MediaScaleflex and the GDPR: agreement, role and data location.
Scaleflex is a media 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
- Media
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Scaleflex do with personal data?
Store, process and deliver images and videos. That is how Privacyboard describes a typical use of Scaleflex, as a starting point you can edit.
The data usually involved: account identifiers, IP addresses, Documents & attachments, Images & recordings, which may show people
Is Scaleflex a processor or a controller?
Most customers use Scaleflex as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for media 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 Scaleflex store personal data?
Scaleflex 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 the account or product environment settings for the storage region.
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 Scaleflex?
For the usual use of Scaleflex, companies most often rely on legitimate interests (GDPR Article 6(1)). Media hosting is needed to show our content to visitors.
The interest you would state: “Storing and delivering the images and videos of our website and service.” 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 Scaleflex have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Scaleflex 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 Privacy Addendum, created 1 Jan 2024 and reviewed 15 Sep 2025, with the applicable Scaleflex contracting entity as Processor. Customer selects a processing Region that data is not transferred out of; SCCs and UK Addendum used for sub-processor transfers.
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 Scaleflex agreementHow to declare Scaleflex
- 1
In your privacy policy
Name Scaleflex as a recipient, say what it is used for (store, process and deliver images and videos) 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 Scaleflex 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 Scaleflex 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 Scaleflex
- Get permission before uploading images or videos of identifiable people.
- Set who can view each file: private, unlisted or public.
- Check where files are stored and delivered from.
- Delete files when the reason for keeping them ends.
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Questions, answered.
Is Scaleflex GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Scaleflex 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 Scaleflex have a DPA?
Yes. Scaleflex 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://legal.scaleflex.com/privacy-and-data-processing/global-privacy-policy/data-privacy-addendum.
Is Scaleflex a data processor?
Usually, yes. Most customers use Scaleflex 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 Scaleflex?
For the usual use of Scaleflex, companies most often rely on legitimate interests (GDPR Article 6(1)). Media hosting is needed to show our content to visitors. The interest you would state: “Storing and delivering the images and videos of our website and service.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Scaleflex store data?
Scaleflex 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 the account or product environment settings for the storage region.
Do I need to mention Scaleflex in my privacy policy?
Yes, if Scaleflex 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 Scaleflex to my vendor list?
In Privacyboard, pick Scaleflex 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 Scaleflex. 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.