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Independently verified · Quarterly re-audit
EU VETTED

Padloc

VERIFIED
Password managers · Germany
Founded 2019 · padloc.app ↗

German AGPLv3 open-source password manager (MaKleSoft, Bavaria), audited 3×, self-hostable, but hosted cloud uses Stripe + defunct Privacy Shield ref.

In short

Padloc, in the Password managers category, offers EU hosting with Germany as its hosting location, but a US parent or sub-processor leaves material CLOUD Act exposure.

Assessment notes

Padloc is an AGPLv3 open-source password manager developed by MaKleSoft (a German micro-company at Meisenstr. 5, Ansbach, Bavaria; contact Martin Kleinschrodt), end-to-end encrypted and audited by three independent security groups, self-hostable for free for personal/non-profit use, but the hosted cloud version has material gaps: the public privacy policy still references the long-defunct 'U.S.-E.U. Privacy Shield Framework' (invalidated by Schrems II in July 2020), names Stripe (US) as payment processor, and does not disclose the cloud hosting location or a sub-processor list, so the hosted product carries material CLOUD Act exposure and an out-of-date privacy posture; self-hosted on EU infrastructure it is EU-owned, self-hosted, with no CLOUD Act exposure.

CLOUD ACT
OWNERSHIP
SUB-PROCS
not disclosed
CLOUD Act by deployment

Exposure depends on how you run this product.

Hosted SaaS (default)

Vendor-operated: the sub-processors below apply.

Self-hosted (open-source)

Deploy on your own EU infrastructure and you control hosting and every sub-processor.

Verified signals
Jurisdiction
  • EU / adequacy hosting
  • EU / adequacy operator
  • No US CLOUD Act exposure
Transparency
  • Public DPA
  • Sub-processors disclosed
  • Open-source clients
  • Third-party certification
JUMP TO
OVERVIEW

About Padloc

Padloc is an open-source, end-to-end encrypted password manager developed by MaKleSoft, a German micro-company based at Meisenstr. 5 in Ansbach, Bavaria, with Martin Kleinschrodt as the contact person. It is the successor to the earlier "Padlock" project (which dates to around 2015) and was rebranded to Padloc around 2019. The product is published under the GNU Affero General Public License (AGPLv3), with a commercial licence available for commercial use; self-hosting is free for personal use and non-profit organisations. Padloc states its data is end-to-end encrypted so neither MaKleSoft nor anyone else can read it, and the project advertises that it has been audited by three independent groups of security experts.

For an EU-sovereignty audit, Padloc splits sharply into two products. The self-hosted path is excellent: AGPLv3 source on GitHub, a published security whitepaper, a German developer bound by GDPR, and full control of where the data lives. Run on Hetzner, OVHcloud or Scaleway and it is EU-owned, self-hosted, with no CLOUD Act exposure. The hosted cloud path is where the concerns sit. Padloc's public privacy policy still states that its third-party data processors "conform to the U.S.-E.U. Privacy Shield Framework", a framework that the Court of Justice of the EU invalidated in the Schrems II ruling in July 2020. A privacy policy that has not been updated to reflect five-year-old case law is itself a red flag. The policy also names Stripe (US) as the payment processor and does not disclose the cloud hosting location or a full sub-processors list. On that basis the hosted product carries material CLOUD Act exposure and an unresolved DPA / sub-processor gap.

Pricing is freemium: a Free $0 tier; Premium at $3.49/month ($34.90/year); Family at $5.95/month; Team at $3.49/user/month; Business at $6.99/user/month; Enterprise custom. Best fit: privacy-conscious individuals and teams who will self-host Padloc on EU infrastructure. That is the configuration that earns the listing. Buyers considering the hosted cloud version should weigh the outdated privacy policy and prefer Proton Pass, Passbolt or Psono until MaKleSoft updates its sub-processor and hosting disclosures.

SUB-PROCESSORS

Sub-processor map · not disclosed

Vendor does not publish a sub-processors list. Schrems II compliance and CLOUD Act exposure cannot be independently verified without it.
CERTIFICATIONS

Frameworks & certifications · none listed

We checked the vendor's website and standard certification body registries. No active certifications found at the time of last audit (2026-05-18).
FEATURES

Capability matrix

Breach monitoring Yes
Family sharing Yes
Data export Yes
Devices Unlimited
Platforms iOS macOS Windows Android Linux Web
INTEGRATION & ACCESS
REST API No
SSO (SAML / OIDC) No
COMPLIANCE & GOVERNANCE
Audit log No
Self-host / on-prem option Yes
PRICING

Pricing & tiers

FREEMIUM
from €3/mo
View pricing page ↗
PUBLIC DOCUMENTS

Public documents

Vendor does not publish a public DPA. Without a publicly accessible Data Processing Addendum, small EU customers cannot self-serve the processor agreement. This is recorded as no public DPA (see How we assess).
Vendor does not publish a sub-processors list. Schrems II compliance and CLOUD Act exposure cannot be independently verified without it.
  • Data Processing Addendum (DPA)
    — missing
    missing
  • Sub-processors list
    — missing
    missing
  • Terms of Service
    padloc.app/tos…
    Open ↗
ALTERNATIVES

Alternatives in this category

heylogin
Germany · Founded 2021
EU-SOVEREIGN

German passwordless zero-knowledge password manager (heylogin GmbH, Braunschweig), all-German sub-processor stack, ISO 27001:2022, no CLOUD Act exposure.

Public DPA Sub-processors Open source
FROM
€4/mo
CLOUD ACT
NONE
KeePassXC
Germany · Founded 2016
EU-SOVEREIGN

GPLv3 fully-offline desktop password manager (KeePassXC Team, Weimar DE, est. 2016): no cloud, no servers, no telemetry; structurally zero CLOUD Act exposure.

Public DPA Sub-processors Open source
FROM
CLOUD ACT
NONE
LC-Pass
Germany
EU-SOVEREIGN

German-hosted business password manager from LC by vBoxx GmbH; collections, group sharing, central management, unlimited devices; an EU-hosted 1Password / LastPass alternative.

Public DPA Sub-processors Open source
FROM
€3.99/mo
CLOUD ACT
NONE