Free
FreeTrains on your data unless you switch it off
EU hosting not documented · no DPA
Price: Free
30 tools, 6 of which don't train on your data, keep it in the EU and include a DPA. From the vendors' own pages.
Checked on
Each tool's business plan where there is one, against your five rules. 10 tools without a page of their own open their answers with “Show answers”.
The five marks, in order: No AI training · EU hosting · DPA · Sub-processors listed · DPF or EU vendor. ✓ meets it, ✕ doesn't, – partly, ? not stated.
S1 pay as you go · See details
Doesn't train on your dataEU hosting available · DPA in the terms
✓✓✓?✓
Pro Team · €24.99 / user / mo
Doesn't train on your dataLimited EU hosting · DPA on request
✓–✓✕✓
Professional · $65 / user / mo
Trains on your data unless you switch it offEU hosting available · DPA on request
✕✓✓✓✓
Team · $64 / user / mo
Doesn't say whether it trains on your dataEU hosting not documented · DPA in the terms
??✓✕✓
DPA in the terms.
Yes. A Data Processing Agreement is Schedule 1 of Fyxer's Terms of Use, with Fyxer AI Limited as processor
Source: app.fyxer.com · Checked on
UK (EU adequacy).
Not applicable (UK vendor, Fyxer AI Limited; the DPF covers US organisations). Search 'Fyxer' returned no results
Source: dataprivacyframework.gov · Checked on
SOC 2 Type II and ISO 27001 (vendor statement); HIPAA and GDPR compliance claimed
Source: fyxer.com · Checked on
Google Workspace Business Standard · See details
Doesn't train on your dataEU hosting available · DPA in the terms
✓✓✓✓✓
Business Standard · €13.60 / user / mo
Doesn't train on your dataEU hosting available · DPA in the terms
✓✓✓✓✓
Pro (team, bought online) (+1) · €12 / mo
Trains on your data unless you switch it offEU hosting not documented · DPA in the terms
✕?✓✓✓
Plus · $45 / user / mo
Trains on your data unless you switch it offEU hosting not documented · DPA in the terms
✕?✓✓✓
Growth · See details
Doesn't train on your dataData in the EU by default · DPA in the terms
✓✓✓✓✕
Basic · Quote only
Says it doesn't train on your dataEU hosting not documented · DPA not stated
✓???✕
Says it doesn't train on your data.
No, per the pricing page only: data is never used to train public AI models. The terms of service let Hypotenuse use content data to improve its services; neither policy mentions training.
“Your data remains your own and is used only to power your workflows in Hypotenuse AI. It is never shared with third parties or used to train public AI models.”Source: hypotenuse.ai · Checked on
United States: data from users outside the US is transferred to and processed in the US.
“If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.”Source: hypotenuse.ai · Checked on
Not listed.
No listing found for search term 'Hypotenuse'
Source: dataprivacyframework.gov · Checked on
No fixed period: personal data is kept as long as necessary for the policy's purposes and legal duties; deletion by account request.
“We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.”Source: hypotenuse.ai · Checked on
1 named: SOC 2 Type II (security, availability, confidentiality), stated on the pricing page only.
“Hypotenuse AI is SOC 2 Type II compliant, with controls covering security, availability, and confidentiality.”Source: hypotenuse.ai · Checked on
Starter bundle · $94 / mo
Doesn't say whether it trains on your dataEU hosting not documented · DPA in the terms
??✓✕✕
Doesn't say whether it trains on your data.
Not stated for Instantly; terms disclaim responsibility for what its third-party AI providers do with your inputs, 'including for use in their model training'
“Instantly is not responsible for the Third-Party Services' handling of your Inputs or Outputs, including for use in their model training.”Source: instantly.ai · Checked on
United States: Instantly generally stores the information used in its services in the United States
“We generally store the Information used in our Services in the United States.”Source: instantly.ai · Checked on
DPA in the terms.
Yes: the Data Processing Addendum is incorporated into the Terms whenever Instantly processes personal data covered by data protection law; published at instantly.ai/dpa
“Subscriber agrees that the terms and conditions of the Data Processing Addendum, applies and is hereby incorporated into this Agreement.”Source: instantly.ai · Checked on
Not listed.
No listing found for search term 'Foo Monk', 'Instantly'
Source: dataprivacyframework.gov · Checked on
After termination Instantly returns, deletes or anonymises personal data within 30 days (legal-retention exceptions); the terms say Instantly may delete other account data under its retention policies
“Within 30 days after the expiration or earlier termination of the Agreement, Service Provider shall, to the fullest extent technically possible in the circumstances”Source: instantly.ai · Checked on
Team · €56.90 / user / yr
Doesn't train on your dataData in the EU by default · DPA on request
✓✓✓✓✓
Team Plan · $89 / user / mo
Doesn't say whether it trains on your dataEU hosting not documented · DPA not stated
???✕✕
Doesn't say whether it trains on your data.
Not stated for Lavender's own models; the privacy policy says raw email content sent to the LLM is not used to train it or to improve the AI model externally
“The raw email content is not used for the training of the LLM or for improving the AI model externally”Source: lavender.ai · Checked on
Not public.
No public list shown; the privacy policy says you may ask for a list of third parties including LLM providers, and lavender.ai/dpa offers email notice of sub-processor changes 10 days ahead
“You may ask us for a list of third-parties with whom we share your personal information (including LLM service providers)”Source: lavender.ai · Checked on
Not listed.
No listing found for search term 'Sorter'
Source: dataprivacyframework.gov · Checked on
The Terms say Lavender does not retain copies of your emails; account data can be deleted in the dashboard settings. No fixed retention period is stated in the Terms.
“Lavender does not retain copies of your emails”Source: lavender.ai · Checked on
SOC 2 (type not stated) and GDPR compliance, claimed on the marketing site only; no report or audit page
“We are SOC2-certified and GDPR-compliant.”Source: lavender.ai · Checked on
Email · $55 / mo
Doesn't say whether it trains on your dataEU hosting available · DPA on request
?✓✓?✓
European Union: lemlist's host servers are located exclusively in the EU (DPA: hosting by OVH and backups by Scaleway, France). Some processing tools may transfer data outside the EU
“All servers are located in the EU in order to be fully GDPR compliant.”Source: docdroid.net · Checked on
EU hosting available.
Yes, by default: all lemlist servers are in the EU. Optional AI providers (OpenAI, Anthropic, Google Gemini, Perplexity) and Intercom support are USA-based with SCCs
“All servers are located in the EU in order to be fully GDPR compliant.”Source: docdroid.net · Checked on
DPA on request.
Yes: the DPA is incorporated into the Terms and accepted by signing them; an e-signed copy is sent on request
“These terms and conditions incorporate the Data Processing Agreement (DPA). By signing these terms and conditions, the Customer accepts the DPA.”Source: lemlist.com · Checked on
See details.
Listed in Annex I.C of the downloadable standard DPA (not a separate web page): 13 entries, 13 companies (5 standard, 5 optional AI/voice, 3 for Lead Finder). AI providers: OpenAI, Anthropic, Google Gemini, Perplexity AI, ElevenLabs
“Some of the Service’s features and integrations require the use of additional Sub-Processors.”Source: docdroid.net · Checked on
EU or Swiss vendor.
Not applicable (EU-based vendor, lempire SAS, Paris, France)
“a company registered under France law number 823 475082 with the Paris Trade & Companies Register”Source: lemlist.com · Checked on
Account and usage personal data: no longer than 3 years after the account is closed; at termination lemlist destroys or returns the customer's personal data at the customer's choice (DPA 13.2); Confidential Information destroyed within 30 days on a reasonable-efforts basis. No period stated for AI prompts
“The time needed to provide to you our services, and in no event no longer than 3 years after closing your account”Source: lemlist.com · Checked on
SOC 2 Type II (1 certification); report shown on the trust centre
“Compliance SOC2 type 2 report View all”Source: trust.lemlist.com · Checked on
Explorer · $149 / mo
Trains on your data unless you switch it offEU hosting not documented · DPA on request
✕?✓✓✓
Productive · $24 / user / mo
Says it doesn't train on your dataEU hosting not documented · DPA on request
✓?✓✓✕
Microsoft 365 Business Standard with Copilot · See details
Doesn't train on your dataEU hosting available · DPA in the terms
✓✓✓–✓
Amplify Essentials · Quote only
Trains on your data, with no documented way to stop itEU hosting available · DPA in the terms
✕✓✓✓✓
Software UI/UX · See details
Trains on your data, with no documented way to stop itEU hosting not documented · DPA on request
✕?✓✓✓
Workspace Premium · $19.99 / user / mo
Doesn't train on your dataNo EU hosting · DPA on request
✓✕✓✓✓
Premium · €10.00 / user / mo
Doesn't train on your dataEU hosting not documented · DPA not stated
✓???✓
Pro · $49 / mo
Doesn't say whether it trains on your dataEU hosting not documented · DPA not stated
????✕
United States: servers and central databases are located there.
“please be mindful that such information may be transferred, stored or processed in the United States where our servers or central databases are located.”Source: rytr.me · Checked on
Not listed.
No listing found for search term 'Rytr'
Source: dataprivacyframework.gov · Checked on
No fixed period: kept as long as necessary for the policy's purposes and legal duties; you can request deletion in account settings. Teams page mentions 'retention choices' without detail.
“The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.”Source: rytr.me · Checked on
Cadence, quote-based · See details
Doesn't say whether it trains on your dataEU hosting not documented · DPA in the terms
??✓–✓
The Salesloft platform is hosted on AWS and Google Cloud in the US and the EU; the Drift product runs on AWS in the US. Which region a given customer gets is not stated.
“The Salesloft platform is hosted at Amazon and Google data centers, running on Amazon Web Service (AWS) and Google Cloud Platform (GCP) technology, in the US and the EU.”Source: salesloft.com · Checked on
DPA in the terms.
Yes. The MSA says each party agrees to comply with the DPA, which is incorporated into the agreement; the DPA includes Standard Contractual Clauses.
“Each party agrees to comply with the DPA, which is incorporated into this Agreement.”Source: salesloft.com · Checked on
Behind sign-in.
Partly public: Clari's list at https://www.salesloft.com/legal/clari-subprocessors has 22 entries incl. AWS, Google Cloud, Microsoft Azure (AI analysis), 1Mind and Ada (AI). The Salesloft/Drift list is only in the trust portal (needs browser).
“Microsoft Azure USA Service provider Artificial Intelligence analysis and insights”Source: salesloft.com · Checked on
On the list.
Active (Salesloft; EU-US DPF, Swiss-US DPF, UK Extension)
Source: dataprivacyframework.gov · Checked on
On request within 90 days after the subscription ends, Salesloft returns or deletes personal data; after 90 days it has no obligation to keep it. No in-product retention setting described.
“Upon request made by Customer within ninety (90) days following the expiration or termination of the Subscription Term, Salesloft will return or delete the Personal Data”Source: salesloft.com · Checked on
3 named on the security page: SOC 2 Type 2, ISO 27001, ISO 27701. The trust centre also shows a CSA badge plus GDPR, CCPA and DPF badges.
“The Salesloft and Drift platform services undergo SOC 2 Type 2 examinations”Source: salesloft.com · Checked on
Business · $30 / user / mo
Doesn't say whether it trains on your dataEU hosting not documented · DPA not stated
???✕✕
Doesn't say whether it trains on your data.
Not stated for Shortwave itself; it says your data will never be used to train third-party LLMs
“Your data will never be used to train third-party LLMs.”Source: shortwave.com · Checked on
United States: Shortwave stores all data in Google Cloud and transfers it to servers in the US
“your Personal Data will be transferred from your location to our facilities and servers in the United States.”Source: shortwave.com · Checked on
Not public.
No separate list; the security page names 4 providers: Google Cloud, OpenAI, Anthropic, Pinecone
“Currently, besides Google Cloud, we only use OpenAI, Anthropic, and Pinecone.”Source: shortwave.com · Checked on
Not listed.
No listing found for search term 'Shortwave'
Source: dataprivacyframework.gov · Checked on
No fixed period: personal data is kept as long as reasonably necessary; you can delete your account and all associated data
“We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy”Source: shortwave.com · Checked on
CASA Tier 2 (annual third-party security audit). For SOC 2 Type II or GDPR compliance the security page only says to contact support; no report or certificate is published
“To maintain this verification, Shortwave undergoes an annual security audit.”Source: shortwave.com · Checked on
Adapt · $1,200 / yr
Trains on your data in partEU hosting available · DPA on request
–✓✓✓✕
Pro · $94 / mo
Doesn't say whether it trains on your dataEU hosting not documented · DPA in the terms
??✓✕✕
Amazon Web Services, Sydney region (Australia). Other User Data may also be processed in Singapore, India, Japan, US, Canada, Germany, Ireland and Sweden.
“securely storing data in a certified data repository, specifically one located in the Sydney Region of Amazon Web Services;”Source: smartlead.ai · Checked on
DPA in the terms.
Yes. The DPA is part of the Terms and is accepted automatically when the user buys a subscription; no signature needed.
“THIS DPA IS ACCEPTED BY THE USER BY VIRTUE OF THE USER ACCEPTING THE TERMS UPON BUYING A SUBCRIPTION FROM SMARTLEAD. THIS DPA CONSTITUTES PART OF THE TERMS.”Source: smartlead.ai · Checked on
Not public.
No public list. DPA Annex III names one sub-processor (AWS for hosting) and says the remainder is available on request. 1 entry listed; no AI or model providers named.
“AWS for hosting Remainder available on request”Source: smartlead.ai · Checked on
Not listed.
No listing found for search term 'Smartlead', '521 Products'
Source: dataprivacyframework.gov · Checked on
After deactivation, personal data is deleted within 90 days once invoices are paid (backups excepted). The terms allow removal of user data one month after termination. No customer-set retention period found.
“Upon deactivation of the Service, all Personal Data shall be deleted within 90 days subject to full User payment of any outstanding invoices”Source: smartlead.ai · Checked on
Pro · €22 / user / mo
Doesn't train on your dataEU hosting not documented · DPA in the terms
✓?✓✕✓
Business · $33 / user / mo
Trains on your data unless you switch it offEU hosting not documented · DPA on request
✕?✓✓✓
Unlimited · $6.99 / user / mo
Trains on your data in partEU hosting not documented · DPA not stated
–???✕
Trains on your data in part.
Yes, in part: the Business privacy policy says that in certain cases anonymised data is used to train its AI algorithm, and the terms of use license your content to improve the algorithms behind Wordtune. No stop setting is described.
“In certain cases, we may or will anonymize or de-identify your Personal Data and further use it (for internal and external purposes, including, without limitation, to improve the services, to train our AI algorithm, for research purposes”Source: wordtune.com · Checked on
United States: the privacy policy says personal data is processed and stored on AI21's servers there.
“This includes processing and storing your Personal Data in our facilities and servers in the United States.”Source: wordtune.com · Checked on
DPA not stated.
Business accounts: request a data processing agreement through the sales contact form. Not stated for the Unlimited plan.
“To the extent that Client needs to execute a data processing agreement,please request it at https://www.wordtune.com/business/contact-sales.”Source: wordtune.com · Checked on
Not listed.
No listing found for search term 'AI21 Labs'
Source: dataprivacyframework.gov · Checked on
Kept until AI21 deletes it or you send a valid deletion request (email privacy@wordtune.com); no fixed period; longer where law or disputes require.
“Your Personal Data will be stored until we proactively delete it or you send a valid deletion request.”Source: wordtune.com · Checked on
1 named: SOC 2 (stated as 'SOC2 compliant' in the Business privacy policy; no report type or ISO certification named).
“We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. Wordtune is SOC2 compliant.”Source: wordtune.com · Checked on
Starter · See details
Doesn't train on your dataEU hosting not documented · DPA on request
✓?✓✓✓
Trains on your data unless you switch it off
EU hosting not documented · no DPA
Price: Free
Trains on your data unless you switch it off
EU hosting not documented · DPA in the terms
Price: €12 / mo
No tool is GDPR compliant on its own: that depends on how your business uses it. This page shows the vendor's side, from its own pages. It is not legal advice.
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