Apollo.io
Sales intelligence · apollo.io · last read 2026-11-09
At a glance
- Is Apollo.io GDPR compliant?
- No tool is GDPR compliant on its own: compliance depends on what you process with it and how. What follows is what Apollo.io itself publishes, each answer linked to its source and the date we read it.
- Does Apollo.io have a data processing agreement (DPA)?
- Yes. Apollo.io publishes a data processing agreement at apollo.io. It gives 30 days' notice before a new subprocessor is added. It commits to telling you of a personal data breach within 72 hours. Source and date
- Which version of the Apollo.io DPA is current?
- On 2026-11-09, Apollo.io's DPA at apollo.io printed “Updated August 10, 2026”. Source and date
- Does Apollo.io have a SOC 2 report?
- Apollo.io says a SOC 2 Type 2 report is available on request. In Apollo.io's words: “Use this Apollo Trust Center to learn about our security posture and request access to our security documentation.” We read this on 2026-10-25. Source and date
- Is Apollo.io ISO 27001 certified?
- Apollo.io states ISO/IEC 27001 certification, and says the certificate or audit report is available on request. In Apollo.io's words: “ISO 27001 Recertification: This international security standard reflects our commitment to protecting your data through comprehensive security practices across all levels of our organization.” We read this on 2026-10-25. Source and date
- Where is Apollo.io's trust center?
- Apollo.io publishes a page it calls “Trust Center” at trust.apollo.io. Some of its documents sit behind a request or sign-in: the page says “Get access”. The page mentions SOC 2, ISO 27001, a penetration test, subprocessors and security questionnaires. We read it on 2026-11-03. Source and date
- How does Apollo.io transfer personal data out of the EU?
- Apollo.io's agreement relies on the EU standard contractual clauses, the EU-U.S. Data Privacy Framework and the UK transfer addendum. Zenleads Inc. (dba Apollo.io) is on the official Data Privacy Framework List (status: Active). Source and date
- Who are Apollo.io's subprocessors?
- Apollo.io lists 23 third-party subprocessors; 23 of them name at least one processing country outside the EEA. We last read the list on 2026-11-02. We have recorded 1 change to it, the latest on 2026-11-02. Source and date
The same questions for any vendor, and the rule behind each: the vendor due diligence checklist.
Identity
| Legal entity | ZenLeads Inc. d/b/a Apollo.io |
|---|---|
| HQ | — |
| Parent company | — |
| Ultimate ownership | — |
| EU contracting entity | — |
| LEI | — |
| US CLOUD Act reach | Not determined from the sources read |
| Source | apollo.io · 2026-10-25 |
Data location
No data-location observation recorded yet.
The same question for every vendor: where SaaS vendors store EU data.
Apollo.io's subprocessor list names AWS, Microsoft and Google for hosting or infrastructure. Which SaaS vendors run on which cloud, and the sovereign offerings of each: sovereign clouds.
Subprocessor chain
23 third parties · 23 with a country outside the EEA · all read 2026-11-02
| Subprocessor | Country | Purpose |
|---|---|---|
| Amazon Web Services (AWS) | US | Secure cloud hosting of production files such as images and attachments |
| Anthropic | US | Artificially Generated Project and Communications Recommendations |
| AssemblyAI | US | Transforms call recordings into transcripts |
| Astronomer | US | Internal analytics and orchestration platform |
| Baseten | US | Model inference infrastructure for AI-powered platform features. |
| Cloudflare | US | Content delivery network and cloud cybersecurity services |
| Databricks | US | Cloud-based platform used for processing high volume data |
| Datadog | US | Data observability platform |
| dbt Labs | US | Data analytics |
| Exa | US | AI-powered web search API |
| Fullview | US | Session replay and co-browsing technology for customer support and issue resolution |
| Google Cloud | US | Secure cloud hosting of production systems; suite of business apps including email, calendar, contact management, file sharing and artificially generated project and communications recommendations |
| LangChain | US | Observability platform for AI products |
| Microsoft Azure | US | Hosting and AI Provider |
| Nylas | US | API software that facilitates email and calendar synchronization |
| OpenAI | US | Artificially Generated Project and Communications Recommendations |
| Panther Labs, Inc. | US | Security information and event management platform to centralize logs and detect threats |
| Perplexity AI | US | Search engine functionality |
| Quarterzip | US | AI-powered customer onboarding platform |
| Recall.ai | US | Call recording technology |
| Snowflake | US | Data warehousing services |
| Team Mailpool | US | Email infrastructure platform |
| Twilio | US | Direct dialer provider |
The count outside the EEA is arithmetic over the country column, not a judgement about lawfulness. A transfer outside the EEA can be perfectly lawful; whether this one is depends on your use, not on the vendor.
Every subprocessor in the registry, and which vendors name it: subprocessors.
Processing terms
From the vendor's data processing agreement · read 2026-10-25 · apollo.io
| Term | What the agreement says |
|---|---|
| Transfer mechanism | EU-U.S. DPF |
| Transfer mechanism | SCC module 1 |
| Transfer mechanism | SCC module 2 |
| Transfer mechanism | Swiss FADP clauses |
| Transfer mechanism | UK Addendum |
| Notice of new subprocessors | At least 30 days before the new Subprocessor starts processing, by posting on the privacy center or trust webpage, or by email to the last known address |
| If you object to one | Customer may object on reasonable data-protection grounds. The parties then negotiate in good faith. If they don't agree within 30 days, the customer may terminate immediately and get a refund of prepaid fees for unused services, which is its sole and exclusive remedy. If it doesn't object within 30 days of the Notice, it is deemed to accept. |
| Obligations passed to subprocessors | written agreement with each Subprocessor imposing substantially similar data protection obligations as are imposed on the vendor as Processor under the DPA |
| Breach notification | without undue delay |
| Breach notification | without undue delay, and in any event within 72 hours of confirmation |
| Deletion when the service ends | At Customer's election, made within 90 days of termination, deletes all Customer Personal Data processed by Apollo or its Subprocessors (or returns it instead); retention only as required by applicable law, kept confidential |
| Getting your data back | at Customer's election, within 90 days of termination, return a complete copy of all Customer Personal Data by secure file transfer in a format Customer specifies |
| Requests from data subjects | reasonable endeavors to assist via appropriate technical and organizational measures in responding to data subject rights requests, to the extent required by law |
| Audit | On reasonable request, vendor makes available information reasonably necessary to demonstrate compliance |
| Audit | audits/inspections by customer or its mandated third party, where required by Data Protection Law; no more than once per year (unless a Supervisory Authority requests); during business hours; minimal disruption |
| Processing on your instructions | only in accordance with Customer's Instructions; notifies Customer if law requires processing otherwise (unless legally prohibited) |
| Confidentiality of staff | Customer Personal Data treated as confidential; authorized employees and personnel bound by a binding duty of confidentiality during and after their engagement |
| Security measures | appropriate technical and organizational measures to ensure security appropriate to the risk, including the measures set out in Exhibit 2 |
Terms as the agreement states them. Where it is silent on a term, there is no row; that is not a statement that the vendor does not offer it.
Which version applies
On 2026-11-09, the agreement printed: Updated August 10, 2026
at apollo.io
Last updated 2026-08-10
This version is in our copies from 2026-10-25.
These terms side by side for every vendor: data processing agreements compared. What vendors give you for a transfer impact assessment: transfer impact assessments.
Assurance
Does Apollo.io have a SOC 2 report?
Apollo.io says a SOC 2 Type 2 report is available on request. We read this on 2026-10-25.
- Available on request “Use this Apollo Trust Center to learn about our security posture and request access to our security documentation.”
- Available on request “SOC 2 Type 2 Report (Security, Availability, Confidentiality): Validated by independent auditors”
Source: trust.apollo.io, 2026-10-25
Of the 114 vendors in this registry whose own pages mention SOC 2, 57 say the report is available on request, 1 links to the report itself, and 56 state it without saying how to get it. The type is the one the vendor names.
Is Apollo.io ISO 27001 certified?
Apollo.io states ISO/IEC 27001 certification, and says the certificate or audit report is available on request. We read this on 2026-10-25.
- Available on request “ISO 27001 Recertification: This international security standard reflects our commitment to protecting your data through comprehensive security practices across all levels of our organization.”
Source: trust.apollo.io, 2026-10-25
Of the 122 vendors in this registry whose own pages state ISO/IEC 27001, 16 link to the certificate, 43 say it is available on request, and 63 state it without saying how to get it. A certificate names the certification body, the scope and the expiry date: those are the three things to check.
| Scheme | Status | Scope | Source | Observed |
|---|---|---|---|---|
| CCPA | Claimed | — | trust.apollo.io | 2026-10-25 |
| CPRA · CCPA | Claimed | — | trust.apollo.io | 2026-10-25 |
| EU-US DPF · DPF | Claimed | — | trust.apollo.io | 2026-10-25 |
| GDPR | Claimed | — | trust.apollo.io | 2026-10-25 |
| ISO 27001 · ISO27001 | Available on request | across all levels of our organization | trust.apollo.io | 2026-10-25 |
| ISO/IEC 27001 · ISO27001 | Claimed | — | trust.apollo.io | 2026-10-25 |
| ISO/IEC 27001 SoA · ISO27001 | Claimed | — | trust.apollo.io | 2026-10-25 |
| CASA Tier 2 | Claimed | — | trust.apollo.io | 2026-10-25 |
| Cloud Application Security Assessment (CASA) | Available on request | our application | trust.apollo.io | 2026-10-25 |
| PCI DSS · PCIDSS | Available on request | — | trust.apollo.io | 2026-10-25 |
| SOC 2 · SOC2 | Available on request | — | trust.apollo.io | 2026-10-25 |
| SOC 2 Type 2 · SOC2T2 | Available on request | Security, Availability, Confidentiality | trust.apollo.io | 2026-10-25 |
Claimed means the vendor asserts the scheme on its own page and offers nothing further. Available on request means the report or certificate exists but sits behind a request, a login or an NDA. Neither is a certificate we have seen. That is a distinction an auditor makes, so we make it too.
SecNumCloud, C5, ENS and HDS for every vendor, with the pages for ISO standards, SOC 2 and TISAX: certifications compared.
Official registers
| Register | Offering, as the register names it | Status | Level | Valid until | Observed |
|---|---|---|---|---|---|
| Data Privacy Framework List (US) | EU-U.S. Data Privacy Framework · Zenleads Inc. (dba Apollo.io) | Active | HR data, non-HR data | 2027-03-17 | 2026-10-25 |
| Data Privacy Framework List (US) | Swiss-U.S. Data Privacy Framework · Zenleads Inc. (dba Apollo.io) | Active | HR data, non-HR data | 2027-03-17 | 2026-10-25 |
| Data Privacy Framework List (US) | UK Extension to the EU-U.S. DPF · Zenleads Inc. (dba Apollo.io) | Active | HR data, non-HR data | 2027-03-17 | 2026-10-25 |
- ACN qualified cloud (Italy): checked 2026-11-09, no entry under Apollo.io; ZenLeads Inc. d/b/a Apollo.io
- ISO 27001 on the basis of IT-Grundschutz (BSI, Germany): checked 2026-11-09, no entry under Apollo.io; ZenLeads Inc. d/b/a Apollo.io
- CISPE Data Protection Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under Apollo.io; ZenLeads Inc. d/b/a Apollo.io
- DORA critical ICT third-party providers (ESAs): checked 2026-11-09, no entry under Apollo.io; ZenLeads Inc. d/b/a Apollo.io
- Data Privacy Framework List (US): checked 2026-11-09, 3 entries under Apollo.io; ZenLeads Inc. d/b/a Apollo.io
- ENS certificates of conformity (CCN, Spain): checked 2026-11-09, no entry under Apollo.io; ZenLeads Inc. d/b/a Apollo.io
- EU Cloud Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under Apollo.io; ZenLeads Inc. d/b/a Apollo.io
- FedRAMP Marketplace (US): checked 2026-11-09, no entry under Apollo.io; ZenLeads Inc. d/b/a Apollo.io
- GPAI Code of Practice signatories (European Commission): checked 2026-11-09, no entry under Apollo.io; ZenLeads Inc. d/b/a Apollo.io
- SecNumCloud qualified services (ANSSI, France): checked 2026-11-09, no entry under Apollo.io; ZenLeads Inc. d/b/a Apollo.io
What the authority publishes, not what the vendor claims. An entry covers the offering it names and nothing else: a FedRAMP authorisation for a government edition says nothing about the commercial service. No entry is not a finding about security - most vendors never apply - and an entry filed under a name not listed above would not have been found.
What an entry on the Data Privacy Framework List covers, and which vendors hold one: EU-US Data Privacy Framework.
Support window
Not yet collected. This row will say not declared only once we have read a lifecycle or security page and found no period stated — see support windows.
Vulnerability reporting: no security.txt at the well-known path (read 2026-10-25)
How other vendors publish theirs: security.txt across the registry.
Documents
Where is Apollo.io's trust center?
Apollo.io publishes a page it calls “Trust Center” at trust.apollo.io. Some of its documents sit behind a request or sign-in. The page mentions SOC 2, ISO 27001, a penetration test, subprocessors and security questionnaires. We read it on 2026-11-03. Open trust.apollo.io
- Name “Welcome to Apollo.io's Apollo Trust Center. Our commitment to data privacy and security is embedded in every part of our business. Use this Apollo Trust Center”
- Request step “Get access”
Source: trust.apollo.io, 2026-11-03. Read from the page's text, without a model; every vendor's trust center.
| Document | Disclosure | Transcription | HTTP | Observed |
|---|---|---|---|---|
| certifications | Public | full | 200 | 2026-10-25 |
| dpa | Public | full | 200 | 2026-10-25 |
| identity | Public | full | 200 | 2026-10-25 |
| subprocessors | Public | full | 200 | 2026-11-02 |
History
| Detected | What moved | Why | Source |
|---|---|---|---|
| 2026-11-02 | Subprocessors removed NetNut Ltd. | the vendor changed it | trust.apollo.io |
Every reviewed change across the registry, newest first: vendor changes.