Expense managementPleo and the GDPR: agreement, role and data location.
Pleo 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.
Prefilled for you · Free to set up · No credit card
In short
- Category
- Expense management
- Usual role
- Depends on the activity
- Data location
- Often Ireland (AWS eu-west-1), check your account
- Agreement
- Published by the vendor
What does Pleo do with personal data?
Manage company cards, expense reports, receipts and business travel. That is how Privacyboard describes a typical use of Pleo, as a starting point you can edit.
The data usually involved: employee names, contact details, card and transaction data, receipts and travel details.
Is Pleo a processor or a controller?
As a licensed payment provider, Pleo processes some data as controller, e.g. for anti-money laundering.
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 Pleo store personal data?
Pleo is usually associated with Ireland (AWS eu-west-1), 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 Pleo says (read on 2026-11-05): Primary servers in AWS eu-west-1 Ireland, secondary backups in Frankfurt Source: https://help.pleo.io/en/articles/6967661-q-a-on-gdpr
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 Pleo?
For the usual use of Pleo, 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 Pleo have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Pleo publishes the text of its data processing agreement as a PDF 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 Agreement, effective 14 Oct 2025, with Pleo Technologies A/S, Pleo Financial Services A/S and Pleo Financial Services UK Ltd. Transfers rely on adequacy, 2021 SCCs or the UK Addendum; allows Pleo controller processing (e.g. AML).
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 Pleo agreementHow to declare Pleo
- 1
In your privacy policy
Name Pleo 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 Pleo 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 Pleo 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 Pleo
- 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.
Go online for free. Grow when you need to.
Free puts you online. Pro adds requests, domains and your team; Business, your brand only.
Free
$0 forever
No card, no time limit
For getting compliant and going online on your own.
Start for freeKey features:
- Privacy and cookie policies
- Vendor and processing registers
- Requests and breaches tracked
- Impact assessment screening
- Privacy center on privacyboard.io
- Cookie banner on 1 domain
- 1 person
No card needed
ProRecommended
$32 per month
Billed $384 a year Save $84
For taking requests, covering all your sites and working as a team.
Start with ProEverything in Free, plus:
- DPA for your clients
- PDF and Excel exports
- Email reminders
- Request form and replies
- Your own domain
- Banner on 3 domains, every choice logged
- Weekly site scan
- Complete DPIAs and TIAs
- AI assistant connector
- Up to 5 people, with roles
Cancel any time
Business
$109 per month
Billed $1,308 a year Save $240
For proving it to customers and auditors, under your brand only.
Start with BusinessEverything in Pro, plus:
- No Privacyboard mention
- Security section and vendor alerts
- Evidence pack in one click
- Banner on 10 domains, daily scan
- Up to 50 people
- Two-step verification required
- Activity log kept 3 years
Bank transfer on request
Questions, answered.
Is Pleo GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Pleo 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 Pleo have a DPA?
Yes. Pleo publishes the text of its data processing agreement as a PDF 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://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf.
Is Pleo a data processor?
It depends on the activity. As a licensed payment provider, Pleo processes some data as controller, e.g. for anti-money laundering.
Which legal basis applies when I use Pleo?
For the usual use of Pleo, 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 Pleo store data?
Pleo is usually associated with Ireland (AWS eu-west-1), 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 Pleo says (read on 2026-11-05): Primary servers in AWS eu-west-1 Ireland, secondary backups in Frankfurt Source: https://help.pleo.io/en/articles/6967661-q-a-on-gdpr
Do I need to mention Pleo in my privacy policy?
Yes, if Pleo 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 Pleo to my vendor list?
In Privacyboard, pick Pleo 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.
Similar tools
Compare all expense management tools
Privacyboard is not affiliated with Pleo. 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.