Timely and the GDPR: agreement, role and data location.
Timely is a scheduling tool. Most customers use it as a processor, it publishes its data processing agreement, and it usually keeps data in the European Union. Below: what to check and how to declare it.
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In short
- Category
- Scheduling
- Usual role
- Usually a processor
- Data location
- Usually the European Union
- Agreement
- Published by the vendor
What does Timely do with personal data?
Schedule meetings with prospects, customers and team members. That is how Privacyboard describes a typical use of Timely, as a starting point you can edit.
The data usually involved: names, email addresses, availability, calendar event details and booking responses.
Is Timely a processor or a controller?
Most customers use Timely as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for scheduling 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 Timely store personal data?
Timely usually keeps data in the European Union 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 Timely says (read on 2026-11-05): “Data is processed and stored in the EU” by AWS Source: https://www.timely.com/help/handbook/privacy/timely-and-gdpr/
How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
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 Timely?
For the usual use of Timely, companies most often rely on legitimate interests (GDPR Article 6(1)). Booking a slot is something the person asked for in order to speak with the company.
The interest you would state: “Scheduling the meetings that prospects and customers ask for.” 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 Timely have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Timely 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, undated, with processor Timely AS (Oslo, Norway), governed by Norwegian law. Core hosting sub-processors in the EU; some US sub-processors under DPF or SCCs; EU SCCs are the general transfer basis.
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 Timely agreementHow to declare Timely
- 1
In your privacy policy
Name Timely as a recipient, say what it is used for (schedule meetings with prospects, customers and team members) 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 Timely 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 Timely 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 Timely
- Show a short notice on the booking page.
- Check which calendar data the tool can read and write.
- Set a retention period for past bookings.
- Record the region and any transfer outside the EEA.
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Questions, answered.
Is Timely GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Timely 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 Timely have a DPA?
Yes. Timely 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.timely.com/data-processing-agreement/.
Is Timely a data processor?
Usually, yes. Most customers use Timely 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 Timely?
For the usual use of Timely, companies most often rely on legitimate interests (GDPR Article 6(1)). Booking a slot is something the person asked for in order to speak with the company. The interest you would state: “Scheduling the meetings that prospects and customers ask for.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Timely store data?
Timely usually keeps data in the European Union 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 Timely says (read on 2026-11-05): “Data is processed and stored in the EU” by AWS Source: https://www.timely.com/help/handbook/privacy/timely-and-gdpr/
Do I need to mention Timely in my privacy policy?
Yes, if Timely 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 Timely to my vendor list?
In Privacyboard, pick Timely 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 Timely. 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.