Customer.io and GDPR: hosting, non-EU transfer and DPA

Customer.io is published by Peaberry Software, Inc.. If your teams use it, it is a processor within the meaning of Article 28 GDPR and it must appear in your record of processing activities.

Does using Customer.io mean a non-EU transfer?

Yes. Peaberry Software, Inc. is a US vendor listed under the EU-US Data Privacy Framework: the transfer is lawful as long as the certification is active — check it on dataprivacyframework.gov and record the date of your check.

What to write in your Article 30 record

Purpose: Marketing. Categories of personal data: identity, contact details, usage data. Recipient: Peaberry Software, Inc.. Transfer: United States — EU-US DPF. Retention: aligned with the contract or the account lifetime, whichever is shorter.

How RoPA Pilot handles it

RoPA Pilot detects Customer.io from the domain name of the tab — never from page content — and pre-fills the record above in one click. The extension flags the record if the transfer mechanism is missing or unverified.

Indicative information from public sources. The transfer mechanism actually applicable to you is the one written in your contract.