Privacy Battles
Swetrix
Privacy Score
64
%
⚔️
AT Internet
Privacy Score
86
%

Designated DPO or GDPR correspondent

Compliant
Partially Compliant
Not Compliant

Swetrix doesn't mention having a DPO or GDPR correspondent but has a privacy dedicated email contact available on its website: contact@swetrix.com.

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.

Privacy Policy

Country & Type of Data storage

Compliant
Partially Compliant
Not Compliant

Company Headquarters:

Ukraine

Storage Facilities:

Analytics data is stored in German by US cloud provider Cloudflare.

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

Data is deemed not transferred outside the EU.

If ever, Swetrix commits only to transferring personal data outside the EU if adequate security controls are in place.

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 the same protection level as set out in Swetrix’s Privacy Policy: https://swetrix.com/privacy 

Swetrix has made public its list of subprocessors: https://swetrix.com/privacy 

Swetrix doesn’t specify if written contracts are signed with subcontractors, nor if they inform controllers about adding a new subcontractor to the analytics service.

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

Swetrix 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.

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

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

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

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

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

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

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

Swetrix 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 Cloudflare.

Other measures:

Data pseudonymisation (salted hash), data backups, data encryption.

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).

Compliant
Partially Compliant
Not Compliant

AT Internet never mentions data encryption.

Restriction of access

Compliant
Partially Compliant
Not Compliant

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

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

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

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, Swetrix analytics script is fully cookieless.

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, data is hashed and not stored on servers more than 30min.

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.