Privacy Battles
Visitor Analytics
Privacy Score
100
%
⚔️
AT Internet
Privacy Score
86
%

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

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:
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:
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 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

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 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

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

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

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

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

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

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

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

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

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

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

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 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

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 encryption in transit (SSL).

Compliant
Partially Compliant
Not Compliant

AT Internet never mentions data encryption.

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

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

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

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, 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, 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 stored in the EU by an European cloud provider.

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.