Mangopay
A single roll-up of ownership and CLOUD Act exposure.
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EU-Sovereign EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
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EU-Based EU-operated, with at most minor or transient US exposure.
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EU-Hosted This listing EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
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US-Linked Operated by a US-incorporated entity, directly subject to US jurisdiction.
Luxembourg CSSF + UK FCA-EMI-licensed marketplace payments (2013), 2,500+ platforms (Vinted, Malt, Wallapop), Advent International-owned since 2022.
Mangopay offers EU hosting in Luxembourg, but a US parent or sub-processor leaves material CLOUD Act exposure. It is listed under Payments.
Assessment notes
Mangopay S.A. (Luxembourg, founded 2013, marketplace-payments specialist for Vinted / Malt / Wallapop / Chrono24 / 2,500+ platforms) holds an EMI licence from the CSSF (Luxembourg) plus a UK EMI from the FCA (strong EU regulatory anchoring) but was acquired in April 2022 by Advent International (US private equity, Boston) with €75M primary capital injection; ownership_signal: eu_hq_us_funded, cloud_act_exposure: material (US-PE controlling shareholder) despite the Luxembourg licence; no public DPA or sub-processors list accessible at audit.
Findings
- CLOUD Act
- CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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None EU operator, no US parent, no US sub-processors of note.
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Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
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Material This listing US parent, or a core sub-processor is a US-owned hyperscaler.
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Direct The operator itself is US-incorporated.
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- Ownership
- Ownership
Where ultimate control over the operating company sits.
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EU-owned EU-incorporated and EU-controlled; no significant US ownership.
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EU HQ, US-funded This listing EU-headquartered but US venture- or PE-controlled.
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EU subsidiary, US parent European operating company owned by a US parent company.
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US-owned The operating company itself is US-headquartered.
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Other A non-EU jurisdiction. Swiss/EEA-owned vendors count as European here; the UK and others do not.
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- Sub-processors
- — not disclosed
Verified signals
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EU / adequacy hosting: Yes
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EU / adequacy operator: Yes
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No US CLOUD Act exposure: No
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Public DPA: No
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Sub-processors disclosed: No
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Open-source clients: No
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Third-party certification: No
Jump to
About Mangopay
Mangopay is a Luxembourg-headquartered marketplace-payments specialist operated by Mangopay S.A. and founded in 2013. The product is purpose-built for two-sided marketplaces and platforms: multi-party wallet infrastructure, multi-currency accounts, FX, KYC / KYB across 16+ countries, payouts to merchants, and the regulated end-to-end flow that Stripe Connect and Braintree compete on. The customer base includes Vinted (EU's largest second-hand fashion marketplace), Malt (freelance marketplace), Wallapop (Spanish C2C), Debenhams, and Chrono24; 2,500+ platforms in total, processing €68B across 207M wallets to date.
Regulatory posture is strong on paper: Mangopay S.A. holds a CSSF (Commission de Surveillance du Secteur Financier) Electronic Money Institution licence in Luxembourg for EU/EEA passporting, plus a UK Electronic Money Institution licence from the FCA for post-Brexit UK operations. Luxembourg's CSSF-EMI framework is among the most demanding in Europe and is widely used by Fortune-500-grade fintech. Where the EU-sovereignty audit complicates things is ownership: in 2015 Mangopay (alongside Leetchi.com, the consumer-side sister product) was acquired by Crédit Mutuel Arkéa, the French cooperative bank, a clean EU-owned chapter. In April 2022 Crédit Mutuel exited and Advent International (a US private-equity firm headquartered in Boston, Massachusetts) acquired Mangopay with €75M of primary capital. The US-PE controlling shareholder results in ownership_signal: eu_hq_us_funded and cloud_act_exposure: material even though the licensed entity remains Luxembourgish.
Pricing is enterprise / volume-negotiated for marketplaces; no public per-transaction pricing applies, and starts_from_eur is left null. Best fit: marketplace and platform operators in the EU who need multi-party regulated payments and KYC at scale and accept a US-PE-owned counter-party. Procurement-grade EU-only marketplaces should consider Lemonway (FR, also marketplace-focused, listed later in this category) or build on top of Adyen / Worldline (NL/FR public-listed) instead.
Sub-processor map · not disclosed
Frameworks & certifications · none listed
Capability matrix
Table 1Capabilities of Mangopay
Integration & access
Compliance & governance
Pricing & tiers
Public documents
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missingData Processing Addendum (DPA)— missing
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missingSub-processors list— missing
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OpenTerms of Servicemangopay.com/terms-and-conditions…
Alternatives in this category
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NetherlandsEU-HostedCLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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None EU operator, no US parent, no US sub-processors of note.
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Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
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Material This listing US parent, or a core sub-processor is a US-owned hyperscaler.
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Direct The operator itself is US-incorporated.
Public DPA: Yes Sub-processors: Yes Open source: No -
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FranceEU-HostedCLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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None EU operator, no US parent, no US sub-processors of note.
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Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
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Material This listing US parent, or a core sub-processor is a US-owned hyperscaler.
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Direct The operator itself is US-incorporated.
Public DPA: No Sub-processors: No Open source: No -
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NorwayEU-BasedCLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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None EU operator, no US parent, no US sub-processors of note.
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Minor This listing A transient US sub-processor (CDN, maps); data at rest stays in the EU.
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Material US parent, or a core sub-processor is a US-owned hyperscaler.
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Direct The operator itself is US-incorporated.
Public DPA: Yes Sub-processors: Yes Open source: No -
| Product | Sovereignty | CLOUD Act | Signals | From |
|---|---|---|---|---|
Adyen
Netherlands
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EU-Hosted | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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Public DPA: Yes
Sub-processors: Yes
Open source: No
|
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Alma
France
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EU-Hosted | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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Public DPA: No
Sub-processors: No
Open source: No
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Dintero
Norway
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EU-Based | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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Public DPA: Yes
Sub-processors: Yes
Open source: No
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