Pleo publishes its customer data processing agreement at https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf. We last opened that link on 31 October 2026.

Is Pleo'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. Pleo's is at https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf.

Where is Pleo's sub-processor list?

Pleo publishes the list of its own sub-processors at https://www.pleo.io/en/sub-processors. We last opened that link on 31 October 2026.

Which legal entity does Pleo contract through?

Pleo Technologies A/S, registered in Denmark. That is the name to put in a record of processing or a sub-processor list, not the brand.

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

No. Pleo Technologies A/S is registered in Denmark, 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 Pleo's trust center?

Pleo publishes it at https://www.pleo.io/en/trust-and-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 Pleo's page, so we link to it rather than repeat what it says.

Pleo: DPA, subprocessors and transfers

Links last opened 31 October 2026. Record confirmed by a person on 16 September 2026. 20 recorded changes, listed below.

Pleo contracts through Pleo Technologies A/S, registered in Denmark. 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://www.pleo.io/en/trust-and-security. Its customer data processing agreement, also called a data processing addendum, is published by Pleo itself; the link is below. Its sub-processor list is published by Pleo itself; the link is below. We open those pages every day — last on 31 October 2026 — and a person last went through this record on 16 September 2026.

Contracting legal entity: Pleo Technologies A/S
Country of registration: Denmark
Transfer mechanism for its own onward transfers: Standard contractual clauses (SCC)
Reaching Pleo is not a transfer out of the EEA: it is registered in Denmark. 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.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
Subprocessor list: https://www.pleo.io/en/sub-processors
Security or trust page: https://www.pleo.io/en/trust-and-security
Data regions: EU

What to put in your subprocessor list

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

Subprocessor	Legal entity	Country	Purpose	Transfer	DPA
Pleo	Pleo Technologies A/S	DK	Finance	SCC	https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf

Questions people ask about Pleo

Where is Pleo's DPA?: Pleo publishes its customer data processing agreement at https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf. We last opened that link on 31 October 2026.
Is Pleo'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. Pleo's is at https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf.
Where is Pleo's sub-processor list?: Pleo publishes the list of its own sub-processors at https://www.pleo.io/en/sub-processors. We last opened that link on 31 October 2026.
Which legal entity does Pleo contract through?: Pleo Technologies A/S, registered in Denmark. That is the name to put in a record of processing or a sub-processor list, not the brand.
Does sending personal data to Pleo count as a transfer out of the EEA?: No. Pleo Technologies A/S is registered in Denmark, 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 Pleo's trust center?: Pleo publishes it at https://www.pleo.io/en/trust-and-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 Pleo's page, so we link to it rather than repeat what it says.

What has changed, and when

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

31 October 2026
No substantive changes were detected in the data processing agreement text.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
30 October 2026
No changes were detected in Pleo's data processing agreement.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
29 October 2026
No substantive changes were detected in Pleo's Data Processing Agreement.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
28 October 2026
No changes were detected in Pleo's data processing agreement.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
27 October 2026
No substantive changes were detected in Pleo's Data Processing Agreement.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
24 October 2026
No substantive changes were detected in the DPA text.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
23 October 2026
No substantive changes were detected in Pleo's data processing agreement.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
22 October 2026
No substantive changes were detected in the DPA text.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
21 October 2026
No changes detected in the DPA text between versions.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
20 October 2026
No substantive changes were detected in Pleo's data processing agreement.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
17 October 2026
No substantive changes were detected in the DPA text.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
16 October 2026
Pleo's Data Processing Agreement was reviewed but no changes were detected in the document content.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
15 October 2026
No substantive changes were detected in Pleo's data processing agreement.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
14 October 2026
No material changes were detected in the Data Processing Agreement text.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
13 October 2026
I cannot generate a change note because no actual text changes were detected in the DPA. The document shows 0 lines added and 0 removed, indicating no substantive modifications were made.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
10 October 2026
I cannot provide a change note because the input shows no lines were added or removed from the DPA. There is no substantive change to report.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
9 October 2026
No substantive changes were detected in the DPA text.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
8 October 2026
No substantive changes were detected in Pleo's data processing agreement.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
7 October 2026
No material changes were detected in the DPA text.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf
6 October 2026
No substantive changes were detected in the DPA text.
Seen on https://www.pleo.io/legal-documents/pleo-data-processing-addendum-en.pdf

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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.

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Pleo: DPA, subprocessors and transfers

What to put in your subprocessor list

Questions people ask about Pleo

What has changed, and when

Building your own sub-processor list?

Where to go next

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Pleo: DPA, subprocessors and transfers

What to put in your subprocessor list

Questions people ask about Pleo

What has changed, and when

Building your own sub-processor list?

Where to go next

Other finance