CircleCI: DPA, subprocessors and transfers

What to put in your subprocessor list

A ready row. Replace the purpose with what your client actually uses CircleCI for.

Questions people ask about CircleCI

Where is CircleCI's sub-processor list?

CircleCI publishes the list of its own sub-processors at https://circleci.com/legal/subprocessors/. We last opened that link on 31 October 2026.

Which legal entity does CircleCI contract through?

Circle Internet Services, Inc. dba CircleCI, registered in United States. That is the name to put in a record of processing or a sub-processor list, not the brand.

What covers a transfer of personal data to CircleCI outside the EEA?

EU-US Data Privacy Framework (DPF). A US certification scheme covered by an EU adequacy decision. Transfers to a certified US organisation need no further mechanism for the certified scope. Whether that is enough for a particular processing operation is a judgement for the controller.

Where is CircleCI's trust center?

CircleCI publishes it at https://circleci.com/security/. A trust center, trust page or security page is the same thing under different names: the vendor's own account of how it protects data, and the place it keeps its certifications. It is CircleCI's page, so we link to it rather than repeat what it says.

Where to go next

Worked out from the registry and what we have written: the country this vendor contracts from, the guides that answer the question this page raises, and the rest of the registry.

• Vendors contracting from United States646 in the registry
• What to tell a client with an Irish entity about NIS2Ireland has not transposed NIS2, so there are no national duties yet — what is live instead, what to do meanwhile, and w
• The vendor registryLegal entities, transfer mechanisms and DPA links, checked by a person
• Download the registry as a CSVFree, for a spreadsheet
• Guides for privacy practicesHow the work is actually done

Other developer tools

Six of them. All developer tools in the registry · others that transfer the same way.

• 37signals, LLC.US
• Ably RealtimeGB
• Aikido SecurityUS
• AirbyteUS
• AlgoliaFR
• APILayerAT