TL;DR: Quick Reference
• What: Complete guide to EU data residency requirements and HubSpot subprocessors for financial services firms
• Key Benefit: Navigate GDPR compliance confidently and prevent data residency from derailing deals
• For: Financial services compliance teams, HubSpot implementers, and sales teams selling to EU markets
• Bottom Line: Address data residency proactively—EU hosting solves the primary storage question, but subprocessor awareness is essential for full compliance
Author: Vantage Point | Category: HubSpot, GDPR, Data Residency, Financial Services
If you're selling HubSpot into a European financial institution, the question will surface early and forcefully: "Can you guarantee our data never leaves the EU?" The honest answer is nuanced, and understanding that nuance is essential to navigating the sales cycle without surprises twelve months in.
At Vantage Point, we've encountered this objection firsthand — both from European subsidiaries of US firms and from EU-headquartered financial institutions. The firms that handle it well address data residency at the beginning of the engagement, not at the end.
Yes. Since July 2021, new HubSpot customers can choose to host their data in the EU data center located in Frankfurt, Germany. Existing customers can also migrate their data to the EU data center using HubSpot's migration tool. When your account is hosted in the EU, your customer data is processed and stored in that location and replicated to other data centers within the same regional hosting location for disaster recovery and backup purposes.
For European financial services firms, this means the primary data storage question is answered. Your CRM data, contacts, deals, marketing assets, and activity logs reside in the EU by default if you select that data center at sign-up or migrate to it afterward.
Here's where the complexity begins. Even when your HubSpot account is hosted in the EU data center, certain subprocessors may process data outside the EU. HubSpot publishes its full list of subprocessors, and for each one, you can see the processing location based on your data center selection. Some subprocessors are marked with an asterisk, meaning you can choose not to use the functionality they provide — effectively opting out of that data transfer.
The critical example that comes up repeatedly in financial services procurement is Meta Platforms. If your organization runs any Meta advertising services through HubSpot, data may route through US-based infrastructure. Similarly, certain AI features powered by providers like OpenAI may involve processing outside the EU, though HubSpot has contractual commitments around data retention minimization and prohibits AI service providers from using customer data for model training.
We've worked with organizations including a high-frequency trading firm with European subsidiaries, that addressed this by running separate HubSpot instances for their European and US businesses. The European business operated its own instance with EU data hosting, and integration between the two was handled carefully to maintain data separation. They contracted separately for the European instance, ensuring full compliance with GDPR requirements.
This pattern — separate instances with controlled integration — is common among financial services firms that operate across both sides of the Atlantic. It adds operational complexity, but it provides the clean data separation that compliance teams require.
HubSpot's Data Processing Agreement includes the EU-US Data Privacy Framework, the Swiss-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, and the European Commission's Standard Contractual Clauses as mechanisms for lawful data transfer from the EU to the US. HubSpot also provides a Transfer Impact Assessment that organizations can review as part of their due diligence.
For financial services compliance teams evaluating these mechanisms, the practical question is whether your specific regulatory framework accepts SCCs and the DPF as sufficient grounds for transfer. Most European regulators have accepted these mechanisms, but individual supervisory authorities may impose additional requirements, and financial services regulations in certain jurisdictions may layer on top of GDPR.
Start by mapping which HubSpot features your organization will actually use. Not every subprocessor applies to every customer — if you don't use certain integrations or AI features, those subprocessors never touch your data. Subscribe to HubSpot's subprocessor update notifications so you receive advance notice of any changes, which HubSpot provides at least 30 days before a new subprocessor is engaged.
Bring your Data Protection Officer into the evaluation early. Have them review HubSpot's DPA, subprocessor list, and Transfer Impact Assessment against your organization's specific obligations. If full EU data containment is an absolute regulatory requirement, identify which features might involve non-EU processing and make informed decisions about whether to use them.
The worst outcome is discovering a data residency issue after months of engagement. Financial services procurement teams will ask about this, and if you don't have clear answers ready, you lose credibility and momentum.
At Vantage Point, we recommend addressing data residency proactively in the first substantive conversation with any EU financial services prospect. Present the architecture: EU data center in Frankfurt, the subprocessor landscape, the legal transfer mechanisms, and the practical options for managing any features that involve non-EU processing. Having a partner that has navigated these conversations before — and can speak to specific examples of how other financial services organizations have structured their deployments — turns what could be a deal-blocker into a manageable procurement step.
About Vantage Point: Vantage Point is a boutique consulting firm exclusively serving financial services organizations across HubSpot, Salesforce, and the broader technology stack. With on-the-ground presence in both the US and Europe, we help clients navigate the intersection of platform implementation and regulatory compliance. Learn more at vantagepoint.io.