CleverReach
Email marketing · cleverreach.com · last read 2026-11-09
At a glance
- Is CleverReach GDPR compliant?
- No tool is GDPR compliant on its own: compliance depends on what you process with it and how. What follows is what CleverReach itself publishes, each answer linked to its source and the date we read it.
- Does CleverReach have a data processing agreement (DPA)?
- Yes. CleverReach publishes a data processing agreement at eu2.cleverreach.com. It describes how a new subprocessor is announced but states no notice period. Source and date
- How does CleverReach transfer personal data out of the EU?
- CleverReach's agreement relies on the EU standard contractual clauses and the EU-U.S. Data Privacy Framework. We found no entry for CleverReach on the official Data Privacy Framework List. Source and date
- Does CleverReach offer EU data residency?
- The EU is the default region for this vendor. Source and date
- Who are CleverReach's subprocessors?
- CleverReach lists 3 third-party subprocessors; 0 of them name at least one processing country outside the EEA. We last read the list on 2026-10-25. Source and date
- How do you report a security vulnerability to CleverReach?
- CleverReach publishes a security.txt at www.cleverreach.com naming [email protected]. The file falls short of RFC 9116: expired 2024-12-31. Source and date
The same questions for any vendor, and the rule behind each: the vendor due diligence checklist.
Identity
| Legal entity | CleverReach GmbH & Co. KG |
|---|---|
| HQ | DE |
| Parent company | — |
| Ultimate ownership | — |
| EU contracting entity | — |
| LEI | 3912003MG9BS05PLY117 |
| US CLOUD Act reach | Not determined from the sources read |
| Source | cleverreach.com · 2026-10-25 |
Legal entity from the vendor's own terms. LEI, registered country and parent company from the Global LEI Index (GLEIF); ownership is left empty where GLEIF names no parent. The CLOUD Act row is arithmetic over those countries, not an assessment of risk.
CleverReach data residency
| Region | EU data location | Minimum plan | Source | Observed |
|---|---|---|---|---|
| EU | EU by default | — | cleverreach.com | 2026-10-25 |
EU: All data is stored in the vendor's data centers exclusively in the European region; no customer choice, plan, or cost is mentioned.
The same question for every vendor: where SaaS vendors store EU data.
CleverReach's subprocessor list names AWS for hosting or infrastructure. Which SaaS vendors run on which cloud, and the sovereign offerings of each: sovereign clouds.
Subprocessor chain
3 third parties · 0 with a country outside the EEA · all read 2026-10-25
| Subprocessor | Country | Purpose |
|---|---|---|
| Amazon Web Services, Inc. | IE, DE | Data storage and processing, E-mail dispatch |
| Hetzner Online GmbH | DE | E-mail dispatch |
| PlusServer GmbH | DE | E-mail dispatch |
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 · eu2.cleverreach.com
| Term | What the agreement says |
|---|---|
| Transfer mechanism | EU-U.S. DPF |
| Transfer mechanism | SCC (module not stated) |
| Notice of new subprocessors | Controller informed in advance of any intended addition or replacement of sub-processors; notice period not stated |
| If you object to one | Controller may object to intended changes of subprocessors within 30 days; objection must be in writing and only for good reasons (e.g., violation of data protection law) |
| If you object to one | Controller may object within 30 days, in written form, and only for good reasons (e.g. a breach of data protection law) |
| Obligations passed to subprocessors | Written contract ensuring the regulations of this Agreement also apply to subcontractors, with sufficient guarantees of appropriate technical and organisational measures |
| Breach notification | immediately, including suspected breaches; violations reported without delay |
| Deletion when the service ends | After completion of the processing, delete or return all personal data at the Controller's discretion, unless a legal obligation to store applies; also applies to backup copies in accordance with the technical and organisational measures |
| Getting your data back | After completion of the processing, return all personal data at the Controller's discretion (as an alternative to deletion), unless a legal obligation to store applies |
| Requests from data subjects | Supports Controller in responding to data subject rights requests; requests sent directly to the Processor are forwarded immediately to the Controller; information to data subjects only after Controller's prior instruction |
| Audit | Controller or its appointee may monitor compliance by obtaining information, requesting documents, or accessing Processor's offices during business hours after prior notice; certificates (e.g., ISO 27001) may serve as evidence |
| Processing on your instructions | only in accordance with the Controller's instructions and within the scope of the contract, unless required by EU or Member State law (Controller informed beforehand unless prohibited) |
| Confidentiality of staff | Persons authorized to process the personal data are bound by confidentiality or subject to an appropriate statutory confidentiality obligation; personnel familiarized with data protection provisions |
| Security measures | appropriate technical and organizational security measures, documented in Annex 3 |
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
No certification claims transcribed yet.
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 |
|---|---|---|---|---|---|
| Global LEI Index (GLEIF) | CleverReach GmbH & Co. KG · CleverReach GmbH & Co. KG | ISSUED | DE | 2027-09-17 | 2026-10-25 |
- ACN qualified cloud (Italy): checked 2026-11-09, no entry under CleverReach; CleverReach GmbH & Co. KG
- ISO 27001 on the basis of IT-Grundschutz (BSI, Germany): checked 2026-11-09, no entry under CleverReach; CleverReach GmbH & Co. KG
- CISPE Data Protection Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under CleverReach; CleverReach GmbH & Co. KG
- DORA critical ICT third-party providers (ESAs): checked 2026-11-09, no entry under CleverReach; CleverReach GmbH & Co. KG
- Data Privacy Framework List (US): checked 2026-11-09, no entry under CleverReach; CleverReach GmbH & Co. KG
- ENS certificates of conformity (CCN, Spain): checked 2026-11-09, no entry under CleverReach; CleverReach GmbH & Co. KG
- EU Cloud Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under CleverReach; CleverReach GmbH & Co. KG
- FedRAMP Marketplace (US): checked 2026-11-09, no entry under CleverReach; CleverReach GmbH & Co. KG
- GPAI Code of Practice signatories (European Commission): checked 2026-11-09, no entry under CleverReach; CleverReach GmbH & Co. KG
- SecNumCloud qualified services (ANSSI, France): checked 2026-11-09, no entry under CleverReach; CleverReach GmbH & Co. KG
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: [email protected] (security.txt, expired 2024-12-31; read 2026-10-25)
How other vendors publish theirs: security.txt across the registry.
Documents
| Document | Disclosure | Transcription | HTTP | Observed |
|---|---|---|---|---|
| dpa | Public | full | 200 | 2026-10-25 |
| identity | Public | full | 200 | 2026-10-25 |
| residency | Public | full | 200 | 2026-10-25 |
| subprocessors | Public | full | 200 | 2026-10-25 |
History
Nothing has moved since we started watching this vendor on 2026-10-25. Changes appear here only after a human has reviewed them.
Every reviewed change across the registry, newest first: vendor changes.