Intercom: DPA, subprocessors and transfers

Links last opened 22 October 2026. Record confirmed by a person on 16 September 2026. 2 recorded changes, listed below.

Intercom contracts through Intercom R&D Unlimited Company, registered in Ireland. It is registered inside the EEA, so sending personal data to it is not a transfer out of the EEA. Data regions it offers: US, EU, AU. Its trust center is published at https://trust.intercom.com/. Its customer data processing agreement, also called a data processing addendum, is published by Intercom itself; the link is below. Its sub-processor list is published by Intercom itself; the link is below. We open those pages every day — last on 22 October 2026 — and a person last went through this record on 16 September 2026.

Contracting legal entity: Intercom R&D Unlimited Company
Country of registration: Ireland
Transfer mechanism for its own onward transfers: EU-US Data Privacy Framework (DPF)
Reaching Intercom is not a transfer out of the EEA: it is registered in Ireland. 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.
Data processing agreement: https://www.intercom.com/legal/data-processing-agreement
Subprocessor list: https://www.intercom.com/legal/subprocessors-list
Security or trust page: https://trust.intercom.com/
Data regions: US, EU, AU

What to put in your subprocessor list

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

Subprocessor	Legal entity	Country	Purpose	Transfer	DPA
Intercom	Intercom R&D Unlimited Company	IE	Communication	DPF	https://www.intercom.com/legal/data-processing-agreement

Questions people ask about Intercom

Where is Intercom's DPA?: Intercom publishes its customer data processing agreement at https://www.intercom.com/legal/data-processing-agreement. We last opened that link on 22 October 2026.
Is Intercom's DPA the same thing as a data processing addendum?: Yes. A data processing agreement and a data processing addendum are two names for the document Article 28 of the GDPR requires between a controller and a processor; vendors use both, and some call it processor terms. What it has to contain does not change with the name. Intercom's is at https://www.intercom.com/legal/data-processing-agreement.
Where is Intercom's sub-processor list?: Intercom publishes the list of its own sub-processors at https://www.intercom.com/legal/subprocessors-list. We last opened that link on 22 October 2026.
Which legal entity does Intercom contract through?: Intercom R&D Unlimited Company, registered in Ireland. That is the name to put in a record of processing or a sub-processor list, not the brand.
Does sending personal data to Intercom count as a transfer out of the EEA?: No. Intercom R&D Unlimited Company is registered in Ireland, inside the EEA, so no transfer mechanism is needed to reach it. Where it sends personal data on to is a separate question, and one for its own sub-processor list.
Where is Intercom's trust center?: Intercom publishes it at https://trust.intercom.com/. 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 Intercom's page, so we link to it rather than repeat what it says.

What has changed, and when

Changes we noticed on Intercom's own pages, each with the page we saw it on. The vendor does not publish this, and neither does anyone else.

22 October 2026
Intercom expanded its data transfer mechanisms to include reliance on adequacy decisions in addition to the Data Privacy Framework and Standard Contractual Clauses, and added Brazil (LGPD), Canada (PIPEDA), and Australia to its list of applicable data protection laws with corresponding transfer safeguards. The vendor also added definitions for Australian Privacy Principles, LGPD, PIPEDA, and LGPD transfers, and clarified that restrictions on sub-processor authorization and processing instructions now require explicit documentation from customers.
Seen on https://www.intercom.com/legal/data-processing-agreement
22 September 2026
We recorded a change to the UK transfer mechanism.
Recorded from a source other than their own pages.

Building your own sub-processor list?

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Build my list

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.

Other communication

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

Subprocessor

Legal entity

Country

Purpose

Transfer

DPA

Intercom

Intercom R&D Unlimited Company

Communication

DPF

https://www.intercom.com/legal/data-processing-agreement

Questions people ask about Intercom

Where is Intercom's DPA?

Intercom publishes its customer data processing agreement at https://www.intercom.com/legal/data-processing-agreement. We last opened that link on 22 October 2026.

Is Intercom's DPA the same thing as a data processing addendum?

Yes. A data processing agreement and a data processing addendum are two names for the document Article 28 of the GDPR requires between a controller and a processor; vendors use both, and some call it processor terms. What it has to contain does not change with the name. Intercom's is at https://www.intercom.com/legal/data-processing-agreement.

Where is Intercom's sub-processor list?

Intercom publishes the list of its own sub-processors at https://www.intercom.com/legal/subprocessors-list. We last opened that link on 22 October 2026.

Which legal entity does Intercom contract through?

Intercom R&D Unlimited Company, registered in Ireland. That is the name to put in a record of processing or a sub-processor list, not the brand.

Does sending personal data to Intercom count as a transfer out of the EEA?

No. Intercom R&D Unlimited Company is registered in Ireland, inside the EEA, so no transfer mechanism is needed to reach it. Where it sends personal data on to is a separate question, and one for its own sub-processor list.

Where is Intercom's trust center?

Intercom publishes it at https://trust.intercom.com/. 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 Intercom's page, so we link to it rather than repeat what it says.

What has changed, and when

Changes we noticed on Intercom's own pages, each with the page we saw it on. The vendor does not publish this, and neither does anyone else.

22 October 2026

Intercom expanded its data transfer mechanisms to include reliance on adequacy decisions in addition to the Data Privacy Framework and Standard Contractual Clauses, and added Brazil (LGPD), Canada (PIPEDA), and Australia to its list of applicable data protection laws with corresponding transfer safeguards. The vendor also added definitions for Australian Privacy Principles, LGPD, PIPEDA, and LGPD transfers, and clarified that restrictions on sub-processor authorization and processing instructions now require explicit documentation from customers.

Seen on https://www.intercom.com/legal/data-processing-agreement

22 September 2026

We recorded a change to the UK transfer mechanism.

Recorded from a source other than their own pages.

Intercom: DPA, subprocessors and transfers

What to put in your subprocessor list

Questions people ask about Intercom

What has changed, and when

Building your own sub-processor list?

Where to go next

Other communication

Intercom: DPA, subprocessors and transfers

What to put in your subprocessor list

Questions people ask about Intercom

What has changed, and when

Building your own sub-processor list?

Where to go next

Other communication