E-commerceTito and the GDPR: agreement, role and data location.
Tito is a e-commerce 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
- E-commerce
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does Tito do with personal data?
Run an online store: take orders, process payments and manage delivery and customer accounts. That is how Privacyboard describes a typical use of Tito, as a starting point you can edit.
The data usually involved: names, Email addresses, Payment details, Phone numbers, Postal addresses, Contract & billing data, delivery
Is Tito a processor or a controller?
Most customers use Tito as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for e-commerce 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 Tito store personal data?
Tito 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 store 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 Tito?
For the usual use of Tito, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Taking and delivering an order is the contract, and order and invoice records must be kept by law.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Does Tito have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. Tito 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: Section 14 Data Processing of the Terms & Conditions makes Tito the processor and the customer the controller; Tito says no separate DPA is needed. Contracting entity Team Tito Limited, Dublin. No hosting location or SCCs stated.
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 Tito agreementHow to declare Tito
- 1
In your privacy policy
Name Tito as a recipient, say what it is used for (run an online store: take orders, process payments and manage delivery and customer accounts) 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 Tito 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 Tito 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 Tito
- Confirm the region and any transfer outside the EEA.
- Keep the agreement text you accepted and its date.
- List the provider in your privacy policy and your processing register.
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Questions, answered.
Is Tito GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Tito 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 Tito have a DPA?
Yes. Tito 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://ti.to/terms.
Is Tito a data processor?
Usually, yes. Most customers use Tito 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 Tito?
For the usual use of Tito, companies most often rely on performance of a contract and legal obligation (GDPR Article 6(1)). Taking and delivering an order is the contract, and order and invoice records must be kept by law. This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Where does Tito store data?
Tito 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 store settings or the provider’s data processing terms.
Do I need to mention Tito in my privacy policy?
Yes, if Tito 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 Tito to my vendor list?
In Privacyboard, pick Tito 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 Tito. 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.