AnalyticsWalkMe and the GDPR: agreement, role and data location.
WalkMe is a analytics 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
- Analytics
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Published by the vendor
What does WalkMe do with personal data?
Measure website or service usage and understand visitor interactions. That is how Privacyboard describes a typical use of WalkMe, 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 WalkMe a processor or a controller?
Most customers use WalkMe as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for analytics 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 WalkMe store personal data?
WalkMe 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 your account settings or WalkMe’s data processing terms for where your data is stored.
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.
Does WalkMe have a data processing agreement?
Checked on 1 November 2026. Vendors change their pages, so check the date.
Yes. WalkMe 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: WalkMe Data Processing Agreement, last update December 2025, with a link to the September 2024 version. Processor is the WalkMe entity on the order form (not named). No hosting location stated; SCCs cover 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 WalkMe agreementHow to declare WalkMe
- 1
In your privacy policy
Name WalkMe 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 WalkMe 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 WalkMe 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 WalkMe
- 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.
Questions, answered.
Is WalkMe GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how WalkMe 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 WalkMe have a DPA?
Yes. WalkMe 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.walkme.com/walkme-dpa/.
Is WalkMe a data processor?
Usually, yes. Most customers use WalkMe as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Where does WalkMe store data?
WalkMe 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 your account settings or WalkMe’s data processing terms for where your data is stored.
Do I need to mention WalkMe in my privacy policy?
Yes, if WalkMe 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 WalkMe to my vendor list?
In Privacyboard, pick WalkMe 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.
Privacyboard is not affiliated with WalkMe. 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.