Links last opened 28 October 2026. Record confirmed by a person on 16 September 2026. 7 recorded changes, listed below.
Factorial contracts through Everyday Software, S.L., registered in Spain. It is registered inside the EEA, so sending personal data to it is not a transfer out of the EEA. Data regions it offers: EU. Its trust center is published at https://trust.factorial.co/. Its customer data processing agreement, also called a data processing addendum, is published by Factorial itself; the link is below. Its sub-processor list is published by Factorial itself; the link is below. We open those pages every day — last on 28 October 2026 — and a person last went through this record on 16 September 2026.
Reaching Factorial is not a transfer out of the EEA: it is registered in Spain. This is what the record holds for where it sends personal data on, and it is not something we have checked — its sub-processor list is the place to look.
A ready row. Replace the purpose with what your client actually uses Factorial for.
| Subprocessor | Legal entity | Country | Purpose | Transfer | DPA |
|---|---|---|---|---|---|
| Factorial | Everyday Software, S.L. | ES | HR | SCC | https://trust.factorial.co/?itemUid=87ae22b2-15c8-437f-b945-b253f18e052b |
Changes we noticed on Factorial's own pages, each with the page we saw it on. The vendor does not publish this, and neither does anyone else.
24 October 2026
Factorial removed references to a Penetration Test Report, ISO27001 Statement of Applicability, and SOC 2 Type 2 compliance documentation from their data processing agreement, which means those security certifications and assessments are no longer listed as available compliance materials for the vendor.
Seen on https://trust.factorial.co/?itemUid=87ae22b2-15c8-437f-b945-b253f18e052b
23 October 2026
Factorial updated their data processing agreement to add reference to their Security Policies Pack and removed references to their Pentest Report and AI Overview.
Seen on https://trust.factorial.co/?itemUid=87ae22b2-15c8-437f-b945-b253f18e052b
21 October 2026
Factorial removed contact instructions for reporting security vulnerabilities from their Data Processing Agreement.
Seen on https://trust.factorial.co/?itemUid=87ae22b2-15c8-437f-b945-b253f18e052b
9 October 2026
Factorial replaced their standard Data Processing Agreement document with a software certificate (Softwarebescheinigung). This changes which legal document governs data processing terms and may affect how data protection obligations and subprocessor requirements are documented.
Seen on https://trust.factorial.co/?itemUid=87ae22b2-15c8-437f-b945-b253f18e052b
7 October 2026
Factorial added two new entities (Marqués de Riscal and FRS Co-Op) to their data processing agreement, which means these organizations may now be subprocessors or data controllers in the processing chain and should be documented in your records of processing.
Seen on https://trust.factorial.co/?itemUid=87ae22b2-15c8-437f-b945-b253f18e052b
2 October 2026
We recorded a change to the data processing agreement link.
22 September 2026
We recorded a change to the UK transfer mechanism.
Recorded from a source other than their own pages.
Enter your website: each service it loads, what it is for and links to its own DPA, in a minute or two. No sign-up.
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.
Six of them. All hr in the registry · others that transfer the same way.