the relevant Payhawk contracting party. Lists platform provider Payhawk EOOD in Belgium and Germany (Google Cloud); transfers must comply with GDPR Chapter V.
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 Payhawk agreementHow to declare Payhawk
- 1
In your privacy policy
Name Payhawk 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 Payhawk 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 Payhawk 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 Payhawk
- 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 Payhawk GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Payhawk 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 Payhawk have a DPA?
Yes. Payhawk 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://payhawk.com/dpa.
Is Payhawk a data processor?
It depends on the activity. Cards are issued by Payhawk's regulated payment entities, which run their own compliance checks as controller.
Which legal basis applies when I use Payhawk?
For the usual use of Payhawk, 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 Payhawk store data?
Payhawk is usually associated with Belgium and Germany, 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 Payhawk says (read on 2026-11-05): Platform provider location: “Belgium and Germany (LLMs hosted on Google Cloud)” Source: https://payhawk.com/dpa
Do I need to mention Payhawk in my privacy policy?
Yes, if Payhawk 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 Payhawk to my vendor list?
In Privacyboard, pick Payhawk 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 Payhawk. 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.