OpenRouter
GDPR Compliance
Data Handling
EU in-region routing (eu.openrouter.ai) is enterprise-only and not enabled by default. Standard accounts route globally through US infrastructure with no data-residency guarantee. Even with EU routing enabled, every request passes through OpenRouter's US gateway infrastructure, creating a mandatory cross-border transfer.
OpenRouter layer: prompts not logged by default (ZDR mode). Opt-in prompt logging available. Upstream providers each have their own retention policies, which vary widely. ZDR flag restricts routing to zero-retention endpoints only.
Each of 60+ upstream providers is effectively a sub-processor with its own data handling policy. OpenRouter's own DPA covers only OpenRouter's layer, not upstream providers.
Certifications & EU AI Act
Verification
Gateway routing to 300+ upstream models (GPT-4o, Claude, Gemini, Llama, DeepSeek, Mistral, etc.). Most complex GDPR posture in this directory: the gateway architecture makes every upstream provider a de facto sub-processor, none of which are formally listed. EU routing requires enterprise agreement. Illustrates the compliance gap created by gateway/aggregator services.