Privacy Battles
Matomo
Privacy Score
94
%
⚔️
AT Internet
Privacy Score
86
%

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

AT Internet has appointed a Data Protection Officer who can be contacted at the following address: dpo@atinternet.com or by post.

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:
France 🇫🇷  (EU) 🇪🇺

Storage Facilities:
All analytics data is stored in the EU by cloud providers AWS and SFR.

AT Internet however doesn’t specify in which country data is hosted.

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

AT Internet doesn’t transfer analytics data outside the EU.

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

At Internet commits itself to verify that its subcontractors present sufficient guarantees regarding the implementation of technical and organizational measures.

AT Internet has made public its list of subprocessors: https://www.atinternet.com/en/processor-sub-processor-information-parent-company/

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

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

In case of a data breach, AT Internet will notify the controller without undue delay after becoming aware of the breach, and provide the necessary information to notify Data Protection Authorities.

Right Requests Process

Compliant
Partially Compliant
Not Compliant

Data request will be forwarded to the controller without delay.

Compliant
Partially Compliant
Not Compliant

Data request will be forwarded to the controller without delay and assistance will be provided to the controller to answer any request.

Data Privacy Impact Assessment

Compliant
Partially Compliant
Not Compliant

Matomo will provide assistance to the controller for DPIAs.

Compliant
Partially Compliant
Not Compliant

AT Internet will provide necessary assistance to the controller in case of Data Privacy Impact Assessment on an analytics processing activity.

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

Employees are trained on the confidentiality of personal data and subjects to a strict confidentiality obligation.

Security Policy

Compliant
Partially Compliant
Not Compliant

Matomo doesn’t mention having a security policy.

Compliant
Partially Compliant
Not Compliant

AT Internet mentions having a security policy and updating it regularly, but has not made it public.

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

AT Internet mentions having a security policy and updating it regularly, but has not made it public.

Data Encryption

Compliant
Partially Compliant
Not Compliant

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

Compliant
Partially Compliant
Not Compliant

AT Internet never mentions data encryption.

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

AT Internet limits access to data only to persons who need to know and does not share data with third parties without prior demand of the controller.

Reuse of data

Compliant
Partially Compliant
Not Compliant

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

Compliant
Partially Compliant
Not Compliant

AT Internet doesn’t pursue its own purposes with this data processing. The controller stays the data owner.

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, if controller masks the following personal data by default (visitor ID, postal code, internet service provider, converted visit) and anonymizes IP addresses.

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

YES, data hosted on Amazon servers doesn’t appear to be anonymized nor encrypted at rest, therefore can be accessed by an American intelligence agency on demand.