pCloud Pass
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 This listing EU-operated, with at most minor or transient US exposure.
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EU-Hosted 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.
Swiss zero-knowledge password manager (pCloud International AG), client-side AES-256, free single-device tier, Luxembourg or US data residency.
pCloud Pass is a European service hosted in Luxembourg, with at most minor, transient US exposure under the CLOUD Act. It is listed under Password managers.
Assessment notes
pCloud Pass is the password-manager product of the Swiss pCloud group, whose privacy policy names the operator as pCloud International AG (registered seat recorded as Baar, Switzerland; founded 2013 by Tunio Zafer and Anton Titov, ~22M users across the broader pCloud group). It is Swiss-incorporated, founder-controlled, with client-side AES-256 zero-knowledge encryption so even pCloud cannot decrypt customer vaults, but pCloud operates two data centres (Luxembourg AND Texas, USA) and customer-data residency depends on the region the user selects at signup, so EU buyers must explicitly choose the Luxembourg region. Key gaps: pCloud Pass does not publish a standalone DPA (the Business Agreement contains no DPA section and no dedicated data-processing document exists for Pass specifically) and no sub-processor list was found at audit. With EU data-residency selected: Swiss-incorporated, EU-hosted, minor CLOUD Act exposure (Swiss entity, no US parent); without explicit EU placement the posture deteriorates materially.
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 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.
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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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European This listing Swiss/EEA-owned, with no significant US ownership; treated as European.
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EU HQ, US-funded 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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- 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: Not assessed
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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 pCloud Pass
pCloud Pass is the standalone password-manager product of the Swiss pCloud cloud-storage group, headquartered in Baar (canton of Zug) and founded in 2013 by Tunio Zafer (CEO) and Anton Titov. The pCloud privacy policy names the operating entity as pCloud International AG, giving no address, so the exact registered company is worth confirming against the Swiss commercial register. The broader pCloud group reports more than 22 million users worldwide, primarily for its consumer cloud-storage product but increasingly through Pass and the wider Suite bundle. pCloud Pass launched in 2022 as a separate offering with zero-knowledge client-side encryption (passwords are encrypted on the user's device before any data leaves it, so pCloud has no ability to read customer vaults under any circumstance) and bundles features standard for the category: AES-256 encryption, password generation, secure sharing, auto-fill across browsers and mobile, biometric unlock, and recovery flows.
For an EU-sovereignty audit the picture is nuanced. The legal entity (pCloud International AG) is Swiss-incorporated, founder-controlled, and operates under Swiss law. Switzerland holds an EU adequacy decision so cross-border transfers between EU and CH need no SCCs. But pCloud operates two data centres globally, in Luxembourg (EU) and Texas (USA), and the customer selects their data-residency region at signup. Buyers who choose EU placement get a clean Swiss-Luxembourg posture; buyers who choose US placement (or default to it without thinking) end up with their encrypted vault on US infrastructure. Per the strict-ownership stance the customer-side choice matters: with explicit EU placement, CLOUD Act exposure is minor (Swiss entity, EU at-rest); with US placement, it would be material. The score reflects the EU configuration; the Luxembourg-only data-residency point should be a procurement instruction on the actual listing page.
Pricing is competitive and lifetime-friendly: the free tier covers one device with basic features; Premium is €29.99/year (annual) or available as a lifetime one-time payment (a distinguishing feature in the password-manager category, where most competitors are subscription-only). Best fit: pCloud Suite customers already on the platform, Swiss / EU SMBs wanting a Swiss-entity password manager without setting up a separate vendor relationship, and consumers who prefer lifetime pricing over subscription. Procurement-grade buyers needing the cleanest possible posture should prefer Proton Pass (CH, Proton Foundation-owned, no US DC option), Passbolt (FR, self-hostable open-source), or Psono (DE, open-source self-host), all covered elsewhere on this directory.
Sub-processor map · not disclosed
Frameworks & certifications · none listed
Capability matrix
Table 1Capabilities of pCloud Pass
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 Servicewww.pcloud.com/terms_of_service.html…
Alternatives in this category
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Germany · €4/moEU-SovereignCLOUD 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 This listing 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 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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GermanyEU-SovereignCLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
-
None This listing EU operator, no US parent, no US sub-processors of note.
-
Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
-
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: Not assessed Sub-processors: No Open source: Yes -
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Germany · €3.99/moEU-SovereignCLOUD 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 This listing EU operator, no US parent, no US sub-processors of note.
-
Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
-
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: Not assessed Sub-processors: No Open source: No -
| Product | Sovereignty | CLOUD Act | Signals | From |
|---|---|---|---|---|
heylogin
Germany
|
EU-Sovereign | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
|
Public DPA: Yes
Sub-processors: Yes
Open source: No
|
€4/mo |
KeePassXC
Germany
|
EU-Sovereign | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
|
Public DPA: Not assessed
Sub-processors: No
Open source: Yes
|
— |
LC-Pass
Germany
|
EU-Sovereign | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
|
Public DPA: Not assessed
Sub-processors: No
Open source: No
|
€3.99/mo |