eucsoft

Pleo

Spend management · pleo.io · last read 2026-10-12

Identity

Legal entityPleo Technologies A/S
HQDK
Parent company—
Ultimate ownership—
EU contracting entityPleo Financial Services A/S (and 1 other EU entity by country)
LEI—
US CLOUD Act reachNot determined from the sources read
Sourcepleo.io · 2026-10-08

Data location

RegionEU data locationMinimum planSourceObserved
EUEU by default—pleo.io2026-10-08

EU: The document says customer data is stored and processed in data centers in Ireland (eu-west-1) and that AWS data centres are in the EU/EEA. It mentions no customer choice, plan or cost.

Subprocessor chain

27 third parties · 9 of the vendor's own group companies · 10 with a country outside the EEA · all read 2026-10-08

SubprocessorCountryPurpose
AnthropicUSAI-product enablement
Anthropic, PBCUSAI-product enablement
AshbyUSRecruiting Processes
AWSIEApplication Infrastructure, Cloud Hosting
AWSIEHosting Services
EnfuceDEPayment Processing
EverlawEUPrivacy Management
FreshWork & FreshDeskEUSupport Ticketing System
FreshworksEUCustomer support
Gong (optional)EUInsights Analysis
Google Cloud Platform (GCP)EUAnalytics, App Functionalities
Google Cloud Platform (GCP)EUHosting Services
Google IrelandEUProductivity suite
GrafanaUSData Visualization
HubSpotUSCustomer Relationship Management (CRM) System
HubspotUSMarketing Activities
LaunchdarklyEUImprove Application Feature Development
Microsoft AzureEUCloud Provider
Microsoft AzureEUHosting Services
Notion LabsEUCustomer Support
OnfidoEUIdentity Verification, Fraud Detection and Compliance
Pay UKGBFraud
SaltedgeDEOpen Banking Compliance with PSD2
ScriveEUIdentity Verification, Fraud Detection and Compliance
TaktileEUFraud Prevention
TwilioEUAnalytics Functionalities
VitallyEUCustomer support
Pleo's own group companies listed as subprocessors (9)
CompanyCountryPurpose
GTMPLEO Technologies Portugal, Unipessoal LDAPT—
Pleo North America, IncUS—
Pleo Technologies ABSE—
Pleo Technologies B.VNL—
Pleo Technologies GmbHDE—
Pleo Technologies Inc.CA—
Pleo Technologies LtdGB—
Pleo Technologies S.L.ES—
Pleo Technologies SASFR—

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.

Processing terms

From the vendor's data processing agreement · read 2026-10-09 · pleo.io

TermWhat the agreement says
Transfer mechanismSCC module 1
Transfer mechanismSCC module 2
Transfer mechanismSCC module 4
Transfer mechanismUK Addendum
Notice of new subprocessorsAt least 10 days in advance, in writing, of additions or replacements to the agreed sub-processor list
Notice of new subprocessorsAt least 30 calendar days before the new sub-processor processes Customer Data, by notice to the email provided in the Order Form; list published at https://www.pleo.io/en/sub-processors
If you object to oneData exporter may object to the changes before the sub-processor is engaged; the data importer must provide the information needed to exercise this right
If you object to oneObject in writing to [email protected] within 15 days of notice; Pleo uses reasonable efforts to offer a change; if none within 60 days, customer may terminate only the affected Services; no timely objection counts as consent
Breach notificationwithout undue delay (data importer notifies data exporter and competent supervisory authority, for breaches likely to result in a risk)
Breach notificationwithout undue delay after becoming aware
Breach notificationwithout undue delay after becoming aware of the breach (data importer to data exporter, SCC Clause 8.6(C))
Transfer impact assessmentParties document the transfer assessment (SCC Clause 14(b)) and make it available to the competent supervisory authority on request
Transfer impact assessmentPleo performs transfer impact assessments as required under applicable data protection laws, including the GDPR
Transfer impact assessmentPleo will perform transfer impact assessments as required under applicable data protection laws, including the GDPR
Transfer impact assessmentSCC Clause 14 warranty: the parties declare they took account of the transfer circumstances, the destination country's laws and practices, and any supplementary safeguards; no separate TIA document is mentioned
AuditIndependent third-party and internal audits against PCI standards; customer (or its chosen third-party auditor) may audit if available info is insufficient, after a Security Incident notice, or if required by law/regulator; up to once a year with at least three weeks' written notice, during business hours; customer reimburses personnel expenses
AuditOn data exporter's request, importer allows and contributes to audits at reasonable intervals or if there are indications of non-compliance; exporter may audit itself or mandate an independent auditor; may include on-site inspections with reasonable notice; certifications may be taken into account

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.

Assurance

SchemeStatusScopeSourceObserved
CAIQ Self-Assessment · CAIQClaimedto benchmark against industry best practicespleo.io2026-10-08
GDPRClaimedwhich protects the privacy and data of EU citizenspleo.io2026-10-08
authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011ClaimedPleo Financial Services UK Ltd; firm reference number: 1020730pleo.io2026-10-08
Google's Cloud Application Security Assessment (CASA)Claimedfor cloud securitypleo.io2026-10-08
HackerOne's Bug Bounty Penetration TestingClaimedto identify and fix vulnerabilitiespleo.io2026-10-08
PCI-DSS · PCIDSSClaimedfor secure payment processingpleo.io2026-10-08

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.

Official registers

RegisterOffering, as the register names itStatusLevelValid untilObserved
Global LEI Index (GLEIF)Pleo Financial Services A/S · Pleo Financial Services A/SISSUEDDK2027-04-012026-10-09
Global LEI Index (GLEIF)Pleo Technologies A/S · Pleo Technologies A/SISSUEDDK2027-02-062026-10-09

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: no security.txt at the well-known path (read 2026-10-11)

Documents

What we read, how it was disclosed, and when.
DocumentDisclosureTranscriptionHTTPObserved
certificationsPublicfull2002026-10-08
dpaPublicfull2002026-10-09
residencyPublicfull2002026-10-08
subprocessorsPublicfull2002026-10-08

History

Nothing has moved since we started watching this vendor on 2026-10-08. Changes appear here only after a human has reviewed them.