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GDPR-Compliant File Conversion Without a Data Processing Agreement

If a document contains personal data — names, addresses, ID numbers, employee records, customer details — and it gets uploaded to a third-party website to convert or edit it, that site has typically just become a data processor under GDPR. That usually means a Data Processing Agreement (DPA) is supposed to be in place before the upload ever happens, which most people using a free online converter for a one-off task have obviously never signed.

The practical answer: a tool that never receives the file at all — because processing happens locally in your own browser — never takes on the role of a data processor for that document in the first place, since it never has access to the personal data within it.

Why the upload step is the actual issue

GDPR's processor obligations get triggered by a third party gaining access to personal data on your behalf. With a conventional online converter, that access happens the moment your file is uploaded, before any conversion even starts. With a tool that reads and processes your file entirely in your browser using JavaScript/WebAssembly, that access never occurs — nothing about the file is transmitted to us or to any server, so there is no data processing happening outside your own device to account for.

See it for yourself

Rather than ask you to trust that description, the Transparency page walks through checking it directly: open your browser's Network tab while using any tool here, and confirm no file data is being sent anywhere.

This is general information, not legal advice

This page explains how the technology works so your own team can assess it — it isn't a formal compliance certification, and it isn't a substitute for your organization's Data Protection Officer or legal counsel making the actual determination for your specific use case. GDPR compliance depends on your full processing context (lawful basis, retention, data subject rights handling, and more), not just whether one particular tool avoids a file upload. If your organization requires a formal assessment before using any external tool, please route this page to whoever handles that review.

Tools commonly used with personal data