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GDPR Compliance Risk

Adobe Photoshop is a US-based service subject to the CLOUD Act. EU organizations using this service risk non-compliance with GDPR data transfer requirements.

Adobe Photoshop logo

GDPR-Compliant Alternative to Adobe Photoshop

🇺🇸Adobe Inc. · US-based · Subject to CLOUD Act

Adobe Photoshop, developed by Adobe Inc., is a comprehensive design and creative tool widely used for photo editing, graphic design, and digital art. It allows users to manipulate images with precision, offering a vast array of tools for tasks ranging from simple retouching to complex 3D designs. Key features include advanced editing capabilities, layer management, and a variety of brushes and filters to enhance creativity. Photoshop is designed for professional photographers, graphic designers, and digital artists who require robust tools for detailed image manipulation and creation. As a US-based product, Adobe Photoshop stores data in the United States, making it subject to US data laws such as the CLOUD Act and FISA 702. The software is available through a subscription model, with pricing options that vary based on the plan and included features.

Why You Need a GDPR-Compliant Alternative to Adobe Photoshop

Since the landmark Schrems II ruling in 2020, transferring personal data to US-based services like Adobe Photoshop has become a significant legal risk for EU organizations. The US CLOUD Act gives American authorities the power to access data held by US companies, regardless of where that data is physically stored — even if it's in an EU data center.

While the EU-US Data Privacy Framework (DPF) adopted in 2023 provides a new legal basis for transfers, privacy experts and legal scholars have raised concerns about its long-term viability. The framework could face the same fate as its predecessors (Safe Harbor and Privacy Shield), both of which were struck down by the Court of Justice of the EU.

For organizations that want to eliminate compliance risk entirely, switching to a European-based design & creative tools is the most straightforward solution. Below are the best GDPR-compliant alternatives to Adobe Photoshop, all headquartered in Europe with data stored in EU data centers.

CLOUD Act Exposure

US authorities can access your data stored by Adobe Photoshop, even if servers are located in Europe.

GDPR Fine Risk

Non-compliant data transfers can result in fines up to 4% of annual global revenue under GDPR Article 83.

EU Alternative Available

3 GDPR-compliant European alternatives available with full EU data residency.

3 GDPR-Compliant Alternatives to Adobe Photoshop

European services with full GDPR compliance and EU data residency

Affinity Suite logo

by Affinity Suite

UK-based professional creative suite including Photo, Designer, and Publisher as one-time purchase alternatives to Adobe.

GDPR CompliantEU-Based
paidMigration:2-4 hours

Why switch?

  • One-time purchase of Affinity Suite is $54.99 vs. Adobe's $20.99/month.
  • Affinity Suite offers cross-platform support for Windows, macOS, and iPad.
  • GDPR compliance ensures better data protection for EU users.

Consider

  • Photoshop's extensive brush and filter library is not fully replicated.
  • Learning curve exists due to different interface and tool organization.
Photopea logo

Photopea

🇨🇿

by Photopea

Photopea is a web-based graphic editor that supports various file formats, including PSD, XCF, and Sketch. It offers tools for photo editing, vector graphics, and text manipulation. Users can work directly in the browser without the need for software installation, making it accessible across devices.

GDPR CompliantEU-Based
freemiumMigration:2-4 hours

Why switch?

  • Photopea runs in a browser, eliminating installation requirements.
  • Free tier available, with no subscription fees like Photoshop's $20/month.
  • Supports PSD files, allowing easy import/export from Photoshop.

Consider

  • Limited advanced features compared to Photoshop's extensive toolset.
  • Learning curve for users accustomed to Photoshop's interface.
Krita logo

Krita

🇳🇱

by Krita

Krita is a free, open-source digital painting software designed for artists. It offers a variety of brushes, tools, and features for creating illustrations, concept art, and animations. Users can work with layers, masks, and advanced color management. Compatible with multiple operating systems, Krita supports various file formats for easy sharing and collaboration.

GDPR CompliantEU-BasedOpen Source
freeMigration:2-4 hours

Why switch?

  • Krita is open source, allowing for community-driven feature updates.
  • Krita offers extensive brush customization with over 30 brush engines.
  • Animation support in Krita includes frame-by-frame and onion skinning.

Consider

  • Photoshop's advanced editing tools are more comprehensive than Krita's.
  • Krita's learning curve may be steep for users accustomed to Photoshop.

Quick GDPR Compliance Comparison

ServiceHQ LocationGDPR NativeEU Data CentersCLOUD Act FreePricing
🇺🇸Adobe Photoshop
United StatesNoPartialNo-
🌍Affinity SuiteGBYesYesYespaid
🇨🇿PhotopeaCZYesYesYesfreemium
🇳🇱KritaNLYesYesYesfree

Frequently Asked Questions

Is Adobe Photoshop GDPR compliant?

Adobe Photoshop is a US-based service operated by Adobe Inc.. While it may have some GDPR compliance measures, as a US company it is subject to the CLOUD Act, which allows US authorities to access data stored by US companies regardless of where the data is physically located. This creates a fundamental conflict with GDPR requirements for data protection.

What are the GDPR risks of using Adobe Photoshop?

The main GDPR risks include: (1) Data transfers to the US may lack adequate protection since the Schrems II ruling invalidated Privacy Shield, (2) US authorities can demand access under the CLOUD Act, (3) Your organization may face GDPR fines up to 4% of annual revenue for non-compliant data transfers, and (4) User consent may not be sufficient to legitimize transfers given the systematic access by US authorities.

What are the best GDPR-compliant alternatives to Adobe Photoshop?

The top GDPR-compliant alternatives to Adobe Photoshop include Affinity Suite, Photopea, Krita. These European services store your data in EU data centers and are fully subject to GDPR protections.

How do I migrate from Adobe Photoshop to a GDPR-compliant alternative?

Most migrations involve three steps: (1) Export your data from Adobe Photoshop using their data export tools, (2) Create an account with your chosen EU alternative, and (3) Import your data into the new service. We provide detailed migration guides for each alternative to make the switch as smooth as possible.

Can EU companies legally use Adobe Photoshop?

Since the Schrems II ruling (2020), EU organizations face significant legal risk when using US cloud services like Adobe Photoshop. While the EU-US Data Privacy Framework (2023) provides a new legal basis, its long-term stability is uncertain. Many EU data protection authorities recommend using EU-based alternatives to avoid compliance risks entirely.

Other GDPR Alternatives in Design & Creative Tools

Last updated: January 31, 2026