CommunicationsPlivo and the GDPR: agreement, role and data location.
Plivo is a communications 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
- Communications
- Usual role
- Usually a processor
- Data location
- Often United States, check your account
- Agreement
- Published by the vendor
What does Plivo do with personal data?
Send text messages, verification codes and notifications, and handle phone calls with customers. That is how Privacyboard describes a typical use of Plivo, as a starting point you can edit.
The data usually involved: phone numbers, message content, call metadata and delivery status.
Is Plivo a processor or a controller?
Most customers use Plivo as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for communications 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 Plivo store personal data?
Plivo is usually associated with United States, 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 Plivo says (read on 2026-11-05): “Plivo main processing facilities are in the United States of America.” Source: https://plivo.com/assets/dist/Plivo_DPA_New_SCC.pdf
How to find yours: Check the account’s region settings or the provider’s data processing terms.
If the data is processed outside the European Economic Area, Articles 44 to 49 require a transfer mechanism, such as standard contractual clauses, an adequacy decision or the EU-US Data Privacy Framework. Your privacy policy should name it.
Which legal basis usually applies to Plivo?
For the usual use of Plivo, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). Verification codes and service notifications are part of delivering the service; keeping logs rests on a legitimate interest.
The interest you would state: “Keeping a record of our communications to resolve disputes and improve our service.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Marketing texts and calls to individuals need consent. 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 Plivo have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Plivo 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: Plivo Data Processing Addendum incorporating GDPR and SCCs, undated; contracting entity Plivo, Inc. (Delaware) or the Plivo entity on the Order. States main processing facilities are in the US; transfers via EU SCCs (2021/914), DPA governed by Irish law.
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 Plivo agreementHow to declare Plivo
- 1
In your privacy policy
Name Plivo as a recipient, say what it is used for (send text messages, verification codes and notifications, and handle phone calls with customers) 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 Plivo 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 Plivo 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 Plivo
- Confirm the region and any transfer outside the EEA.
- Keep the agreement text you accepted and its date.
- List the provider in your privacy policy and your processing register.
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Questions, answered.
Is Plivo GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Plivo 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 Plivo have a DPA?
Yes. Plivo 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://plivo.com/assets/dist/Plivo_DPA_New_SCC.pdf.
Is Plivo a data processor?
Usually, yes. Most customers use Plivo 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 Plivo?
For the usual use of Plivo, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). Verification codes and service notifications are part of delivering the service; keeping logs rests on a legitimate interest. The interest you would state: “Keeping a record of our communications to resolve disputes and improve our service.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Plivo store data?
Plivo is usually associated with United States, 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 Plivo says (read on 2026-11-05): “Plivo main processing facilities are in the United States of America.” Source: https://plivo.com/assets/dist/Plivo_DPA_New_SCC.pdf
Do I need to mention Plivo in my privacy policy?
Yes, if Plivo 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 Plivo to my vendor list?
In Privacyboard, pick Plivo 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 Plivo. 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.