Zscaler
Security · zscaler.com · last read 2026-11-09
At a glance
- Is Zscaler GDPR compliant?
- No tool is GDPR compliant on its own: compliance depends on what you process with it and how. What follows is what Zscaler itself publishes, each answer linked to its source and the date we read it.
- Does Zscaler have a data processing agreement (DPA)?
- Yes. Zscaler publishes a data processing agreement at zscaler.com. It gives 30 days' notice before a new subprocessor is added. It promises breach notification "without undue delay", with no number of hours. Source and date
- Does Zscaler have a SOC 2 report?
- Zscaler 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 Zscaler ISO 27001 certified?
- Zscaler states ISO/IEC 27001 on its own page, but does not say there how to get the certificate. We read this on 2026-11-09. Source and date
- Does Zscaler use your data to train AI models?
- For business plans (Zscaler Products): Customer Data not used to create, develop, fine-tune or train AI without the Customer's prior consent, except solely to provide the Products to that Customer. Source and date
- How does Zscaler transfer personal data out of the EU?
- Zscaler's agreement relies on the EU standard contractual clauses, the EU-U.S. Data Privacy Framework and the UK transfer addendum. Source and date
- Who are Zscaler's subprocessors?
- Zscaler lists 19 third-party subprocessors; 16 of them name at least one processing country outside the EEA. We last read the list on 2026-11-09. Source and date
The same questions for any vendor, and the rule behind each: the vendor due diligence checklist.
Identity
| Legal entity | Zscaler, Inc. |
|---|---|
| HQ | US |
| Parent company | — |
| Ultimate ownership | US |
| EU contracting entity | — |
| LEI | 529900MZ0RTK1BWRNF46 |
| US CLOUD Act reach | Contracting entity incorporated in the US |
| Source | zscaler.com · 2026-11-09 |
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.
Data location
No data-location observation recorded yet.
The same question for every vendor: where SaaS vendors store EU data.
Zscaler'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
19 third parties · 1 of the vendor's own group companies · 16 with a country outside the EEA · all read 2026-11-09
| Subprocessor | Country | Purpose |
|---|---|---|
| Accenture Federal Services | US | Providing Zscaler Support Services for certain Gov Cloud Customers. |
| Alibaba Cloud | CN | Hosting for certain features of Zscaler Products to support Customer Users in China |
| Amazon Web Services (AWS) | — | Hosting for certain features of Zscaler products (ZPA, ZIA, ZDX, etc.) |
| CentraComm Communications | US | Augmenting Zscaler Support Services for GovCloud Customers, including responding to support tickets |
| Concentrix | BG, IN | Augmenting Zscaler Support Services, including responding to support tickets |
| Databricks | US | Hosting for certain features of Data Security Posture Management (DSPM) |
| Functional Software, Inc. d/b/a Sentry | US | Application monitoring for MDR |
| Google Cloud Platform | US, EU | Hosting for certain features of Zscaler Digital Experience (ZDX), CIEM, and other products |
| Have I Been Pwned | US, AU | Email address breach detection and exposure monitoring for Zero Trust Browser |
| JTP CO | JP | Augmenting Zscaler Support Services for Customers who require Japanese language capabilities |
| Microsoft Corporation (Azure) | — | Hosting for certain features of Zscaler products (ZPA, ZIA, ZDX, etc.) |
| Momentum Labs, Inc. | US | Improving customer support services |
| Movate (formerly CSS Corp. dba SlashSupport) | IN | Augmenting Zscaler Support Services, including responding to support tickets |
| Salesforce, Inc. | US | Customer support platform |
| Sendgrid (Twilio, Inc.) | US | Email communications provider for transactional notifications to system administrators for Zero Trust Browser and MDR |
| SendSafely, Inc. | US | Encrypted file exchange platform used for support services |
| Snowflake | — | Hosting for certain features of Zscaler Posture Control (ZPC), Asset Exposure Management, Identity Protection, and Agentic SecOps |
| Splunk, Inc. | US | Infrastructure logging and metrics for MDR |
| theLoopsai, Inc. | US | Improving customer support services |
Zscaler's own group companies listed as subprocessors (1)
| Company | Country | Purpose |
|---|---|---|
| Zscaler Affiliates | US, IN, BR, AU, CA, JP, IL, CR, GB, ES, SE, AT, DE, FR, CH, NL, PL, HR, SG | To provide the Products, including Support Services, order processing, etc. |
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 · zscaler.com
| Term | What the agreement says |
|---|---|
| Transfer mechanism | EU-U.S. DPF |
| Transfer mechanism | SCC (module not stated) |
| Transfer mechanism | UK Addendum |
| Notice of new subprocessors | At least 30 days advance notice, possibly by email to the address registered at the Zscaler Trust portal or other reasonable means |
| If you object to one | If unresolved within 30 days after objection, either party may terminate the affected Product(s); Customer receives pro-rated refund; sole remedy |
| If you object to one | Object within 30 days on reasonable data protection grounds; Zscaler will not engage the sub-processor, take corrective steps, or cease the feature; if no resolution within 30 days, either party may terminate affected Product(s) with pro-rated refund (sole remedy) |
| Breach notification | without undue delay |
| Audit | Audit by Customer or an independent auditor who is not a Zscaler competitor, no more than once per year during business hours (more often if agreed, required by a regulator/law, or after a Security Incident); 30 days' prior written notice; Customer reimburses Zscaler's audit expenses at an agreed rate; third-party certifications (e.g. ISO 27001, SOC 2 Type II) provided on request if available |
| Audit | Audit of data processing facilities no more than once per year during business hours (exceptions: agreed, regulator-required, or Security Incident); 30 days' prior written notice; by Customer or non-competitor independent auditor, subject to confidentiality |
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.
AI and your data
What Zscaler's own pages state about the data you send its AI products, plan by plan. Compared with other vendors on AI vendors and your data.
| Plans | Term | What the page says | Source | Observed |
|---|---|---|---|---|
| Business Zscaler Products | Training on your data | Not used unless you opt in Customer Data not used to create, develop, fine-tune or train AI without the Customer's prior consent, except solely to provide the Products to that Customer | zscaler.com | 2026-11-09 |
Assurance
Does Zscaler have a SOC 2 report?
Zscaler 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 Zscaler ISO 27001 certified?
Zscaler states ISO/IEC 27001 on its own page, but does not say there how to get the certificate. We read this on 2026-11-09.
On the same list Zscaler also names ISO/IEC 27017, ISO/IEC 27018 and ISO/IEC 27701. Each standard's page says how it relates to ISO/IEC 27001.
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 |
|---|---|---|---|---|
| CSA STAR Level 2 · CSA | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| Cyber Essentials Plus · CyberEssentialsPlus | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| EU-US DPF · DPF | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| Swiss-US DPF · DPF | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| UK Extension to EU-US DPF · DPF | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| ENS | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| GDPR | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| HIPAA | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| HITRUST | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| IRAP | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| ISMAP | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| ISO 22301 · ISO22301 | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| ISO/IEC 27001 · ISO27001 | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| ISO/IEC 27017:2015 · ISO27017 | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| ISO/IEC 27018:2019 · ISO27018 | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| ISO/IEC 27701 · ISO27701 | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| ITAR | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| MTCS Level 3 · MTCS | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| ACN | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| CCCS - CSP ITS | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| China Cybersecurity Law (CSL) | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| CISA: Secure-by-Design Pledge | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| CPSTIC Prod Med | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| CyberVadis Gold | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| DCSO Security Assessment | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| FIPS 140-2 | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| FIPS 140-3 | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| FSQS | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| G-Cloud | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| NIST 800-53 Rev. 5 | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| TruSight | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| PCI DSS · PCIDSS | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| SOC 2 Type 2 · SOC2T2 | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| SOC 3 · SOC3 | Claimed | — | compliance.zscaler.com | 2026-11-09 |
| TISAX | Claimed | — | compliance.zscaler.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
| Register | Offering, as the register names it | Status | Level | Valid until | Observed |
|---|---|---|---|---|---|
| ACN qualified cloud (Italy) | Zscaler Digital Experience · ZSCALER SWITZERLAND GMBH ITALY BRANCH | qualified | QC2 (SaaS) | 2028-12-16 | 2026-11-09 |
| ACN qualified cloud (Italy) | Zscaler Internet Access · ZSCALER SWITZERLAND GMBH ITALY BRANCH | qualified | QC2 (SaaS) | 2028-12-16 | 2026-11-09 |
| ACN qualified cloud (Italy) | Zscaler Private Access · ZSCALER SWITZERLAND GMBH ITALY BRANCH | qualified | QC2 (SaaS) | 2028-12-16 | 2026-11-09 |
| ENS certificates of conformity (CCN, Spain) | Los Sistemas de Información que soportan los servicios de la Plataforma Zscaler Zero Trust Exchange – ZTE, ubicados en Centros de Datos externalizados en las regiones de: España, Francia, Suecia, Noruega, UK, Suiza, Alemania, Holanda, Bélgica, Polonia, Finlandia, Dinamarca, Italia, Austria, Rusia, I… · Zscaler, Inc. | certified | ENS ALTA | 2028-07-31 | 2026-11-09 |
| FedRAMP Marketplace (US) | Zscaler Internet Access - Government (Secure Web Gateway - vTIC) · Zscaler, Inc. | FedRAMP Authorized | Moderate | — | 2026-11-09 |
| FedRAMP Marketplace (US) | Zscaler Internet Access - Government (Secure Web Gateway - vTIC) - High · Zscaler, Inc. | FedRAMP Authorized | High | — | 2026-11-09 |
| FedRAMP Marketplace (US) | Zscaler Private Access - Government (Zero Trust Exchange - VPN Replacement) · Zscaler, Inc. | FedRAMP Authorized | Moderate | — | 2026-11-09 |
| FedRAMP Marketplace (US) | Zscaler Private Access - Government (Zero Trust Networking - VPN Replacement) · Zscaler, Inc. | FedRAMP Authorized | High | — | 2026-11-09 |
| Global LEI Index (GLEIF) | ZSCALER, INC. · ZSCALER, INC. | ISSUED | US-DE | 2027-04-18 | 2026-11-09 |
- ACN qualified cloud (Italy): checked 2026-11-09, 3 entries under Zscaler; Zscaler, Inc.
- DORA critical ICT third-party providers (ESAs): checked 2026-11-09, no entry under Zscaler; Zscaler, Inc.
- ENS certificates of conformity (CCN, Spain): checked 2026-11-09, 1 entry under Zscaler; Zscaler, Inc.
- EU Cloud Code of Conduct (GDPR Art. 40): checked 2026-11-09, no entry under Zscaler; Zscaler, Inc.
- FedRAMP Marketplace (US): checked 2026-11-09, 4 entries under Zscaler; Zscaler, Inc.
- SecNumCloud qualified services (ANSSI, France): checked 2026-11-09, no entry under Zscaler; Zscaler, 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: no security.txt at the well-known path (read 2026-11-09)
How other vendors publish theirs: security.txt across the registry.
Documents
| Document | Disclosure | Transcription | HTTP | Observed |
|---|---|---|---|---|
| ai | Public | full | 200 | 2026-11-09 |
| 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.