Email marketingZoho Campaigns and the GDPR: agreement, role and data location.
Zoho Campaigns is a email marketing 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
- Email marketing
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Obtained through the vendor
What does Zoho Campaigns do with personal data?
Manage mailing lists and deliver marketing campaigns. That is how Privacyboard describes a typical use of Zoho Campaigns, as a starting point you can edit.
The data usually involved: names, email addresses, subscription preferences, campaign content and engagement data where enabled.
Is Zoho Campaigns a processor or a controller?
Most customers use Zoho Campaigns as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for email marketing 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 Zoho Campaigns store personal data?
Zoho Campaigns 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 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 Zoho Campaigns?
For the usual use of Zoho Campaigns, companies most often rely on consent and legitimate interests (GDPR Article 6(1)). Marketing to consumers needs prior consent; the exception is similar products offered to existing customers, and B2B messages related to the person’s role.
The interest you would state: “Sending offers on similar products to existing customers, who can opt out at any time.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Each message must offer a free, simple way to unsubscribe. 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: CNIL: rules for prospecting by email, GDPR Article 6, lawfulness of processing
Does Zoho Campaigns have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
Zoho Campaigns 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: Zoho Accounts help page explains that an org admin requests the Data Processing Addendum under Privacy; after legal review it is signed via Zoho Sign with Zoho Corporation. No hosting location or transfer tool 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.
Open the Zoho Campaigns reference pageHow to declare Zoho Campaigns
- 1
In your privacy policy
Name Zoho Campaigns as a recipient, say what it is used for (manage mailing lists and deliver marketing campaigns) 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 Zoho Campaigns 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 Zoho Campaigns 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 Zoho Campaigns
- Keep proof of consent and a working unsubscribe for every list.
- Check what engagement tracking is on, such as opens and clicks, and mention it in your policy.
- Record the region and any transfer outside the EEA.
- Make sure you can find and erase one subscriber across lists.
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Questions, answered.
Is Zoho Campaigns GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how Zoho Campaigns 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 Zoho Campaigns have a DPA?
Zoho Campaigns 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://help.zoho.com/portal/en/kb/accounts/manage-your-zoho-account/articles/privacy.
Is Zoho Campaigns a data processor?
Usually, yes. Most customers use Zoho Campaigns 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 Zoho Campaigns?
For the usual use of Zoho Campaigns, companies most often rely on consent and legitimate interests (GDPR Article 6(1)). Marketing to consumers needs prior consent; the exception is similar products offered to existing customers, and B2B messages related to the person’s role. The interest you would state: “Sending offers on similar products to existing customers, who can opt out at any time.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does Zoho Campaigns store data?
Zoho Campaigns 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 the provider’s data processing terms.
Do I need to mention Zoho Campaigns in my privacy policy?
Yes, if Zoho Campaigns 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 Zoho Campaigns to my vendor list?
In Privacyboard, pick Zoho Campaigns 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 Zoho Campaigns. 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.