Provision record
Miro · Miro Terms of Service · View original document ↗

Data Processing Addendum and Subprocessor Disclosure

Medium severity Medium confidence Explicit document language Common · 290 of 352 platforms
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Document Record

What it is

How Miro handles personal data on behalf of business customers is governed by a separate Data Processing Addendum, and Miro discloses the third parties it uses to process data in a separate subprocessors list that can change over time.

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)

For business customers under GDPR or other data protection laws, the DPA is the operative legal instrument defining Miro's obligations as a data processor, and the subprocessors list determines which third parties may access the personal data you upload to Miro.

Interpretive note: The adequacy of the DPA for specific regulatory frameworks such as GDPR Article 28 or CCPA service provider requirements depends on the full content of that addendum, which is a separate document and was not available for review in this analysis.

Consumer impact (what this means for users)

If your organization is subject to GDPR, CCPA, or similar data protection law, Miro's Data Processing Addendum governs its obligations as a processor of your customers' and employees' personal data, and changes to the subprocessors list may affect whether your data transfer and vendor management obligations remain satisfied.

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.
  • Delete Your Data
    Review the Customer Data Processing Addendum at miro.com/legal/customer-data-processing-addendum/ and confirm it has been properly executed for your organization's account. Separately review the subprocessors list at miro.com/legal/subprocessors-list/ and set up alerts for changes.

How other platforms handle this

Square Medium

to request that your data be transferred to a third party (data portability)

Google Cloud Medium

Your organization may allow you to access and export your data in order to back it up or transfer it to a service outside of Google.

Roblox Medium

Further, you may take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data prot...

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
Miro's processing of personal data on behalf of customers is governed by the Customer Data Processing Addendum, which is incorporated into these Terms by reference. A current list of subprocessors used by Miro is available at miro.com/legal/subprocessors-list/ and is updated from time to time.

Excerpt from Miro's Terms of Service

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

REGULATORY LANDSCAPE: The Customer Data Processing Addendum is the primary instrument for GDPR Article 28 compliance in Miro's B2B relationships.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

CCPA/CPRA
California, USA
Colorado AI Act
US-CO
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
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 Terms of Service
Entity
Miro
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-009406
Document ID
CA-D-00555
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
06308b39e82e22166438c2239b2aeedf0da011212c7bb09dfc2625cb5127f89b
Analysis generated
May 10, 2026 18:07 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Miro
Document: Miro Terms of Service
Record ID: CA-P-009406
Captured: 2026-05-10 18:07:31 UTC
SHA-256: 06308b39e82e2216…
URL: https://conductatlas.com/platform/miro/miro-terms-of-service/provision/CA-P-009406/data-processing-addendum-and-subprocessor-disclosure/
Accessed: Sept. 23, 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 Data Processing Addendum and Subprocessor Disclosure clause do?

For business customers under GDPR or other data protection laws, the DPA is the operative legal instrument defining Miro's obligations as a data processor, and the subprocessors list determines which third parties may access the personal data you upload to Miro.

How does this clause affect you?

If your organization is subject to GDPR, CCPA, or similar data protection law, Miro's Data Processing Addendum governs its obligations as a processor of your customers' and employees' personal data, and changes to the subprocessors list may affect whether your data transfer and vendor management obligations remain satisfied.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.

Is ConductAtlas affiliated with Miro?

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