TL;DR
Heroku is a cloud platform (PaaS) used to deploy and host applications, and can be GDPR-compliant if you configure it correctly and follow necessary privacy practices.
- How to maintain GDPR compliance with Heroku
- Do I need a cookie banner with Heroku?
- What Heroku’s Privacy Policy / GDPR documentation says
- About Heroku
How to maintain GDPR compliance with Heroku
With Heroku, the data processed depends on how your apps interact with end users and what add-ons or integrations you use. Heroku processes application data, logs, and, depending on your configuration, can process personal data of your users.
To ensure GDPR compliance on Heroku, follow these essential steps:
Request user consent (if applicable)
Heroku itself does not set cookies on your end users by default—this depends on how your app is built. If your Heroku-hosted app uses cookies for analytics, marketing, or similar purposes, you must obtain valid GDPR-compliant user consent.
This means implementing a cookie consent/opt-in banner on your site. Tools like Cookiebot or Termly can help with this if you don’t have a custom solution.
Provide option to opt-out
Make sure users have a way to opt out of non-essential cookies and tracking, if these are implemented in your app. This is a core GDPR principle and is usually managed within your privacy preferences or a CMP tool.
Add Heroku to the list of data processors
Update your privacy policy to include Heroku (owned by Salesforce) as a data processor or sub-processor. Mention the types of data that may be processed via Heroku as part of your services, per GDPR requirements.
Here’s an example of how to mention Heroku in your privacy policy:
We use Heroku, a cloud platform service provided by Salesforce.com, Inc., for application hosting and data processing. Data processed may include [specify, e.g., IP address, user data, application logs], as required for our service delivery.
Monitor data security
Under GDPR Article 33, you must notify users of a personal data breach where applicable. Monitor Heroku’s status and any incident reports to ensure you can react quickly to potential breaches.
To enhance account security:
- Enable Multi-Factor Authentication (MFA) for Heroku accounts.
- Regularly review app permissions and access controls.
- Keep dependencies and software up to date.
Do I need a cookie banner with Heroku?
Only if your application sets cookies for tracking, analytics, or marketing purposes. Heroku itself does not inject cookies for end users; if you are running a web app through Heroku and your application uses cookies, a consent banner is required under GDPR.
What Heroku’s Privacy Policy / GDPR documentation says
Heroku’s privacy and data protection practices are covered by its parent company, Salesforce. Here are the key points:
Policy Scope:
- Applies to the use of Heroku’s platform and related Salesforce services by customers, admin users, and end users.
- Does not cover data collection by customer applications built on Heroku (customers are responsible for their own privacy practices).
Data Collection:
Heroku collects personal data relating to account administration (e.g. name, email), usage data, application logs, and metadata, as required to operate the platform and provide technical support.
Use of Information:
Data is used to deliver, maintain, and improve the Heroku platform; provide support; bill users; improve security; and comply with legal obligations. Salesforce does not use end-user data from customer applications for its own marketing purposes.
Data Sharing:
Personal data may be shared:
- Among Salesforce group companies (including Heroku)
- With contracted subprocessors and vendors
- As required by law or in response to legal process All third-party vendors and subprocessors are subject to data processing agreements and security requirements.
EU, UK, and Swiss Residents:
Salesforce provides detailed data processing addenda (DPA) and participates in frameworks such as the EU-U.S. Data Privacy Framework. Heroku customers can sign a DPA for GDPR compliance, outlining roles (usually Salesforce/Heroku as processor, customer as controller) and safeguards under EU data protection law. Data can be stored in the U.S., with contractual protections (e.g., SCCs) in place.
International Data Transfers:
Heroku (Salesforce) ensures adequate safeguards for international transfers, including Standard Contractual Clauses (SCCs) and adherence to international privacy frameworks.
Data Subject Rights:
Data subjects may request access, correction, deletion, or restriction of processing. Salesforce outlines procedures for exercising these rights and responding to relevant requests.
Data Security and Retention:
Heroku employs strong physical, technical, and administrative security measures. Data is retained only as long as necessary for providing the service or to fulfill legal obligations.
Dispute Resolution and Updates:
Salesforce details processes for handling privacy complaints and makes regular updates to its privacy policy, with notice for significant changes.
Contact Information:
Contact details for data privacy officers and representatives in relevant jurisdictions are provided for privacy inquiries.
California Residents:
Additional rights are granted under the CCPA, including the right to access, delete, and opt-out of the sale or sharing of personal data.
Points to Highlight:
- Commitment to Privacy: Heroku (Salesforce) prioritizes the privacy and security of client and end-user data.
- Global Compliance: Supports GDPR, CCPA, and other privacy laws, with clear mechanisms for international data transfers.
- Customer Responsibility: You, as the app operator, are responsible for ensuring your app’s privacy compliance and for data processed through Heroku.
- Security: Strong security protocols and incident response processes are in place.
About Heroku
Heroku is a leading cloud application platform (Platform as a Service, or PaaS) that allows developers to quickly deploy, manage, and scale modern applications. Founded in 2007 and acquired by Salesforce in 2010, Heroku’s mission is to streamline app deployment and simplify operations for teams of any size.
Key Features:
- Easy App Deployment: Developers can deploy apps with a simple ‘git push’, eliminating complexities of server provisioning and management.
- Scalability: Heroku allows dynamic scaling of applications—instantly adjust how many resources your app has to meet demand.
- Add-ons Ecosystem: Integrate third-party services for databases, caching, monitoring, and more via an extensive add-ons marketplace.
- Integrated CI/CD: Heroku pipelines and GitHub integrations support robust continuous integration and deployment workflows.
- Automatic App Monitoring: Built-in logging and performance analytics help developers monitor app health in real time.
- Managed Runtime: Heroku manages patching, runtime upgrades, and OS-level security, letting developers focus purely on code.
- Data Services: Offers managed databases (e.g., Heroku Postgres, Redis) with automated backups and high availability options.
Heroku continues to innovate, making it easy for developers and businesses to build, run, and enhance modern applications with a focus on developer experience, reliability, and security.