AnalyticsSnowplow and the GDPR: agreement, role and data location.
Snowplow is a analytics 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
- Analytics
- Usual role
- Usually a processor
- Data location
- Often Customer choice, check your account
- Agreement
- Published by the vendor
What does Snowplow do with personal data?
Measure website or service usage and understand visitor interactions. That is how Privacyboard describes a typical use of Snowplow, as a starting point you can edit.
The data usually involved: account identifiers, IP addresses, Website & device data, Usage & activity data
Is Snowplow a processor or a controller?
Most customers use Snowplow as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for analytics 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 Snowplow store personal data?
Snowplow is usually associated with Customer choice, 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 Snowplow says (read on 2026-11-05): “the hosting location for a Workspace will be determined by the Customer” Source: https://snowplow.io/dpa
How to find yours: Look at the address you log in to or your project settings.
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 Snowplow?
For the usual use of Snowplow, companies most often rely on consent (GDPR Article 6(1)). Analytics that read or write identifiers on the visitor’s device need consent, under the ePrivacy rules as well as the GDPR.
Some anonymous audience measurement tools can run without consent in France when the CNIL’s conditions are met (own purposes only, anonymous statistics, no cross-site tracking).
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Sources: CNIL: audience measurement tools exempt from consent, CNIL: cookies and other trackers, questions and answers
Does Snowplow have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Snowplow 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 20 Sep 2024, binding via Order Form; no legal entity named in the text. Customer chooses the hosting location; UK/EEA-hosted data stays there except limited cases. EU SCCs and UK Addendum.
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 Snowplow agreementHow to declare Snowplow
- 1
In your privacy policy
Name Snowplow as a recipient, say what it is used for (measure website or service usage and understand visitor interactions) 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 Snowplow 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 Snowplow 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 Snowplow
- Check whether the tool sets cookies or reads device data, and what consent that requires.
- Say in your privacy policy what is measured and for how long it is kept.
- Review IP address handling, data retention and the data region settings.
- Confirm whether the provider uses the data for its own purposes.
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Questions, answered.
Is Snowplow GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Snowplow 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 Snowplow have a DPA?
Yes. Snowplow 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://snowplow.io/dpa.
Is Snowplow a data processor?
Usually, yes. Most customers use Snowplow 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 Snowplow?
For the usual use of Snowplow, companies most often rely on consent (GDPR Article 6(1)). Analytics that read or write identifiers on the visitor’s device need consent, under the ePrivacy rules as well as the GDPR. Some anonymous audience measurement tools can run without consent in France when the CNIL’s conditions are met (own purposes only, anonymous statistics, no cross-site tracking).
Where does Snowplow store data?
Snowplow is usually associated with Customer choice, 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 Snowplow says (read on 2026-11-05): “the hosting location for a Workspace will be determined by the Customer” Source: https://snowplow.io/dpa
Do I need to mention Snowplow in my privacy policy?
Yes, if Snowplow 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 Snowplow to my vendor list?
In Privacyboard, pick Snowplow 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 Snowplow. 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.