Clay
Sales intelligence · clay.com · last read 2026-11-09
At a glance
- Is Clay GDPR compliant?
- No tool is GDPR compliant on its own: compliance depends on what you process with it and how. What follows is what Clay itself publishes, each answer linked to its source and the date we read it.
- Does Clay have a data processing agreement (DPA)?
- Yes. Clay publishes a data processing agreement at clay.com. It describes how a new subprocessor is announced but states no notice period. It promises breach notification "without undue delay", with no number of hours. Source and date
- Does Clay have a SOC 2 report?
- Clay states SOC 2 Type 2 on its own page, but does not say there how to get a report. We read this on 2026-11-09. Source and date
- Is Clay ISO 27001 certified?
- Clay states ISO/IEC 27001 certification (2022 edition, as Clay names it), and says the certificate or audit report is available on request. We read this on 2026-11-09. Source and date
- How does Clay transfer personal data out of the EU?
- Clay's agreement relies on the EU standard contractual clauses and the UK transfer addendum. Source and date
- Who are Clay's subprocessors?
- Clay lists 33 third-party subprocessors; 31 of them name at least one processing country outside the EEA. We last read the list on 2026-11-09. Source and date
- How do you report a security vulnerability to Clay?
- Clay publishes a security.txt at www.clay.com naming [email protected] or https://trust.clay.com. Source and date
The same questions for any vendor, and the rule behind each: the vendor due diligence checklist.
Identity
| Legal entity | Clay Labs, Inc. |
|---|---|
| HQ | — |
| Parent company | — |
| Ultimate ownership | — |
| EU contracting entity | — |
| LEI | — |
| US CLOUD Act reach | Not determined from the sources read |
| Source | clay.com · 2026-11-09 |
Data location
No data-location observation recorded yet.
The same question for every vendor: where SaaS vendors store EU data.
Clay's subprocessor list names AWS and Google for hosting or infrastructure. Which SaaS vendors run on which cloud, and the sovereign offerings of each: sovereign clouds.
Subprocessor chain
33 third parties · 1 of the vendor's own group companies · 31 with a country outside the EEA · all read 2026-11-09
| Subprocessor | Country | Purpose |
|---|---|---|
| Amazon Web Services | US | Cloud provider |
| Amplitude | US | Data analytics |
| Anthropic | US | LLM provider/hosting |
| Braintrust | US | LLM Operations |
| Browserbase | US | LLM Operations |
| ClickHouse | US | Database |
| Cohere | CA | LLM operations |
| Cube Dev | US | Data analytics |
| Datadog | US | APM and security |
| Fireworks | US | LLM provider/hosting |
| Fivetran | US | Data ETL |
| Google Gemini | US | LLM provider/hosting |
| Grafana | US | Logging and metrics |
| Intercom | US | Customer support |
| Langsmith | US | LLM logging and tracing |
| Mezmo | US | Logging and metrics |
| Mistral | FR | LLM provider/hosting |
| OpenAI | US | LLM provider/hosting |
| Parallel Web Systems | US | LLM operations |
| Planetscale | US | — |
| Postmark | US | Email service provider |
| Raindrop.ai | US | LLM operations |
| Segment | US | Data analytics |
| Sentry | US | Error logging |
| SerpApi | US | LLM operations |
| Serper | US | LLM operations |
| Slack | US | Customer Support |
| Smartlead | US | Email sequencer |
| Snowflake | US | Data analytics |
| Turbopuffer | US | Vector Database |
| Verisoul | US | Fraud Detection |
| WorkOS | US | Authentication support |
| Zenrows | ES | LLM operations |
Clay's own group companies listed as subprocessors (1)
| Company | Country | Purpose |
|---|---|---|
| CLAY LABS UK LTD | GB | — |
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 2026-11-09 · clay.com
| Term | What the agreement says |
|---|---|
| Transfer mechanism | SCC module 1 |
| Transfer mechanism | SCC module 2 |
| Transfer mechanism | SCC module 4 |
| Transfer mechanism | UK Addendum |
| Notice of new subprocessors | Notice to Customer before any intended change to Subprocessors (no period stated) |
| If you object to one | Object in writing on reasonable data-protection grounds within 30 days of notice; parties work in good faith; if Clay keeps the Subprocessor, either party may stop and terminate the affected Services |
| Breach notification | without undue delay |
| Audit | Information to demonstrate compliance; audits/inspections by an independent auditor no more than once per year (unless law or a Supervisory Authority requires more), during business hours; each party bears its own costs; Clay may instead provide a summary of third-party audit or certification reports where permitted by law |
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
We found no version number or date in the agreement as we read it.
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 Clay have a SOC 2 report?
Clay states SOC 2 Type 2 on its own page, but does not say there how to get a report. We read this on 2026-11-09.
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 Clay ISO 27001 certified?
Clay states ISO/IEC 27001 certification (2022 edition, as Clay names it), and says the certificate or audit report is available on request. We read this on 2026-11-09.
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.clay.com | 2026-11-09 |
| GDPR | Claimed | — | trust.clay.com | 2026-11-09 |
| ISO 27001:2022 · ISO27001 | Available on request | — | trust.clay.com | 2026-11-09 |
| ISO 42001:2023 · ISO42001 | Available on request | — | trust.clay.com | 2026-11-09 |
| SOC 2 Type 2 · SOC2T2 | Claimed | — | trust.clay.com | 2026-11-09 |
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
- ACN qualified cloud (Italy): checked 2026-11-09, no entry under Clay; Clay Labs, Inc.
- DORA critical ICT third-party providers (ESAs): checked 2026-11-09, no entry under Clay; Clay Labs, Inc.
- ENS certificates of conformity (CCN, Spain): checked 2026-11-09, no entry under Clay; Clay Labs, Inc.
- EU Cloud Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under Clay; Clay Labs, Inc.
- FedRAMP Marketplace (US): checked 2026-11-09, no entry under Clay; Clay Labs, Inc.
- SecNumCloud qualified services (ANSSI, France): checked 2026-11-09, no entry under Clay; Clay Labs, Inc.
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.
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: [email protected], trust.clay.com (security.txt, expires 2027-07-31; read 2026-11-09)
How other vendors publish theirs: security.txt across the registry.
Documents
| Document | Disclosure | Transcription | HTTP | Observed |
|---|---|---|---|---|
| certifications | Public | full | 200 | 2026-11-09 |
| dpa | Public | full | 200 | 2026-11-09 |
| subprocessors | Public | full | 200 | 2026-11-09 |
History
Nothing has moved since we started watching this vendor on 2026-11-09. Changes appear here only after a human has reviewed them.
Every reviewed change across the registry, newest first: vendor changes.