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Data privacy and GDPR on CUZY Hosting

Your HumHub community holds your members' personal data. Here is who is responsible for it, which privacy laws apply, where it is stored, who can read it and how you take it back, in plain words for data-protection officers and decision makers.

New to HumHub? What it is, who it is for and what you can do with it.

Last updated: 20 October 2026. This page explains our commitments; the binding texts are the Data Processing Agreement (section 10 of the terms of sale) and the privacy policy.

In short

GDPR processor agreement

Accepted with every subscription, versioned, signed copy on request.

Beyond the EU

The same agreement covers the UK, Switzerland, Canada and Quebec, California and the other US states.

Your region

Germany (EU), the USA or Singapore (APAC): your community and its backups stay there.

100% open source

Every line of code your community runs can be read and downloaded through read-only SFTP.

Nobody reads your content

No selling, no advertising, no AI, no staff access without your permission.

Free to leave

Export everything at any time; stop early and the remaining days are refunded pro rata.

Who is responsible for what

  • You are the controller of the personal data in your community: you decide what it is for, who joins and what is collected.
  • CUZY is your processor: it hosts, backs up, updates, monitors and supports the community on your documented instructions only, and uses the data for no purpose of its own.
  • For your customer account and billing, CUZY is the controller, as the privacy policy describes.
  • What CUZY provides: a host that meets the GDPR's requirements, HumHub's privacy tools (export, erasure, consent) and templates for your legal pages, ready to adapt.
  • What stays with you: the templates are a starting point, not legal advice. Have a lawyer review and adapt your legal pages before you publish them; check whether your country requires you to register with or notify its data protection authority; and name a contact person for privacy (a data protection officer, or a representative in the EU when you are outside it) where the law requires one. The administrator handbook and the GDPR checklist go through the rest.

The privacy laws we cover

CUZY's side of the hosting is built for the GDPR, and the Data Processing Agreement applies the same commitments wherever an equivalent law governs your data. Your own obligations under these laws are yours to check, ideally with a lawyer.

Where, and which lawWhat the agreement provides
European Union and EEA: GDPRThe processor contract of Article 28; transfers under Chapter V
United Kingdom: UK GDPR and Data Protection Act 2018The same terms, the Information Commissioner as authority, the UK transfer addendum
Switzerland: Federal Act on Data Protection (FADP)The contract its Article 9 requires; transfers under the clauses the Swiss Commissioner recognizes
Canada: PIPEDA and provincial laws, Quebec's Law 25 includedA written contract giving comparable protection, notice of any breach, the information Quebec's transfer assessment needs
California and other US states: CCPA and comparable state lawsCUZY as your service provider: one business purpose, no selling or sharing, no combining with other data

Under every one of them CUZY follows your instructions, applies the published security measures, binds its sub-processors by written contracts, notifies you of a breach within 72 hours at the latest, helps you answer your members' requests, opens its practices to audit and deletes the data at the end. Another law applies to you? Ask us.

Where your data is

  • You choose the region when the community is created: Germany (EU), the default, the USA or Singapore (APAC). The community and its backups stay there, encrypted backups of Singapore communities excepted (stored in the United States).
  • Organizations whose members are in the European Union choose Germany (EU): hosting and backups then never leave the EU.
  • Any transfer outside the region rests on an adequacy decision, the European Commission's Standard Contractual Clauses or the EU-US Data Privacy Framework, with encryption as a supplementary measure.

Sub-processors

Hetzner (servers, in your region), Backblaze (encrypted backups, in your region), Cloudflare (DNS), SMTP2GO (community emails), Infomaniak (our support mailboxes, Switzerland), and on Business HumHub GmbH with Google Firebase (push notifications), Google (address geocoding for the map modules) and WhatsApp (the support channel). Each is bound by a written contract with at least the protection of our agreement, and CUZY stays liable for them. You are told at least 30 days before one is added or replaced, and you may then leave with the unused period refunded. The binding list with locations and transfer safeguards is in the Data Processing Agreement and the privacy policy.

100% open source, nothing hidden

  • Every piece of code CUZY installs for your community is open source: HumHub (AGPL), the CUZY modules (AGPL, or the CUZY commercial license for marketplace updates) and the CUZY agent that connects the community to our platform. Modules you add from the marketplace yourself follow their publisher's license.
  • You can check it yourself: Team and Business include a read-only SFTP access to the whole installation. Browse and download all the code and files, review them, or have them reviewed.
  • There is no hidden layer that only runs on our servers, and no tracker: the agent reports counts and technical status, never your members' content.

Who can read your data

  • Your members and administrators, according to the permissions you set.
  • CUZY staff only for support you ask for, an incident or a legal obligation, bound to confidentiality. A support login uses a one-time link that is recorded in your community's audit log; you can switch support access off.
  • CUZY never sells or shares your data, uses no advertising, and no AI service processes it.
  • Data goes to a public authority only on a binding legal order: CUZY checks it, contests it when there are grounds, discloses the minimum and tells you first unless the law forbids it.

Your data, your exit

  • Export at any time: subscribers download a complete copy of the database and files from their customer account, once a day, and any backup can be downloaded or restored from there too.
  • Run it anywhere: the export and the code rebuild the same community on your own server or with another provider, HumHub's own hosting included.
  • Stop when you want: ask us to end your subscription and the remaining days are refunded pro rata (terms of service, section 10).
  • Deletion: after the end, the community is archived about 30 days later and deleted with its backups at the latest 6 months after the end, earlier if you ask; written confirmation on request. Details: backup and retention schedule.

If something goes wrong

A personal data breach affecting your community is notified to you without undue delay and within 72 hours at the latest, with what is known and what was done, so you can inform your authority and your members. For the data CUZY controls, CUZY notifies the Irish Data Protection Commission when required.

Data privacy questions

Does CUZY Hosting make our community GDPR compliant?

CUZY gives you what the GDPR asks of a host: a Data Processing Agreement (Article 28) accepted with every subscription, the data kept in the region you choose, the published security measures, HumHub's own privacy tools (export, erasure, consent) and templates for your legal pages. That does not make your community compliant on its own: you are the controller. Have a lawyer review and adapt the legal pages before you publish them, check whether your country requires you to register with or notify its data protection authority, and name a contact person for privacy (a data protection officer, or a representative in the EU when you are outside it) where the law requires one. The administrator handbook lists the rest of your part.

Does the agreement cover the UK, Switzerland, Canada and California?

Yes. The Data Processing Agreement covers the UK GDPR, the Swiss Federal Act on Data Protection, Canada's PIPEDA with Quebec's Law 25, and the California Consumer Privacy Act with the comparable US state laws, under which CUZY is your service provider.

Can we check the code that runs our community?

Yes. HumHub, its modules and the CUZY agent are open source. On Team and Business, a read-only SFTP access lets you browse and download the whole installation: 100% of the code your community runs, and its files.

Is our data used to train AI or sold?

No. CUZY never sells or shares your data, uses it for no purpose of its own, and no AI service processes it.

Need the agreement signed, a filled-in questionnaire or the assessment of a transfer? Contact us; we answer data-protection officers directly. Privacy questions: contact@cuzy.app.

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