AccountingShine and the GDPR: agreement, role and data location.
Shine is a accounting 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
- Accounting
- Usual role
- Depends on the activity
- Data location
- Often EEA, check your account
- Agreement
- Published by the vendor
What does Shine do with personal data?
Keep accounts, issue invoices and manage bookkeeping. That is how Privacyboard describes a typical use of Shine, as a starting point you can edit.
The data usually involved: names, Payment details, Contract & billing data, Customer
Is Shine a processor or a controller?
as a bank, Shine is controller for account, KYC and payment data and processor only for platform features.
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 Shine store personal data?
Shine is usually associated with EEA, 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 Shine says (read on 2026-11-05): “Data is processed by the Data Processor within the European Economic Area” Source: https://shine.co/legal/dpa
How to find yours: Check the organization settings, or the provider’s data processing terms.
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 Shine?
For the usual use of Shine, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Invoices and accounts must be kept as accounting and tax law requires, and billing follows the contract.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Does Shine have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Shine 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: Shine Data Processing Agreement, appendix to the Terms of Service, version applicable from 7 Oct 2025; processor is the Shine Group company in the customer's contract. Says data is processed in the EEA (AWS Luxembourg) with SCCs for non-EEA sub-processors.
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 Shine agreementHow to declare Shine
- 1
In your privacy policy
Name Shine as a recipient, say what it is used for (keep accounts, issue invoices and manage bookkeeping) 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 Shine 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 Shine 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 Shine
- Limit access to people who need the books, and review it when someone leaves.
- Agree how long invoices are kept: accounting law often sets a minimum.
- Check the region and any transfer outside the EEA.
- Record whether your accountant also has access, as a separate recipient.
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Questions, answered.
Is Shine GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Shine 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 Shine have a DPA?
Yes. Shine 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://shine.co/legal/dpa.
Is Shine a data processor?
It depends on the activity. as a bank, Shine is controller for account, KYC and payment data and processor only for platform features.
Which legal basis applies when I use Shine?
For the usual use of Shine, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Invoices and accounts must be kept as accounting and tax law requires, and billing follows the contract. This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Where does Shine store data?
Shine is usually associated with EEA, 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 Shine says (read on 2026-11-05): “Data is processed by the Data Processor within the European Economic Area” Source: https://shine.co/legal/dpa
Do I need to mention Shine in my privacy policy?
Yes, if Shine 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 Shine to my vendor list?
In Privacyboard, pick Shine 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 Shine. 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.