CDN

Yandex.Cloud CDN

Yandex.Cloud CDN is the content delivery network operated by Yandex, mainly serving Russia and the CIS region, with significant data transfer implications for European websites.

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Overview

What does Yandex.Cloud CDN do?

What Yandex.Cloud CDN is

Yandex.Cloud CDN is the content delivery network of Russian provider Yandex. It distributes static and dynamic resources from edge points of presence and is mainly used to accelerate websites that target Russia and other Russian speaking markets. When a European website routes traffic through this CDN, every request from a European visitor is first sent to a Yandex edge node before the content is served.

Data and cookies processed

Yandex.Cloud CDN itself does not require cookies to operate. The edge nevertheless processes the visitor IP address, request URL, user agent and referrer to deliver content and to apply caching and security rules. Operational logs may be retained for analytics and abuse prevention. Any cookies seen on the page are coming from the origin website, not from the CDN.

GDPR and Schrems II considerations

Russia has no adequacy decision under the GDPR. Sending personal data of EU visitors through Yandex.Cloud CDN therefore qualifies as a transfer to a third country and falls under chapter V of the regulation. The Schrems II case law requires Standard Contractual Clauses, a transfer impact assessment and supplementary measures whenever the destination country lacks an adequacy decision and offers wide intelligence access powers.

Consent and legal basis

Given the transfer profile, the safest approach for an EU site is explicit informed consent before the visitor's requests are routed through Yandex points of presence. Combine this consent with SCCs signed with Yandex.Cloud and document the assessment that justifies the transfer. If consent is refused, fall back to an EU based CDN such as Cloudflare with EU only routing, BunnyCDN or Akamai with EU traffic settings.

Risks and supplementary measures

Russian Federal Law 152 FZ on Personal Data and a series of laws on access by security services significantly limit what supplementary measures can achieve. End to end encryption between visitor and origin reduces exposure of payload data, but the IP address and request metadata seen at the edge are still processed in country. EU data protection authorities have publicly cautioned against routing EU traffic through Russian infrastructure since 2022.

Practical compliance steps

For European audiences, prefer an EU based CDN. If you must use Yandex.Cloud CDN, restrict it to specific geographies, sign SCCs, complete and archive a transfer impact assessment, document the transfer in your privacy notice, and obtain unambiguous consent before the first request reaches the edge. Review the deployment annually and after every major change in Russian legislation.

Compliance

Yandex.Cloud CDN and the GDPR

Yandex.Cloud CDN is classified as “Unclassified”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.

Legal basis: Consent (Art. 6(1)(a) GDPR) for the data transfer to Russia, plus legitimate interest (Art. 6(1)(f)) for the security and routing aspects of CDN delivery
Risk level: high
Applicable regulations: GDPR, ePrivacy Directive, Russian Federal Law 152 FZ on Personal Data, Schrems II case law

Impact assessment (DPIA)

A DPIA is strongly recommended. Yandex.Cloud CDN routes visitor IP addresses, user agents and request metadata through points of presence largely outside the EEA, including Russia, a country without an adequacy decision. Assess transfer risk, document the SCCs in place and decide whether supplementary measures are sufficient or whether an EU based CDN should be preferred.

Sample text for your banner

This site uses Yandex.Cloud CDN to deliver assets faster. Doing so involves transferring your IP address and request metadata to Yandex servers, which may be located in Russia. By accepting, you consent to this transfer to a country without a European Commission adequacy decision.

Cookies and trackers

What Yandex.Cloud CDN sets and contacts

Tracking method: Edge caching of static and dynamic resources via the Yandex.Cloud points of presence; client IP, request URL, user agent and referrer are processed for routing, caching and security purposes
Server location: Yandex.Cloud points of presence located mainly in Russia and the Commonwealth of Independent States, with limited European presence
Cookieless mode available: Yes
Data transferred outside the EU: Russia is not subject to a European Commission adequacy decision. Use of Yandex.Cloud CDN to deliver content to European visitors involves a transfer of personal data outside the EEA that requires Standard Contractual Clauses, a transfer impact assessment and supplementary measures.

Cookies set (2)

Name	Type	Duration	Purpose
yandexuid	Functional / Tracking	10 years	A long lived Yandex visitor identifier that may appear on pages also using Yandex Metrica or Yandex.Auth alongside the CDN.
_ym_uid	Analytics	1 year	Yandex Metrica visitor identifier that frequently coexists with Yandex.Cloud CDN deployments.

Third-party domains contacted (4)

yandex.cloud
cdn.yandexcloud.net
storage.yandexcloud.net
mc.yandex.ru

Questions

Frequently asked questions about Yandex.Cloud CDN

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What cookies does Yandex.Cloud CDN set?

Yandex.Cloud CDN itself does not set client cookies. Any cookie present on a page served through the CDN comes from your origin website or from other third party services embedded in the page.

Do I need consent to use Yandex.Cloud CDN?

For European visitors, yes. Even though no cookies are set by the CDN, sending the visitor IP and request metadata to a Russian operated infrastructure is a transfer to a third country and requires informed consent in addition to SCCs and a transfer impact assessment.

What is the legal basis for using Yandex.Cloud CDN?

Strictly necessary CDN delivery and security relies on legitimate interest under article 6(1)(f) GDPR. The international transfer to Russia, which has no adequacy decision, requires consent under article 6(1)(a) and an article 49 derogation or appropriate safeguards under chapter V.

Does Yandex.Cloud CDN transfer data to Russia or other third countries?

Yes. The bulk of Yandex.Cloud points of presence are located in Russia and the CIS region. EU visitor IP addresses, request URLs and user agents are processed at those edges, which constitutes a third country transfer under the GDPR.

Do I need a DPIA for Yandex.Cloud CDN?

Yes. The combination of a third country transfer, large scale processing of visitor metadata and the risk profile of Russian intelligence access laws meets the thresholds in WP248 and most national DPA guidance, so a DPIA and a documented transfer impact assessment are expected.

How do I implement Yandex.Cloud CDN compliance correctly?

Sign SCCs, complete a transfer impact assessment, configure the CDN to limit logs, enforce TLS, restrict the CDN to non sensitive assets, gate it behind a CMP, document the transfer and offer an EU based fallback whenever consent is refused.

What are the alternatives to Yandex.Cloud CDN for European audiences?

EU friendly options include Cloudflare with EU only routing, BunnyCDN, Fastly with EEA endpoints, KeyCDN, Akamai with EU traffic settings and self hosted edge servers in EU data centres.

How should I update my cookie policy when using Yandex.Cloud CDN?

Add a clear paragraph in your privacy notice explaining that traffic is routed through Yandex points of presence outside the EEA, including Russia. List the categories of metadata processed at the edge, name the safeguards in place and link to the consent mechanism that gates this routing.

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