On Smallstep Certificate Manager's Privacy Page you can request and collect all the privacy and GDPR related information that Smallstep Certificate Manager is providing.
The privacy policy by is a legal document or statement that discloses how Smallstep Certificate Manager gathers, uses, discloses, and manges their customers' data.
The basis for Smallstep sharing, adding, uploading, hosting, accessing or sending personal data out of Europe. Vendors can also add a description of their own impact assessment for data transfers.