Privacy Battles
Visitor Analytics
Privacy Score
100
%
⚔️
Abralytics
Privacy Score
28
%

Designated DPO or GDPR correspondent

Compliant
Partially Compliant
Not Compliant

Visitor Analytics has appointed a Data Protection Officer who can be contacted at the following address: dpo@visitor-analytics.io.

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

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:
Germany and Romania (EU)

Storage Facilities:
All analytics data is processed by German cloud provider Hetzner, in Germany.

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

Data is never transferred outside the EU.

If ever, Visitor commits only to transferring personal data outside the EU if an adequate level of data protection is established.

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 providing the same protection level as set out in Visitor’s DPA: https://www.visitor-analytics.io/fileadmin/visitor-analytics/downloads/dpa/20210622_visitor-analytics_data-processing-agreement_en.pdf

Visitor has made public its of subprocessors: https://www.visitor-analytics.io/fileadmin/visitor-analytics/downloads/dpa/20210622_visitor-analytics_data-processing-agreement_en.pdf

Prior to adding new subprocessor or replacing an existing subprocessor, Visitor informs controllers and provides a reasonable deadline for them 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

Visitor commits to notify controllers without undue delay after becoming aware of a security incident, to assist controllers in fulfilling their notification and communication obligations, and to take appropriate measures to mitigate the possible adverse effect of the incident.

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

Visitor Analytics will notify the concerned controller promptly (maximum 5 working days) in writing of any communication received from a data subject relating to its rights and will assist the controller within the scope of its ability to fulfil the request.

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

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

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

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

Compliant
Partially Compliant
Not Compliant

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

Security Policy

Compliant
Partially Compliant
Not Compliant

Visitor has obtained an ISO 27001 certification, for which a security policy is necessary.

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 Hetzner (CCTV, security team, physical access controls, etc.)

Other measures:
Regular data backup, IP address anonymisation (optional), intrusion detection controls, data encryption in transit, data access monitoring, authorization management, employee security training, firewalls, server redundancy, prohibition of permanent workstation storage of personal data.

Compliant
Partially Compliant
Not Compliant

Abralytics doesn’t mention having a security policy.

Data Encryption

Compliant
Partially Compliant
Not Compliant

Data encryption in transit (SSL).

Compliant
Partially Compliant
Not Compliant

Data encryption is never mentioned.

Restriction of access

Compliant
Partially Compliant
Not Compliant

Visitor allows access or processing of personal data  by employees for IT support and maintenance. The internal access to data (e.g., by employees) is regulated through the concept of least privilege.

A special script and encrypted keys are used to access personal data and audits are conducted to ensure controls are enforced.

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

Visitor Analytics is only providing data to each controller based on the Data Processing Agreement signed between the two parties and will not share personal data without the controller’s consent, except under certain limited circumstances, such as when required by law.

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, Visitor doesn’t collect unnecessary cookies.

Cookies collected relate to ignoring a data subject’s visit on a website.

Compliant
Partially Compliant
Not Compliant

YES, Abralytics doesn’t collect cookies.

Submission to Cloud Act/FISA

Compliant
Partially Compliant
Not Compliant

NO, data is stored in the EU by an European cloud provider.

Compliant
Partially Compliant
Not Compliant

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