OpenClaw hosting in the EU: GDPR, data residency and who actually offers it

“OpenClaw hosting in the EU” is asked for one of two reasons. A reader in Europe wants the agent’s notes, memory and chat history on a server under EU law. Or a company has to show a processing agreement for every service that touches personal data, and an agent that reads a mailbox touches a lot of it. The sentence that sells hosting, “GDPR-compliant servers in Germany”, answers neither question on its own: the regulation is about who is responsible for the data and what paper covers each hop, not about the postcode of the rack.

The first half of this page is the four things the GDPR asks of the company that runs an agent for you, with the articles linked. The second half is a table: every managed OpenClaw host from Managed OpenClaw hosting compared, plus the four European VPS providers the AI assistants name when asked this question, read on their own privacy, terms and DPA pages on 20 October 2026, with “not stated” wherever a page is silent. Aplite is one row in that table, and this page is written by the company behind it.

What the GDPR asks of an agent host

1. You are the controller, the host is a processor

The GDPR assigns roles, not locations. The party that decides what is processed and why is the controller; the party that processes “on behalf of the controller” is the processor (Art. 4(7) and 4(8)). When you point an OpenClaw agent at your notes, your calendar or a mailbox, you are the controller of whatever personal data is in them, and the company running the gateway for you is your processor. That is the relationship Art. 28(1) regulates: a controller “shall use only processors providing sufficient guarantees” of appropriate technical and organisational measures.

Whether the regulation applies to you at all is decided by Art. 3: by where you are established and whose data it is, “regardless of whether the processing takes place in the Union or not”. An EU server does not bring you under the GDPR, and a US server does not take you out of it.

What the processor holds is not small. An OpenClaw instance keeps its sessions and transcripts in a per-agent SQLite database, its memory as markdown files in the workspace, its config and credentials in ~/.openclaw. Every one of those files sits on the host’s disk, which is why the server’s location is a real question, just not the only one.

2. A written processing agreement

Art. 28(3) requires that processing by a processor “shall be governed by a contract or other legal act” that sets out the subject-matter and duration, and binds the processor to act only on documented instructions, keep its staff to confidentiality, take the security measures of Art. 32, help with data-subject requests, delete or return the data at the end, and allow audits. This is the data processing agreement, or DPA; German sites call it AVV. A badge that says “GDPR compliant” is a claim; the DPA is the document. The table below records whether a host publishes one, offers one on request, or says nothing.

3. Sub-processors, and the list of them

A host rarely does everything itself. Art. 28(2) says it “shall not engage another processor without prior specific or general written authorisation” and must tell you about changes so you can object; Art. 28(4) passes the same obligations down to each of those other processors and keeps the first one “fully liable to the controller”. For an OpenClaw host the list is predictable: the data centre, the CDN in front of the site, the mail and payment services, and the one that matters most for an agent, the model provider. A host that cannot name its sub-processors cannot sign Art. 28 honestly, which is why a published list is worth more than any badge.

4. Where the prompts go

The model call leaves the server. Every message you send, every note the agent reads to answer it and every tool result go to whichever company serves the model, and the frontier models in October 2026 are served from the United States. That makes the model call a transfer under Chapter V: Art. 44 allows it “only if” the chapter’s conditions are met, through an adequacy decision under Art. 45, for the US the EU-US Data Privacy Framework adopted on 10 July 2023 and limited to companies certified under it, or through Art. 46 safeguards, in practice the Commission’s standard contractual clauses.

Hosts route that call in one of three ways, and the table’s last column records which.

• Your own key. The instance calls the provider directly; the host says it is not in the path. The provider is then your processor under its own API terms, and the host’s DPA does not cover it.
• The host’s account, usually through a router. The host buys model usage and resells it as credits; the router and the providers behind it are the host’s sub-processors. The common router is OpenRouter, whose documentation says that “each AI provider on OpenRouter has its own data handling policies for logging and retention”, publishes a table of them, and offers EU in-region routing through a regional hostname on its Business and Enterprise plans. Whether a host uses that hostname is not visible from outside; none of the pages below says it does.
• A local model on the box. Ollama on the same server, and nothing about the conversation leaves it. Two hosts in the table describe it; on a VPS you install it yourself.

One more thing leaves an OpenClaw server by default, and it is not the prompts: the runtime makes a daily update check to telemetry.openclaw.ai carrying the version, OS and architecture, with “no request body, install identifier, machine identifier, or random tracking identifier”; anonymous feature statistics are off unless turned on.

So an EU server settles exactly one hop: the data at rest, the transcripts, memory and files, and the host’s own access to them. The model call is the other hop, and it is the same hop on every host that bills frontier models. What differs between hosts is whether the page says so, under which paper, and whether a local model is on offer.

The table

Managed hosts first, in alphabetical order, then the four VPS providers. “Servers” is where the host says your instance runs. “Legal entity” is the company on the privacy policy, the terms or the imprint; where only a governing law is given, that is what is written. “DPA” is whether a data processing agreement is published or offered, and whether a sub-processor list exists. “Prompts go to” is what the host’s own pages say about the model call.

Reading the table

Servers in the EU. Five managed hosts put the instance itself in the EU without being asked: Aplite (Germany), ClawHosters (Germany), Everpod (Germany or Finland), OneClickClaw (Denmark) and OpenClaw Cloud (Germany, Hetzner). Three let you pick an EU location at order time: Hostinger (France, Germany, Lithuania), xCloud (six EU cities) and Railway (Amsterdam). Two say “EU and US” without saying which you get: OpenClaw Launch and Runware. ClawTrust and BetterClaw run in the United States; Flux processes personal data in Switzerland and runs containers on nodes in 67 countries. Four say nothing about where the instance runs: Agent37, Ampere (Hetzner, no country), MyClaw and RapidClaw. All four VPS providers let you choose an EU data centre.

An EU legal entity. The company you would sign with is in the EU at Aplite (Estonia), ClawHosters (Germany), OneClickClaw (Greece) and Hostinger (Lithuania, with a Cypriot entity on the DPA), and at all four VPS providers. Runware is a UK company. Agent37, ClawTrust, Everpod, Railway and xCloud are US companies; MyClaw and OpenClaw Launch name only Delaware law; Ampere names only a Delaware address; BetterClaw is an Indian company; Flux names Swiss law. RapidClaw and OpenClaw Cloud name no entity at all.

A DPA you can read. Published: BetterClaw, ClawTrust, Hostinger, Railway, and OneClickClaw with a draft notice; on request: OpenClaw Launch. Among the VPS providers, Hetzner, OVHcloud and Scaleway publish one; netcup’s was not found. The other eleven managed hosts, Aplite among them, have a privacy policy and no separate agreement. A sub-processor list exists at BetterClaw, Hostinger and OneClickClaw (inside the DPA), Railway (a trust page), OVHcloud (a PDF), and as a processor table in the privacy policies of Aplite and Everpod; ClawTrust gives it on request.

Where the prompts go. Through OpenRouter on the host’s account: Aplite, BetterClaw, Everpod, OpenClaw Launch, and Agent37 for its starter credits. Through the host’s own routing: Hostinger (its AI Router, with Anthropic Ireland on the sub-processor list) and Runware (its own inference for open-source models). Through a provider the page does not name: ClawHosters, ClawTrust, RapidClaw, OpenClaw Cloud. Only your own key: Ampere, Flux, MyClaw, OneClickClaw, Railway, xCloud, and every VPS. OpenRouter’s EU in-region routing is mentioned by none of them.

If the prompts have to stay in the EU too

Three ways, from the table and the upstream docs.

• A local model on the server. OneClickClaw runs Ollama on its Hobbyist and Pro plans; ClawHosters connects Ollama on your own hardware over a VPN; on any VPS you install Ollama yourself. Nothing about the conversation leaves the machine, and the models are the smaller open-weight ones. The $0 path is in OpenClaw hosting for free and the key question in Can you use OpenClaw without an API key?.
• An EU-hosted model API with your own key. Scaleway’s Generative APIs are “All hosted in Europe”; a BYOK host or a VPS lets you point OpenClaw at them. The provider is then your processor under its own terms.
• A router’s EU endpoint. OpenRouter offers in-region EU routing on Business and Enterprise plans; a BYOK host or a VPS lets you use your own account with it. None of the managed hosts that resell OpenRouter say they use it, Aplite included.

The Aplite row, in full

Aplite runs one OpenClaw instance per workspace in its own container on a server at netcup in Nuremberg, Germany; the database and the encrypted backups are on the same server. The company is PIKsolution OÜ, Tallinn, Estonia, named as the controller in the privacy policy and the imprint. The policy lists every processor with its country: netcup (Germany), Cloudflare (USA, in front of every request), OpenRouter and the model providers behind it (USA), Polar (EU and USA, payments), Resend (USA, email), Migadu (France, mailboxes), Google (EU and USA, sign-in only). For transfers outside the EU it relies on the standard contractual clauses and, where the provider holds one, a Data Privacy Framework certification.

The model call: the agent’s messages, the notes it reads and the tool results go to OpenRouter’s standard endpoint and on to the provider of the model you picked from the catalog, under API terms that exclude training. Aplite does not use OpenRouter’s EU in-region routing, does not offer local models, and has no option to bring your own key; what the agent sends is limited to the request at hand, and the policy says so. There is no standalone data processing agreement on the site; the privacy policy is the public statement of how the data is handled, and questions go to support@aplite.ai. None of this is a claim that your deployment is compliant; that depends on what you put into it and on the paper you hold with each party. The rest of what Aplite does and does not do with OpenClaw is on the OpenClaw page.

Every cell in the table was read on 20 October 2026; legal pages change, and the plan is to re-read them once a quarter alongside the prices.

FAQ

Is OpenClaw GDPR compliant?

OpenClaw is software you run, and compliance is a property of a deployment, not of a program. What the software does is documented: it keeps sessions, memory, config and credentials on the machine it runs on, sends the conversation to whichever model provider you configure, and makes a daily update check to the project’s server that carries no prompts or identifiers. Whether a deployment meets the GDPR depends on who runs that machine for you and under which agreement, which provider the prompts go to and on what terms, and whether you have a lawful basis for the data you feed in.

Does an EU server make my agent GDPR-compliant?

No. An EU server settles where the data at rest sits, the transcripts, memory and files, and which law the host answers to. It does not settle the model call, which goes to the provider of the model, in October 2026 usually in the United States, and it does not replace the written processing agreement that Art. 28 requires between you and the host. A server in Frankfurt with no DPA and an unnamed model provider is a server, not compliance.

Which managed OpenClaw hosts are in the EU?

Hosts whose pages put the instance in the EU: Aplite (Germany, Estonian company), ClawHosters (Germany, German sole proprietor), Everpod (Germany or Finland, US company), OneClickClaw (Denmark, Greek sole proprietor), OpenClaw Cloud (Germany, Hetzner, no entity named). Hosts where you pick an EU location: Hostinger, xCloud and Railway. OpenClaw Launch and Runware say “EU and US” without saying which. Hetzner, OVHcloud, Scaleway and netcup rent EU servers for self-hosting.

Which OpenClaw hosts offer a data processing agreement?

Published on the site: BetterClaw, ClawTrust, Hostinger, Railway, and OneClickClaw with a “draft pending legal review” label. On request: OpenClaw Launch. Among VPS providers: Hetzner (in the customer account), OVHcloud and Scaleway (PDF). The others, Aplite included, publish a privacy policy and no separate agreement as of 20 October 2026.

Where do my prompts go on a managed OpenClaw host?

To the company that serves the model. With your own key, straight from the instance to that provider under your agreement with it. With the host’s credits, through the host’s account, most often via OpenRouter in the United States and then to OpenAI, Anthropic, Google or the open-weight provider behind the model; each of those has its own retention policy, which OpenRouter documents per provider. With a local model, nowhere: the conversation stays on the server. The table’s last column says which of the three each host describes.