Evernote and GDPR: hosting, non-EU transfer and DPA

Evernote is published by Bending Spoons S.p.A.. 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 Evernote mean a non-EU transfer?

No. Bending Spoons S.p.A. keeps the data inside the European Union: no structural transfer to document under Chapter V.

What to write in your Article 30 record

Purpose: Productivity. Categories of personal data: identity, content. Recipient: Bending Spoons S.p.A.. Transfer: European Union. Retention: aligned with the contract or the account lifetime, whichever is shorter.

How RoPA Pilot handles it

RoPA Pilot detects Evernote 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.