Toggl Track and GDPR: hosting, non-EU transfer and DPA
Toggl Track is published by Toggl OÜ. 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.
track.toggl.com, toggl.comDoes using Toggl Track mean a non-EU transfer?
No. Toggl OÜ 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, professional data, usage data. Recipient: Toggl OÜ. Transfer: European Union. Retention: aligned with the contract or the account lifetime, whichever is shorter.
How RoPA Pilot handles it
RoPA Pilot detects Toggl Track 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.