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

Recharge is a e-commerce tool. Most customers use it as a processor, it publishes its data processing agreement, and it usually keeps data in United States. Below: what to check and how to declare it.

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In short

Category
E-commerce
Usual role
Usually a processor
Data location
Usually United States
Agreement
Published by the vendor

What does Recharge do with personal data?

Run an online store: take orders, process payments and manage delivery and customer accounts. That is how Privacyboard describes a typical use of Recharge, as a starting point you can edit.

The data usually involved: customer names, email addresses, delivery and billing addresses, phone numbers, order history and payment status.

Is Recharge a processor or a controller?

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

Recharge usually keeps data in United States for every customer on its standard service, so there is normally nothing to choose. Privacyboard prefills this and you can change it if your setup differs.

What Recharge says (read on 2026-11-05): Subscriber Personal Information “will be Processed and stored in the United States” Source: https://getrecharge.com/dpa/

How to find yours: Check the store 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 Recharge?

For the usual use of Recharge, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Taking and delivering an order is the contract, and order and invoice records must be kept by law.

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

Does Recharge have a data processing agreement?

Checked on 5 November 2026. Vendors change their pages, so check the date.

Yes. Recharge 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 30 Mar 2026. Contracting entity Recharge Inc. (Delaware, Santa Monica). States subscriber personal information is processed and stored in the US; EU SCCs Module Two and UK IDTA apply.

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 Recharge agreement

How to declare Recharge

  1. 1

    In your privacy policy

    Name Recharge as a recipient, say what it is used for (run an online store: take orders, process payments and manage delivery and customer accounts) 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 Recharge 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 Recharge 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 Recharge

  • 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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FAQ

Questions, answered.

Is Recharge GDPR compliant?

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

Yes. Recharge 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://getrecharge.com/dpa/.

Is Recharge a data processor?

Usually, yes. Most customers use Recharge 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 Recharge?

For the usual use of Recharge, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Taking and delivering an order is the contract, and order and invoice records must be kept by law. This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.

Where does Recharge store data?

Recharge usually keeps data in United States for every customer on its standard service, so there is normally nothing to choose. Privacyboard prefills this and you can change it if your setup differs. What Recharge says (read on 2026-11-05): Subscriber Personal Information “will be Processed and stored in the United States” Source: https://getrecharge.com/dpa/

Do I need to mention Recharge in my privacy policy?

Yes, if Recharge 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 Recharge to my vendor list?

In Privacyboard, pick Recharge 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 Recharge. 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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