EU-hosted computers for GDPR-compliant AI agents

Sanbox gives AI agents a persistent cloud computer with EU data residency: your Computers, their disks and snapshots, uploaded files, run records and accounts are stored and processed in EU data centres. Sanbox is run by Sanlabs GmbH in Berlin, a company under German law, and comes with a data processing agreement under Article 28 GDPR, governed by German law.

Your agents call the model provider you choose, with your own key. If that provider is EU-hosted too, the whole agent loop stays in the EU.

This post explains EU data residency for AI agents on Sanbox: what is stored where, what leaves the EU, how the GDPR splits responsibilities between you and us, and how the EU Data Act, the AI Act, NIS2 and DORA fit in.

Where does Sanbox store and process data?

With EU data residency, everything Sanbox stores for you sits in EU data centres:

Computers: their disks, installed software, agent memory and chat history, browser profiles, and snapshots.
Files: uploaded files, run outputs and copies of stopped Computers.
Model gateways: the servers that forward your agents' model calls run next to the Computers.
Accounts, run records and settings.
Logs and monitoring.
Account emails, such as sign-up and password-reset emails, are sent from the EU.

Some of the companies that run this infrastructure for us have parent companies outside the EU. Our contracts with them include the EU Standard Contractual Clauses, and our data processing agreement lists each one. Our EU Data Act information page describes the jurisdiction and our protections against access by authorities outside the EU.

Does any data leave the EU?

Only what your agents send out themselves. A Computer's network access is deny-by-default. It reaches the model provider configured for its template and the destinations you allow in its network policy, and nothing else. Each destination, such as a package registry, an internal API or a website, is a choice you make, under your own agreement with that service.

The model is the one that matters most. Sanbox doesn't sell or host models. Your organisation brings its own provider key, and Sanbox forwards the agent's calls to that provider. To keep prompts and responses in the EU as well, use a provider region your contract keeps in the EU, or point your template at any EU-hosted, OpenAI-compatible endpoint. Sanbox supports custom endpoints for exactly this.

Under the GDPR, you are the controller of the personal data your agents work with, and Sanlabs is your processor. Our data processing agreement sets out what we commit to as processor:

We process your data only on your documented instructions.
We list our sub-processors, tell you by email at least 14 days before adding or replacing one, and you can object.
We transfer data outside the EU only through the listed sub-processors, under Chapter V GDPR safeguards such as the Standard Contractual Clauses.
We notify you of a personal data breach within 48 hours at most, with a target of 24 hours.
We delete your data from live systems within 14 days of your instruction, and from backups and logs within 30 days.
We help you, free of charge within the normal scope, with data subject requests, security, breach notifications and data protection impact assessments.

Some decisions stay with you as controller: which personal data your agents process, the legal basis for it, which websites and services they may reach, and which model provider they call. Sanbox's job is to make the infrastructure part of that work straightforward.

No. The GDPR doesn't require any certification. It requires a processor to give "sufficient guarantees" of appropriate technical and organisational measures (Article 28), to sign a contract with the controller, and to secure the data appropriately (Article 32).

Certification schemes under Article 42 GDPR are voluntary. Article 28(5) names an approved certification as one element a processor may use to show sufficient guarantees, not as a condition. ISO 27001, SOC 2 and BSI C5 are information-security standards, not GDPR certificates.

For a vendor review, ask any provider for three documents: its data processing agreement, its sub-processor list with locations, and its technical and organisational measures. Sanbox sends you all three on request.

How does Sanbox keep agents isolated?

Each Computer runs in its own Firecracker microVM, with its own kernel and its own private disk, separated from other Computers by hardware virtualisation. An agent that misbehaves, or code it runs that it shouldn't, stays inside its own machine.

Credentials get the same care. Model provider keys, OAuth tokens and secret proxy credentials are encrypted at application level with AES-256. With Secret Proxies, Sanbox adds a credential to an outgoing request on its way out of the Computer, so the agent can use an API without ever seeing the key. Connections to the console, the API and the CLI use TLS.

Which EU laws apply, and how does Sanbox fit?

GDPR. Covered above: Sanlabs processes your data as your processor, under an Article 28 agreement governed by German law.

EU Data Act. Sanbox is a data processing service under the Data Act, so you can switch provider or take your data with you. You can export files, outputs, templates and run records at any time through the console, the API and the CLI, in open formats such as tar archives and JSON. There are no fees for switching, retrieving or exporting your data, and no early termination fees. The Data Act page has the full switching procedure and the export formats.

EU AI Act. The AI Act regulates AI systems and the companies that provide or deploy them, not the computers those systems run on. If your agent falls into a high-risk area, such as credit scoring or hiring, your obligations include automatic logging, human oversight with a way to stop the system, and robustness. Sanbox gives you the building blocks: an isolated machine per agent, a Stop for every Computer, and run records and event history you can export.

NIS2 and DORA. If your organisation is in scope, both reach your suppliers through your contracts. For your supplier assessment, we provide the data processing agreement, the sub-processor list, the data locations, our technical and organisational measures, and our exit procedure under the Data Act.

Yes. The agent, its files, its session history and everything it builds stay on your Computer in the EU. Sanbox's OpenCode Computer comes with OpenCode ready to use.

The part to check is the model. OpenCode works with many model providers, so you can point it at an EU-hosted, OpenAI-compatible endpoint, or at a provider region covered by your own data processing agreement. Then allow only the destinations each template needs in its network policy.

How is this different from an EU region at a US provider?

If you're looking for an EU alternative to a US sandbox provider: some of them offer an EU region. A region decides where the machine runs. It doesn't change which company you sign with or which company runs the service. With Sanbox you sign with a German company, under German law, and the machine runs in the EU.

Quick answers

Where is my data hosted? In EU data centres: Computers, files, the database, logs and monitoring.

Can my agents run outside the EU? Yes. Sanbox can also run in other regions, in your own cloud or on your own hardware. Write to sales@sanlabs.ai and tell us where your agents need to run.

Does Sanbox train models on my data? No. Sanbox doesn't train models.

Can I see the data processing agreement before signing up? Yes. Write to support@sanlabs.ai and we'll send it, with the sub-processor list.