GDPR Compliance Risk
Heroku is a US-based service subject to the CLOUD Act. EU organizations using this service risk non-compliance with GDPR data transfer requirements.
Cloud platform for deploying, managing, and scaling applications with support for multiple languages.
Since the landmark Schrems II ruling in 2020, transferring personal data to US-based services like Heroku has become a significant legal risk for EU organizations. The US CLOUD Act gives American authorities the power to access data held by US companies, regardless of where that data is physically stored — even if it's in an EU data center.
While the EU-US Data Privacy Framework (DPF) adopted in 2023 provides a new legal basis for transfers, privacy experts and legal scholars have raised concerns about its long-term viability. The framework could face the same fate as its predecessors (Safe Harbor and Privacy Shield), both of which were struck down by the Court of Justice of the EU.
For organizations that want to eliminate compliance risk entirely, switching to a European-based developer tools is the most straightforward solution. Below are the best GDPR-compliant alternatives to Heroku, all headquartered in Europe with data stored in EU data centers.
US authorities can access your data stored by Heroku, even if servers are located in Europe.
Non-compliant data transfers can result in fines up to 4% of annual global revenue under GDPR Article 83.
1 GDPR-compliant European alternative available with full EU data residency.
European services with full GDPR compliance and EU data residency
by Uberspace
Uberspace is a web hosting service that offers flexible and scalable solutions for individuals and businesses. It provides users with the ability to host websites, applications, and databases, along with tools for managing domains and email. The platform supports various programming languages and frameworks, ensuring compatibility with diverse projects.
| Service | HQ Location | GDPR Native | EU Data Centers | CLOUD Act Free | Pricing |
|---|---|---|---|---|---|
🇺🇸Heroku | United States | No | Partial | No | freemium |
| 🇩🇪Uberspace | DE | Yes | Yes | Yes | freemium |
Heroku is a US-based service operated by Salesforce Inc.. While it may have some GDPR compliance measures, as a US company it is subject to the CLOUD Act, which allows US authorities to access data stored by US companies regardless of where the data is physically located. This creates a fundamental conflict with GDPR requirements for data protection.
The main GDPR risks include: (1) Data transfers to the US may lack adequate protection since the Schrems II ruling invalidated Privacy Shield, (2) US authorities can demand access under the CLOUD Act, (3) Your organization may face GDPR fines up to 4% of annual revenue for non-compliant data transfers, and (4) User consent may not be sufficient to legitimize transfers given the systematic access by US authorities.
The top GDPR-compliant alternatives to Heroku include Uberspace. These European services store your data in EU data centers and are fully subject to GDPR protections.
Most migrations involve three steps: (1) Export your data from Heroku using their data export tools, (2) Create an account with your chosen EU alternative, and (3) Import your data into the new service. We provide detailed migration guides for each alternative to make the switch as smooth as possible.
Since the Schrems II ruling (2020), EU organizations face significant legal risk when using US cloud services like Heroku. While the EU-US Data Privacy Framework (2023) provides a new legal basis, its long-term stability is uncertain. Many EU data protection authorities recommend using EU-based alternatives to avoid compliance risks entirely.
Last updated: January 29, 2026
