Privacy Battles
Matomo
Privacy Score
94
%
⚔️
Abralytics
Privacy Score
28
%

Designated DPO or GDPR correspondent

Compliant
Partially Compliant
Not Compliant

DPO is external. It is ePrivacy GmbH who can be reached on privacy@matomo.org or by post.

Compliant
Partially Compliant
Not Compliant

Abralytics doesn't mention having a DPO or GDPR correspondent and doesn’t display a privacy dedicated contact channel.

Privacy Policy

Compliant
Partially Compliant
Not Compliant
Compliant
Partially Compliant
Not Compliant

Regarding website and cloud: https://www.abralytics.com/privacy

It is unclear whether the privacy policy available on Abralytics website applies both for the website and cloud service.

Besides, it doesn’t provide sufficient information to data subjects regarding Article 13 and 14 of the GDPR (data retention periods, legal basis, etc.).

Country & Type of Data storage

Compliant
Partially Compliant
Not Compliant

Company Headquarters:
New Zealand 🇳🇿

Storage Facilities:
Servers, databases and logs are hosted in Frankfurt, Germany (cloud provider is AWS New Zealand). Offsite backups are stored in Dublin, Ireland.

Possibility to host Matomo Analytics on client premises.

Compliant
Partially Compliant
Not Compliant

Company Headquarters:

Ireland (EU)

Storage Facilities:

Data is hosted in the EU but Abralytics doesn’t specify in which country, nor which external cloud provider it uses and what is its nationality.

Data transfers outside the EU

Compliant
Partially Compliant
Not Compliant

The adequate level of protection in New Zealand has been approved by the European Commission.

Every transfer of personal data by Matomo to a country which is not a member state of either the EU or the EEA is submitted to prior consent of the controller.

Compliant
Partially Compliant
Not Compliant

Data is deemed not transferred outside the EU, but that information needs to be verified (cloud provider and its nationality are unknown).

Legal tools for Subcontractors

Compliant
Partially Compliant
Not Compliant

Subcontractors are subjects to written agreements substantially similar to Matomo’s DPA: https://fr.matomo.org/matomo-cloud-dpa/

Matomo has made public its list of subprocessors: https://fr.matomo.org/matomo-cloud-privacy-policy/

Prior to modifying the list of subprocessors, the controller will be notified by email and is able to object.

Compliant
Partially Compliant
Not Compliant

Abralytics doesn’t mention any subcontractors nor its process to contract with them.

Data Breach Notification

Compliant
Partially Compliant
Not Compliant

In case of data breach, Matomo will inform without undue delay the controller by email and provide a description of the incident as well as periodic updates, including the impact on the controller.

Compliant
Partially Compliant
Not Compliant

Abralytics doesn’t mention directly notifying controllers of a data breach in a determined delay, nor providing assistance to controllers to notify the breach to the Supervisory authority.

Right Requests Process

Compliant
Partially Compliant
Not Compliant

Data request will be forwarded to the controller without delay.

Compliant
Partially Compliant
Not Compliant

Abralytics doesn’t mention providing assistance to controllers in case of a data subject's right request.

Data Privacy Impact Assessment

Compliant
Partially Compliant
Not Compliant

Matomo will provide assistance to the controller for DPIAs.

Compliant
Partially Compliant
Not Compliant

Abralytics doesn’t specify having conducted DPIAs or providing assistance to controllers if needed.

Employee Trainings

Compliant
Partially Compliant
Not Compliant

All employees required to access the personal data are deemed informed of the confidential nature of the personal data.

Compliant
Partially Compliant
Not Compliant

Abralytics doesn't mention employee training or submission to NDAs.

Security Policy

Compliant
Partially Compliant
Not Compliant

Matomo doesn’t mention having a security policy.

Compliant
Partially Compliant
Not Compliant

Abralytics doesn’t mention having a security policy.

Organizational and Technical Security Measures

Compliant
Partially Compliant
Not Compliant

Server security:
Cloud security relying on Amazon New Zealand.

Other measures:
Users authentication, authorization management, virtual private cloud implementation, firewall rules, bug bounty program, security trainings for employees, encrypted data in transit (HTTPS) and at rest, access journaling and alerting, security incidents tracking, replication of data backups.

Compliant
Partially Compliant
Not Compliant

Abralytics doesn’t mention having a security policy.

Data Encryption

Compliant
Partially Compliant
Not Compliant

Data is encrypted in transit (HTTPS) and at rest.

Compliant
Partially Compliant
Not Compliant

Data encryption is never mentioned.

Restriction of access

Compliant
Partially Compliant
Not Compliant

A subset of employees has access to the products and to personal data via controlled interfaces. Access is enabled through “just in time” requests for access; all such requests are logged.

Backend production environment is accessible by a dedicated group of Privileged Users approved by senior management. Privileged Users may only access backend production environment via a bastion host (2 factor authentication and SSH to log in).

Compliant
Partially Compliant
Not Compliant

Abralytics doesn’t mention any specific restrictions of access to personal data.

Reuse of data

Compliant
Partially Compliant
Not Compliant

Matomo does not pursue its own purposes with this data processing.

Compliant
Partially Compliant
Not Compliant

Abralytics doesn’t sell any data. Controllers stay owners of personal data.

Exemption of cookie consent

Compliant
Partially Compliant
Not Compliant

YES, if controller disables « cross domain tracking » and « third party cookies » functionalities.

Compliant
Partially Compliant
Not Compliant

YES, Abralytics doesn’t collect cookies.

Submission to Cloud Act/FISA

Compliant
Partially Compliant
Not Compliant

NO, when data is stored on controller premise.

NO, if controller enables data anonymization when using the Cloud solution.

Compliant
Partially Compliant
Not Compliant

NO, data is stored in the EU and anonymized (therefore no more considered personal).