The terms reference a Customer Data Processing Addendum (CDPA), accessible at miro.com/legal/customer-data-processing-addendum/, which governs Miro's processing of personal data on behalf of customers, particularly relevant for GDPR Article 28 compliance.
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
The CDPA establishes Miro's obligations as a data processor under GDPR and similar frameworks, defining the legal basis and conditions under which customer personal data is processed. Enterprise customers are required to assess the CDPA to satisfy their own controller-level compliance obligations.
Interpretive note: The CDPA is referenced by the Terms of Service but its substantive provisions are contained in a separate document; compliance implications depend on the CDPA's specific content.
The agreement incorporates a separate Customer Data Processing Addendum that governs how personal data processed through Miro boards and services is handled under data protection law. Business customers acting as data controllers under GDPR should review the CDPA in conjunction with the Subprocessors List.
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(1) REGULATORY LANDSCAPE: The CDPA directly implicates GDPR Article 28, which requires a written contract between controllers and processors.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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The CDPA establishes Miro's obligations as a data processor under GDPR and similar frameworks, defining the legal basis and conditions under which customer personal data is processed. Enterprise customers are required to assess the CDPA to satisfy their own controller-level compliance obligations.
The agreement incorporates a separate Customer Data Processing Addendum that governs how personal data processed through Miro boards and services is handled under data protection law. Business customers acting as data controllers under GDPR should review the CDPA in conjunction with the Subprocessors List.
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