PaymentsSumUp and the GDPR: agreement, role and data location.
SumUp is a payments tool. Its role depends on the activity, it publishes its data processing agreement, and it usually keeps data in EEA. Below: what to check and how to declare it.
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In short
- Category
- Payments
- Usual role
- Depends on the activity
- Data location
- Usually EEA
- Agreement
- Published by the vendor
What does SumUp do with personal data?
Manage customer payments, subscriptions where applicable, invoicing and billing. That is how Privacyboard describes a typical use of SumUp, as a starting point you can edit.
The data usually involved: customer names, email addresses, billing addresses, transaction identifiers and payment information handled by the provider.
Is SumUp a processor or a controller?
SumUp is a processor for POS, online store and booking tools but controls payment and aggregated data itself.
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 SumUp store personal data?
SumUp usually keeps data in EEA 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 SumUp says (read on 2026-11-05): Processing “shall take place within the territory of the European Economic Area” Source: https://www.sumup.com/en-ie/terms/dpa/
How to find yours: Check the provider’s privacy center or 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 SumUp?
For the usual use of SumUp, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Taking payment is part of the contract, and invoices must be kept as accounting and tax law requires.
Many payment providers also act as independent controllers for fraud prevention and legal checks, on their own basis.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Does SumUp have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. SumUp 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 Agreement effective 16 Jan 2023, amended 10 Dec 2024; contracting SumUp entity is the one named in the Additional Terms. States processing of merchants' customer data takes place in the EEA (and UK); SCCs for other 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 SumUp agreementHow to declare SumUp
- 1
In your privacy policy
Name SumUp as a recipient, say what it is used for (manage customer payments, subscriptions where applicable, invoicing and billing) 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 SumUp 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 SumUp 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 SumUp
- Work out whether the provider acts as your processor, as an independent controller, or as both for different activities.
- Say in your privacy policy that payment data is handled by the provider and for what purpose.
- Record the provider as a recipient of customer names, emails and transaction data.
- Check retention rules the provider applies for legal and fraud reasons.
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Questions, answered.
Is SumUp GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how SumUp 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 SumUp have a DPA?
Yes. SumUp 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://www.sumup.com/en-ie/terms/dpa/.
Is SumUp a data processor?
It depends on the activity. SumUp is a processor for POS, online store and booking tools but controls payment and aggregated data itself.
Which legal basis applies when I use SumUp?
For the usual use of SumUp, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Taking payment is part of the contract, and invoices must be kept as accounting and tax law requires. Many payment providers also act as independent controllers for fraud prevention and legal checks, on their own basis.
Where does SumUp store data?
SumUp usually keeps data in EEA 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 SumUp says (read on 2026-11-05): Processing “shall take place within the territory of the European Economic Area” Source: https://www.sumup.com/en-ie/terms/dpa/
Do I need to mention SumUp in my privacy policy?
Yes, if SumUp 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 SumUp to my vendor list?
In Privacyboard, pick SumUp 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 SumUp. 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.