Is Cloudflare CDN GDPR compliant?

What does Cloudflare CDN do?

A public CDN for libraries. Each file request sends the visitor's IP to Cloudflare. Serving the same files from your own domain removes the transfer and is usually faster over HTTP/2 anyway.

Does Cloudflare CDN need consent?

No consent is needed for Cloudflare CDN on its own, because it does not store or read anything on the device beyond what is strictly necessary. That is not a free pass: it must still be named in your privacy policy, and the request itself still reveals the visitor's IP address to the provider.

GDPR Art. 13(1)(e)

Does Cloudflare CDN send data outside the EEA?

Yes. Cloudflare CDN processes data outside the European Economic Area, so you need a transfer mechanism under Chapter V and you have to say so in your privacy policy. In practice this means standard contractual clauses, or a provider certified under the EU-US Data Privacy Framework.

GDPR Art. 44 · GDPR Art. 46

How do we detect Cloudflare CDN?

We load your page in a real browser as a first-time visitor who clicks nothing, then look at what it contacted. Cloudflare CDN is recognised by requests to cdnjs.cloudflare.com, and we report whether it merely loaded or actually sent data, and whether it set a cookie before any choice was made.