GDPR Compliance
Ovyxa is fully compliant with the EU General Data Protection Regulation (GDPR). This page explains our legal basis, what data we process, and your rights.
Legal Basis for Processing
Legitimate Interest (Article 6(1)(f) GDPR)
Our strict mode operates under legitimate interest as the legal basis:
- Purpose: Audience measurement and website analytics
- Necessity: Data collected is minimal and necessary for analytics
- Balancing test: Visitor privacy rights outweigh our interests, so we:
- Don't collect PII
- Don't track across sites
- Don't store IP addresses
- Provide aggregated data only
This approach has been validated by the French CNIL and other EU authorities for similar privacy-first analytics.
Contract Performance (for our customers)
When you use Ovyxa as a customer:
- Legal basis: Article 6(1)(b) - necessary for service delivery
- We process your account data to provide the analytics service
Data We Process
End-User (Visitor) Data
When someone visits a website using Ovyxa:
| Data Point | Purpose | Retention | Stored? |
|---|---|---|---|
| Page URL | Track pageviews | 6-24 months | Yes |
| Referrer | Identify traffic sources | 6-24 months | Yes |
| IP Address | Derive country only | 0 (RAM only) | No |
| User-Agent | Identify browser/device | 0 (parsed, discarded) | No (categories only) |
| Country Code | Geographic analytics | 6-24 months | Yes |
| Browser Type | Technical analytics | 6-24 months | Yes |
| Device Type | Technical analytics | 6-24 months | Yes |
| OS Family | Technical analytics | 6-24 months | Yes |
| Timestamp | Temporal analytics | 6-24 months | Yes |
Customer (Account) Data
When you create a Ovyxa account:
- Email address (authentication, billing, support)
- Account name (identification)
- Payment information (via Stripe, we don't store credit cards)
- Usage data (plan limits, billing)
Retention: Duration of account + 7 years (tax/legal requirements)
What We DON'T Collect
Explicitly excluded from collection:
- Personal identifiable information (names, emails of visitors)
- Precise geolocation (city, postal code, coordinates)
- Full IP addresses
- Cross-site identifiers
- Biometric data
- Behavioral profiles
- Any special category data (Article 9)
Data Subject Rights
Under GDPR, individuals have the following rights:
Right of Access (Article 15)
For website visitors:
- We don't store PII, so there's no personal data to access
- All data is aggregated and anonymous
For Ovyxa customers:
- Log in to view all your account data
- Export your analytics data anytime
- Contact us for a complete data export
Right to Rectification (Article 16)
Customers: Update your account details in settings
Visitors: No personal data stored to rectify
Right to Erasure (Article 17)
Customers:
- Delete your account in Settings
- All associated data will be deleted within 30 days
- Anonymized analytics may remain (no personal link)
Visitors:
- No personal data stored, nothing to erase
- Site owners can delete all analytics for their site
Right to Restriction (Article 18)
Contact us to restrict processing of your customer data while disputes are resolved.
Right to Data Portability (Article 20)
Export your analytics data in machine-readable formats:
- CSV export
- JSON export via API
- Available for all customers
Right to Object (Article 21)
Website visitors:
- Use Do Not Track (DNT) browser setting (honored by Ovyxa)
- Use ad blockers (we don't circumvent them by default)
- Contact site owner to request exclusion
Customers:
- Delete your account to stop all processing
Data Transfers
No Third-Country Transfers
- All data stored in EU/EEA data centers
- No transfers to USA, UK, or other third countries
- All sub-processors are EU-based (see below)
Sub-Processors
We use the following sub-processors (all EU-based):
| Service Provider | Purpose | Location | Safeguards |
|---|---|---|---|
| OVHcloud | Infrastructure hosting | France | GDPR-compliant DPA |
| Scaleway | Infrastructure hosting | France | GDPR-compliant DPA |
| Stripe | Payment processing | EU instances | Standard Contractual Clauses |
Complete sub-processor list maintained at: [ovyxa.com/subprocessors]
Data Protection Measures
Technical Measures
- Encryption in transit: TLS 1.3 for all connections
- Encryption at rest: Full disk encryption (AES-256)
- Access control: Role-based access, 2FA for staff
- Pseudonymization: IP addresses hashed if used, never stored raw
- Data minimization: Only essential fields collected
Organizational Measures
- Data Protection Officer: Available for GDPR inquiries
- Staff training: All staff trained on GDPR compliance
- Access logging: All data access logged and audited
- Incident response: 72-hour breach notification process
- Regular audits: Annual compliance reviews
Data Processing Agreement (DPA)
All Ovyxa customers act as Data Controllers for their website analytics data.
Ovyxa acts as a Data Processor on behalf of customers.
We provide a Data Processing Agreement that includes:
- Scope and purpose of processing
- Data security obligations
- Sub-processor management
- Data subject rights assistance
- Breach notification procedures
- Audit rights
Download our DPA template or contact sales@ovyxa.com for a signed copy.
Records of Processing Activities
We maintain detailed records as required by Article 30:
- Name and contact details of controller/processor
- Purposes of processing
- Categories of data subjects and personal data
- Categories of recipients
- Data retention periods
- Security measures description
Available upon request from regulatory authorities.
Data Protection Impact Assessment (DPIA)
We've conducted a DPIA for our core analytics processing:
Assessment:
- Systematic monitoring: Yes (analytics)
- Large scale: Potentially yes
- Sensitive data: No
- Innovative technology: No
Risk level: Low
Rationale:
- No PII collected
- No profiling or automated decisions
- Aggregated data only
- Strong technical safeguards
Full DPIA available upon request for enterprise customers.
Breach Notification
In the unlikely event of a data breach:
- Detection: Automated monitoring and alerting
- Assessment: Within 24 hours of detection
- Notification to authority: Within 72 hours (if required)
- Notification to customers: Without undue delay (if high risk)
- Documentation: All breaches logged regardless of severity
Contact: security@ovyxa.com
Exercising Your Rights
For Website Visitors
If you visited a website using Ovyxa:
- Contact the website owner (they control the data)
- Use browser settings (DNT, ad blockers)
- Ovyxa doesn't store your personal data
For Ovyxa Customers
To exercise your rights:
- Email: privacy@ovyxa.com
- In-app: Account Settings > Privacy & Data
- Mail: Ovyxa SAS, [Address], France
We respond within 30 days (GDPR requirement).
Supervisory Authority
Our lead supervisory authority is:
Commission Nationale de l'Informatique et des Libertés (CNIL)
- Address: 3 Place de Fontenoy, 75007 Paris, France
- Website: cnil.fr
- Phone: +33 1 53 73 22 22
You have the right to lodge a complaint with CNIL or your local data protection authority.
Children's Privacy
Ovyxa does not knowingly collect data from children under 16. Website owners are responsible for compliance with local age restrictions.
Changes to This Policy
We will notify customers of material changes to our data processing:
- Email notification (30 days advance notice)
- In-app notification
- Updated version number and "last updated" date
Contact Us
Data Protection Officer:
- Email: dpo@ovyxa.com
- Mail: Ovyxa SAS, ATTN: DPO, [Address], France
General Privacy Questions:
- Email: privacy@ovyxa.com
- Documentation: ovyxa.com/docs/privacy
We're committed to transparency and compliance. If you have questions about our GDPR compliance, please reach out.