Pleo
Spend management · pleo.io · last read 2026-10-12
Identity
| Legal entity | Pleo Technologies A/S |
|---|---|
| HQ | DK |
| Parent company | — |
| Ultimate ownership | — |
| EU contracting entity | Pleo Financial Services A/S (and 1 other EU entity by country) |
| LEI | — |
| US CLOUD Act reach | Not determined from the sources read |
| Source | pleo.io · 2026-10-08 |
Data location
| Region | EU data location | Minimum plan | Source | Observed |
|---|---|---|---|---|
| EU | EU by default | — | pleo.io | 2026-10-08 |
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
| Subprocessor | Country | Purpose |
|---|---|---|
| Anthropic | US | AI-product enablement |
| Anthropic, PBC | US | AI-product enablement |
| Ashby | US | Recruiting Processes |
| AWS | IE | Application Infrastructure, Cloud Hosting |
| AWS | IE | Hosting Services |
| Enfuce | DE | Payment Processing |
| Everlaw | EU | Privacy Management |
| FreshWork & FreshDesk | EU | Support Ticketing System |
| Freshworks | EU | Customer support |
| Gong (optional) | EU | Insights Analysis |
| Google Cloud Platform (GCP) | EU | Analytics, App Functionalities |
| Google Cloud Platform (GCP) | EU | Hosting Services |
| Google Ireland | EU | Productivity suite |
| Grafana | US | Data Visualization |
| HubSpot | US | Customer Relationship Management (CRM) System |
| Hubspot | US | Marketing Activities |
| Launchdarkly | EU | Improve Application Feature Development |
| Microsoft Azure | EU | Cloud Provider |
| Microsoft Azure | EU | Hosting Services |
| Notion Labs | EU | Customer Support |
| Onfido | EU | Identity Verification, Fraud Detection and Compliance |
| Pay UK | GB | Fraud |
| Saltedge | DE | Open Banking Compliance with PSD2 |
| Scrive | EU | Identity Verification, Fraud Detection and Compliance |
| Taktile | EU | Fraud Prevention |
| Twilio | EU | Analytics Functionalities |
| Vitally | EU | Customer support |
Pleo's own group companies listed as subprocessors (9)
| Company | Country | Purpose |
|---|---|---|
| GTMPLEO Technologies Portugal, Unipessoal LDA | PT | — |
| Pleo North America, Inc | US | — |
| Pleo Technologies AB | SE | — |
| Pleo Technologies B.V | NL | — |
| Pleo Technologies GmbH | DE | — |
| Pleo Technologies Inc. | CA | — |
| Pleo Technologies Ltd | GB | — |
| Pleo Technologies S.L. | ES | — |
| Pleo Technologies SAS | FR | — |
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
| 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 | At least 10 days in advance, in writing, of additions or replacements to the agreed sub-processor list |
| Notice of new subprocessors | At 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 one | Data 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 one | Object 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 notification | without undue delay (data importer notifies data exporter and competent supervisory authority, for breaches likely to result in a risk) |
| Breach notification | without undue delay after becoming aware |
| Breach notification | without undue delay after becoming aware of the breach (data importer to data exporter, SCC Clause 8.6(C)) |
| Transfer impact assessment | Parties document the transfer assessment (SCC Clause 14(b)) and make it available to the competent supervisory authority on request |
| Transfer impact assessment | Pleo performs transfer impact assessments as required under applicable data protection laws, including the GDPR |
| Transfer impact assessment | Pleo will perform transfer impact assessments as required under applicable data protection laws, including the GDPR |
| Transfer impact assessment | SCC 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 |
| Audit | Independent 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 |
| Audit | On 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
| Scheme | Status | Scope | Source | Observed |
|---|---|---|---|---|
| CAIQ Self-Assessment · CAIQ | Claimed | to benchmark against industry best practices | pleo.io | 2026-10-08 |
| GDPR | Claimed | which protects the privacy and data of EU citizens | pleo.io | 2026-10-08 |
| authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 | Claimed | Pleo Financial Services UK Ltd; firm reference number: 1020730 | pleo.io | 2026-10-08 |
| Google's Cloud Application Security Assessment (CASA) | Claimed | for cloud security | pleo.io | 2026-10-08 |
| HackerOne's Bug Bounty Penetration Testing | Claimed | to identify and fix vulnerabilities | pleo.io | 2026-10-08 |
| PCI-DSS · PCIDSS | Claimed | for secure payment processing | pleo.io | 2026-10-08 |
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
| Register | Offering, as the register names it | Status | Level | Valid until | Observed |
|---|---|---|---|---|---|
| Global LEI Index (GLEIF) | Pleo Financial Services A/S · Pleo Financial Services A/S | ISSUED | DK | 2027-04-01 | 2026-10-09 |
| Global LEI Index (GLEIF) | Pleo Technologies A/S · Pleo Technologies A/S | ISSUED | DK | 2027-02-06 | 2026-10-09 |
- ACN qualified cloud (Italy): checked 2026-10-12, no entry under Pleo; Pleo Financial Services A/S; Pleo Technologies A/S
- DORA critical ICT third-party providers (ESAs): checked 2026-10-12, no entry under Pleo; Pleo Financial Services A/S; Pleo Technologies A/S
- Data Privacy Framework List (US): checked 2026-10-12, no entry under Pleo; Pleo Financial Services A/S; Pleo Technologies A/S
- EU Cloud Code of Conduct (GDPR Art. 40): checked 2026-10-12, no entry under Pleo; Pleo Financial Services A/S; Pleo Technologies A/S
- FedRAMP Marketplace (US): checked 2026-10-12, no entry under Pleo; Pleo Financial Services A/S; Pleo Technologies A/S
- SecNumCloud qualified services (ANSSI, France): checked 2026-10-12, no entry under Pleo; Pleo Financial Services A/S; Pleo Technologies A/S
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
| Document | Disclosure | Transcription | HTTP | Observed |
|---|---|---|---|---|
| certifications | Public | full | 200 | 2026-10-08 |
| dpa | Public | full | 200 | 2026-10-09 |
| residency | Public | full | 200 | 2026-10-08 |
| subprocessors | Public | full | 200 | 2026-10-08 |
History
Nothing has moved since we started watching this vendor on 2026-10-08. Changes appear here only after a human has reviewed them.