Is Apollo GDPR Compliant?

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Published on Jul 8, 2025 by Iron Brands

TL;DR

Yes — Apollo is GDPR-compliant. It provides a comprehensive Data Processing Addendum with Standard Contractual Clauses, operates as both processor and controller, holds key security certifications (ISO 27001, SOC 2), supports data subject rights, offers strong encryption, subprocessor oversight, and robust incident response.

  1. Apollo’s GDPR Compliance Framework
  2. Platform Highlights
  3. Who Should Care?
  4. Community Feedback
  5. Notable Resources
  6. General Caveat
  7. Final Thoughts
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Apollo’s GDPR Compliance Framework

1. Data Processing Addendum (DPA) & SCCs

Apollo’s DPA, updated May 20, 2024, includes EU Standard Contractual Clauses and clarifies its role as a data processor for Customer Personal Data and controller for its own account/metadata.

2. Processor & Controller Roles

  • As a processor, Apollo handles Customer Personal Data strictly per customer instructions.
  • As a controller, it manages platform metadata and contributor data. They clearly delineate responsibilities in the DPA.

3. Certifications & Security Controls

Apollo holds ISO 27001 and SOC 2 Type II certifications. Data is encrypted both in transit and at rest. Infrastructure includes intrusion detection, VPC security, penetration testing, quarterly audits, and strict access controls.

4. Subprocessor Oversight

Apollo discloses subprocessors on its trust portal and provides notice at least 30 days before new additions. Customers can object; unresolved objections allow cancellation with pro-rata refunds. Subprocessors are contractually bound to the same data protection standards.

5. Data Subject Rights & Privacy Tools

Users can request data access, correction, deletion, or portability via Apollo’s Privacy Center or privacy team (privacy@apollo.io). The platform supports opt-out, DSAR handling, and privacy configuration settings for prospecting workflows.

6. Data Breach Response

Apollo promises notification within 72 hours in case of a security incident. Customers are offered assistance, cooperation in investigations, and appropriate remediation.

7. Privacy by Design & Risk Management

Apollo claims ongoing GDPR compliance since before May 2018. Its tools include privacy-impact features, schema contracts in GraphOS for field-level access controls, and continuous infrastructure monitoring for compliance.

Data transfers to the U.S. are secured via the EU-U.S. Data Privacy Framework and SCCs. Apollo commits to lawful mechanisms before data transfer where required.

Platform Highlights

  • GraphOS & GraphQL: Offers field-level schema contracts and authentication, enabling GDPR-aligned data minimization and access segregation.
  • Apollo.io Platform: Provides privacy toggles in settings and opt-out options for enriched data used in sales/marketing toolsets.

Who Should Care?

  • App developers & backend teams using Apollo GraphQL/GraphOS with EU user data.
  • Sales and marketing teams relying on Apollo.io’s data enrichment—need privacy options, consent, and opt-out mechanisms.
  • Privacy and compliance teams conducting vendor risk assessments—DPA, audits, certifications, and breach MTTR are key factors.

Community Feedback

While Reddit posts express privacy concerns over data enrichment practices, these relate to data sourcing rather than GDPR structure. Apollo enables opt-out and user controls.

Notable Resources

  1. Apollo DPA (May 2024) [www.apollo.io]
  2. Apollo Trust Center: ISO/SOC certifications, encryption, subprocessor tracking (www.apollo.io)
  3. GraphOS privacy controls: Schema contracts, role-based access in supergraphs (www.apollographql.com)
  4. Apollo Privacy Center: Self-service DSAR, opt-out functionality (www.apollo.io)

General Caveat

This overview reflects Apollo’s publicly stated GDPR compliance. True compliance depends on your implementation—tool configuration, user interactions, and internal data policies. Always consult your legal or privacy advisor.

Final Thoughts

Apollo provides a strong GDPR compliance foundation: certified security, transparent subprocessors, explicit legal agreements, data subject control mechanisms, and field-level access configurations. However, as with any data-processing vendor, compliance is shared—you must configure controls properly and respect user rights through workflows and consent handling.

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