Miro · Miro Privacy Policy · View original document ↗

Third-Party Subprocessors

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Document Record

What it is

Miro uses third-party subprocessors to deliver its services, and the current list of subprocessors is maintained as a separate document at miro.com/legal/subprocessors-list/. This list may change over time as Miro adds or removes vendors.

This analysis describes what Miro's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

Subprocessors have access to your data to help deliver Miro's services, and changes to the subprocessors list can affect where and how your data is processed, including in jurisdictions outside the EU or US.

Change history

removed May 21, 2026

Removal of specific subprocessor disclosure provision replaced by broader 'Third-Party Data Sharing', potentially reducing transparency on vendor chain.

View full change record →

Consumer impact (what this means for users)

Your personal data and board content may be shared with multiple third-party vendors listed on Miro's Subprocessors page. The list can change, so users and organizations with strict data residency requirements should monitor it for updates.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Export Your Data
    Review the current Subprocessors List at miro.com/legal/subprocessors-list/ to understand which third parties process your data. Enterprise customers should confirm their DPA includes a notification mechanism for subprocessor changes.

How other platforms handle this

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Skillshare Medium

We may share your information with third-party vendors and service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. We may also share your information with third-party advertising p...

Bumble Medium

We may also share your personal information with third parties that assist us in providing our services, or where we are under an obligation to report to. But rest assured: we will only ever share your personal information in the limited circumstances described in this Policy.

See all platforms with this clause type →

Monitoring

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ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: Subprocessor obligations are governed by GDPR Article 28, which requires that subprocessors provide sufficient guarantees and are subject to contractual obligations equivalent to those in the controller-processor agreement. CCPA creates parallel service provider obligations for US-based subprocessors. (2) GOVERNANCE EXPOSURE: Medium. Maintaining a separate, living subprocessors document rather than embedding the list in the Privacy Policy creates monitoring obligations for compliance teams. Changes to subprocessors may trigger notification obligations under the DPA and may require updated transfer impact assessments. (3) JURISDICTION FLAGS: Subprocessors operating outside the EU or EEA without adequacy decisions require Standard Contractual Clauses or equivalent transfer mechanisms. Organizations with data residency requirements must verify that subprocessors can comply. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise DPAs should specify the notice period for subprocessor changes and the customer's right to object. Compliance teams should subscribe to or actively monitor the Subprocessors List for changes affecting their data categories. (5) COMPLIANCE CONSIDERATIONS: Vendor risk management programs should include periodic review of the Subprocessors List. Any newly added subprocessors processing special category data should trigger a supplementary transfer impact assessment.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has authority over third-party data sharing practices that may constitute unfair or deceptive practices, including inadequate disclosure of subprocessor relationships.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
DMA
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Miro Privacy Policy
Entity
Miro
Document last updated
May 5, 2026
Tracking information
First tracked
May 9, 2026
Last verified
May 9, 2026
Record ID
CA-P-007870
Document ID
CA-D-00556
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a766bd8974076725d4f7690306d79ec6e2b4a86b9e1aa6729b289f5f5eaa9056
Analysis generated
May 9, 2026 23:53 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Miro
Document: Miro Privacy Policy
Record ID: CA-P-007870
Captured: 2026-05-09 23:53:38 UTC
SHA-256: a766bd8974076725…
URL: https://conductatlas.com/platform/miro/miro-privacy-policy/third-party-subprocessors/
Accessed: June 27, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Miro's Third-Party Subprocessors clause do?

Subprocessors have access to your data to help deliver Miro's services, and changes to the subprocessors list can affect where and how your data is processed, including in jurisdictions outside the EU or US.

How does this clause affect you?

Your personal data and board content may be shared with multiple third-party vendors listed on Miro's Subprocessors page. The list can change, so users and organizations with strict data residency requirements should monitor it for updates.

Is ConductAtlas affiliated with Miro?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Miro.