Privacy Battles
Simple Analytics
Privacy Score
94
%
⚔️
Google Analytics
Privacy Score
50
%

Designated DPO or GDPR correspondent

Compliant
Partially Compliant
Not Compliant

Simple Analytics doesn’t process personal data, therefore does not have to designate a DPO.

Simple has a privacy dedicated email contact available on the website: privacyquestions@simpleanalytics.com

Compliant
Partially Compliant
Not Compliant

Google doesn't mention having a DPO but has a privacy dedicated help center which contact is available on its website: https://support.google.com/policies/answer/9581826?hl=en&visit_id=637842217867882507-4117401368&rd=1 

Privacy Policy

Compliant
Partially Compliant
Not Compliant

Regarding cloud:
A Cloud Privacy Policy is not necessary as no personal data is processed in the Cloud.

Regarding website:
https://simpleanalytics.com/privacy-policy

Compliant
Partially Compliant
Not Compliant

Regarding cloud & website: https://policies.google.com/privacy 

This policy however covers a broad scope that includes various Google applications and services (including Analytics), that makes it difficult to apprehend for both controllers and data subjects.

Country & Type of Data storage

Compliant
Partially Compliant
Not Compliant

Company Headquarters:
The Netherlands 🇳🇱  (EU) 🇪🇺

Storage Facilities:
All analytics data is processed by Dutch cloud providers Worldstream and Leaseweb.

Compliant
Partially Compliant
Not Compliant

Company Headquarters:
Ireland (EU)

Storage Facilities:
Google has cloud servers all over the world but (except for the US) doesn’t specify in which countries.

Data transfers outside the EU

Compliant
Partially Compliant
Not Compliant

Data is never transferred outside the EU.

Compliant
Partially Compliant
Not Compliant

Personal data is transferred outside the European Union whether this transfers are based on Adequacy decisions of the European Commission or Standard contractual clauses (SCCs).

However, SCCs have been deemed insufficient when transferring personal data to US servers by the European Court of Justice. This entails the necessity for complementary data protection measures. However, the French Data Protection Authority (CNIL) has considered complementary measures put in place by Google (User ID pseudonymisation, IP addresses anonymisation, etc.) not efficient enough for data protection against intelligence agencies.

Legal tools for Subcontractors

Compliant
Partially Compliant
Not Compliant

Simple has only one subcontractor for CDN that is called BunnyCDN and is part of a company called BunnyWay, located in Slovenia (EU). They have concluded a written agreement protecting personal data processed on BunnyCDN's part.

Compliant
Partially Compliant
Not Compliant

Subcontractors are subjects to written agreements substantially similar to Google’s DPA: https://business.safety.google/intl/en/adsprocessorterms/

Google has made public its list of subprocessors:
https://business.safety.google/intl/en/adssubprocessors/

Before onboarding subprocessors, Google conducts an audit of the security and privacy practices of subprocessors to ensure they provide a level of security and privacy appropriate to their access to data and the scope of the services they are engaged to provide.

‍30 days prior to modifying the list of subprocessors, the controller will be notified by email and is able to object by terminating the contract.

Data Breach Notification

Compliant
Partially Compliant
Not Compliant

Simple shares technical incidents on its website: https://status.simpleanalytics.com/?ref=simpleanalytics.com

Simple doesn’t process personal data and therefore a data breach cannot be materialized nor notified.

Compliant
Partially Compliant
Not Compliant

If Google becomes aware of a Data Incident, Google will notify controllers promptly and without undue delay; and promptly take reasonable steps to minimise harm and secure personal data. Google will deliver its notification by email, phone call or an in-person meeting.

Right Requests Process

Compliant
Partially Compliant
Not Compliant

Simple doesn’t process personal data therefore does not have to fulfill this GDPR obligation.

Compliant
Partially Compliant
Not Compliant

Rights of deletion and portability can be fulfilled by the controllers directly through the SaaS.

If Google receives a request from a data subject, controllers authorize Google to answer directly to the data subject’s request or to advise the data subject to submit their request to the appropriate controller.

Google commits to assist controllers in fulfilling their obligations to respond to requests for exercising the data subject’s rights.

Data Privacy Impact Assessment

Compliant
Partially Compliant
Not Compliant

Simple doesn’t process personal data therefore does not have to fulfill this GDPR obligation.

Compliant
Partially Compliant
Not Compliant

Google assists controllers in ensuring compliance with their obligations in respect of DPIAs and prior consultation.

Employee Trainings

Compliant
Partially Compliant
Not Compliant

Simple doesn't process personal data and therefore is not obliged by the GDPR to have its employees subject to confidentiality obligations and trainings on personal data management.

Compliant
Partially Compliant
Not Compliant

Google ensures all persons authorised to process personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

Security Policy

Compliant
Partially Compliant
Not Compliant

Simple doesn’t mention having a security policy.

Compliant
Partially Compliant
Not Compliant

Google has obtained and maintained an ISO 27001 certification, for which a security policy is necessary.

Organizational and Technical Security Measures

Compliant
Partially Compliant
Not Compliant

Server security:
Cloud security relies on Worldstream and Leaseweb.

Other measures:
Anonymisation and pseudonymisation of data, password encryption, backups on external servers.

Compliant
Partially Compliant
Not Compliant

Google has obtained and maintained an ISO 27001 certification, for which a security policy is necessary.

Data Encryption

Compliant
Partially Compliant
Not Compliant

Data is encrypted at rest.

Compliant
Partially Compliant
Not Compliant

Data encryption in transit (HTTPS) and at rest (AES256).

Restriction of access

Compliant
Partially Compliant
Not Compliant

Simple doesn’t process personal data therefore does not have to fulfill this GDPR obligation.

Compliant
Partially Compliant
Not Compliant

Access to data by employees, contractors, and subcontractors is limited by strict access controls (authentication procedures, SSL, and security logs), restricting access only to authorized users.

Reuse of data

Compliant
Partially Compliant
Not Compliant

Swetrix doesn’t reuse personal data, nor sell it.

Compliant
Partially Compliant
Not Compliant

Google shares personal data between its multiple service platforms (Adsense, etc.).

Concerning third parties, Google states it will not use or disclose any confidential information belonging to controllers without their prior written consent, except to fulfill its obligations under this Agreement or as required by law, regulation or court order.

Exemption of cookie consent

Compliant
Partially Compliant
Not Compliant

YES, Simple doesn’t set any cookies.

Compliant
Partially Compliant
Not Compliant

NO, by default Google collects cookies and therefore visitors’ consent is necessary.

Submission to Cloud Act/FISA

Compliant
Partially Compliant
Not Compliant

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

Compliant
Partially Compliant
Not Compliant

YES, even though Google offers an anonymisation option for IP addresses that can be activated by controllers, other personal data is still transferred on US servers by default (user ID, cookies).

Also, Google publishes a Transparency Report which is a list of demands based on FISA made by intelligence agencies:
https://transparencyreport.google.com/user-data/us-national-security