AnalyticsUserTesting and the GDPR: agreement, role and data location.
UserTesting is a analytics tool. Its role depends on the activity, 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
- Depends on the activity
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does UserTesting do with personal data?
Measure website or service usage and understand visitor interactions. That is how Privacyboard describes a typical use of UserTesting, as a starting point you can edit.
The data usually involved: usage events, device and browser information, user identifiers and IP addresses where collected.
Is UserTesting a processor or a controller?
the DPA makes UserTesting a separate controller for participant and contact data.
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 UserTesting store personal data?
UserTesting 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: Look at the address you log in to or your project settings.
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 UserTesting?
For the usual use of UserTesting, 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 UserTesting have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Yes. UserTesting 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: Online Data Processing Agreement effective 21 Jul 2026. Contracting entity UserTesting Technologies, Inc. or affiliates. No hosting location stated; transfers under EU SCCs Modules 1 and 2, Swiss adaptation 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 UserTesting agreementHow to declare UserTesting
- 1
In your privacy policy
Name UserTesting 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 UserTesting 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 UserTesting 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 UserTesting
- 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 UserTesting GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how UserTesting 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 UserTesting have a DPA?
Yes. UserTesting 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.usertesting.com/data-processing-agreement.
Is UserTesting a data processor?
It depends on the activity. the DPA makes UserTesting a separate controller for participant and contact data.
Which legal basis applies when I use UserTesting?
For the usual use of UserTesting, 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 UserTesting store data?
UserTesting 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: Look at the address you log in to or your project settings.
Do I need to mention UserTesting in my privacy policy?
Yes, if UserTesting 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 UserTesting to my vendor list?
In Privacyboard, pick UserTesting 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 UserTesting. 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.