InfrastructureUpCloud and the GDPR: agreement, role and data location.
UpCloud is a infrastructure tool. Most customers use it as a processor, it explains how to get 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
- Infrastructure
- Usual role
- Usually a processor
- Data location
- Often Customer choice, check your account
- Agreement
- Obtained through the vendor
What does UpCloud do with personal data?
Deliver and protect application traffic through DNS, CDN and network security services. That is how Privacyboard describes a typical use of UpCloud, as a starting point you can edit.
The data usually involved: iP addresses, Documents & attachments, Security & access logs, HTTP request metadata
Is UpCloud a processor or a controller?
Most customers use UpCloud as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for infrastructure 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 UpCloud store personal data?
UpCloud 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 UpCloud says (read on 2026-11-05): Customer Data stored in the data centre the customer selects Source: https://upcloud.com/security-privacy/
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.
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 UpCloud?
For the usual use of UpCloud, companies most often rely on legitimate interests (GDPR Article 6(1)). DNS, CDN and network security are needed to run and protect the service for everyone who visits it.
The interest you would state: “Delivering our website quickly and protecting it against attacks and abuse.” 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 UpCloud have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
UpCloud does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy.
What we noted when we opened the page: Security & Privacy page says the DPA is incorporated into the Terms of Service and binds on acceptance. Account data stored in Finland; customer data stays in the data centre the customer selects; SCCs or adequacy for 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.
Open the UpCloud reference pageHow to declare UpCloud
- 1
In your privacy policy
Name UpCloud as a recipient, say what it is used for (deliver and protect application traffic through DNS, CDN and network security services) 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 UpCloud 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 UpCloud 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 UpCloud
- Check which services are enabled and what logs they keep.
- Review log retention and any regional processing options.
- Record IP addresses and request metadata in your policy where relevant.
- Record transfers outside the EEA and their safeguard.
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Questions, answered.
Is UpCloud GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how UpCloud is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it explains how to get a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does UpCloud have a DPA?
UpCloud does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy. The reference page is https://upcloud.com/security-privacy/.
Is UpCloud a data processor?
Usually, yes. Most customers use UpCloud 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 UpCloud?
For the usual use of UpCloud, companies most often rely on legitimate interests (GDPR Article 6(1)). DNS, CDN and network security are needed to run and protect the service for everyone who visits it. The interest you would state: “Delivering our website quickly and protecting it against attacks and abuse.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does UpCloud store data?
UpCloud 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 UpCloud says (read on 2026-11-05): Customer Data stored in the data centre the customer selects Source: https://upcloud.com/security-privacy/
Do I need to mention UpCloud in my privacy policy?
Yes, if UpCloud 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 UpCloud to my vendor list?
In Privacyboard, pick UpCloud 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 UpCloud. 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.