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• How should I write my privacy notice for Matomo Analytics under GDPR ?

  24 avril 2018, par InnoCraft

  Important note : this blog post has been written by digital analysts, not lawyers. The purpose of this article is to show you an example of a privacy notice for Matomo under GDPR. This work comes from our interpretation of the UK privacy commission : ICO. It cannot be considered as professional legal advice. So as GDPR, this information is subject to change. We strongly advise you to have a look at the different privacy authorities in order to have up to date information.

  A basic rule of thumb is that if you are not processing personal data, then you do not need to show any privacy notice. But if you are doing so, such as processing full IP addresses, then a privacy notice is required at the time of the data collection. Please note that personal data may also be hidden, for example, in page titles or page URLs.

  In this blog post, we will define what a privacy notice is according to GDPR and how to write it if you are using Matomo and you are processing personal data.

  What is a privacy notice under GDPR ?

  One of the most important rights that a data subject has under GDPR, is the right to be informed about the collection and use of their personal data.

  Here is what ICO is saying about the privacy notice :

  “You must provide individuals with information including : your purposes for processing their personal data, your retention periods for that personal data, and who it will be shared with. We call this ‘privacy information’.”

  “When you collect personal data from the individual it relates to, you must provide them with privacy information at the time you obtain their data.”

  Note that a privacy notice is different from a privacy policy.

  The privacy notice has to include :

  • the reasons why you are processing the personal data
  • for how long
  • who the different parties you are going to share them with are

  So whatever lawful basis you are using (explicit consent or legitimate interest), you need to have a privacy notice if you collect personal data.

  What does this privacy notice look like ?

  ICO is providing best practices in order to display the information :

  • a layered approach
  • dashboards
  • just-in-time notices
  • icons
  • mobile and smart device functionalities

  Once more, it really depends on the data you are processing with Matomo. If you wish to track personal data on the entire website, you will probably have an upper or footer privacy notice such as :

  

  If you wish to process specific data, you could also insert just-in-time notices such as :

  

  What is the information you need to disclose to the final user ?

  To us, there are two things to distinguish between the privacy notice and the privacy policy.

  According to ICO, the privacy notice needs to include the 3 following elements :

  • the reasons why you are processing the personal data
  • for how long
  • who are the different parties you are going to share them with

  But you also need to inform them about :

  • The name and contact details of your organisation.
  • The name and contact details of your representative (if applicable).
  • The contact details of your data protection officer (if applicable).
  • The purposes of the processing.
  • The lawful basis for the processing.
  • The legitimate interests for the processing (if applicable).
  • The categories of personal data obtained (if the personal data is not obtained from the individual it relates to).
  • The recipients or categories of recipients of the personal data.
  • The details of transfers of the personal data to any third countries or international organisations (if applicable).
  • The retention periods for the personal data.
  • The rights available to individuals in respect of the processing.
  • The right to withdraw consent (if applicable).
  • The right to lodge a complaint with a supervisory authority.
  • The source of the personal data (if the personal data is not obtained from the individual it relates to).
  • The details of whether individuals are under a statutory or contractual obligation to provide the personal data (if applicable, and if the personal data is collected from the individual it relates to).
  • The details of the existence of automated decision-making, including profiling (if applicable).

  Pretty long, don’t you think ? In order to reduce it, you can either adopt a layered approach where your “pop-up” window will act as a drop down menu. Or from what we understood, page 5 of this document provided by ICO, a privacy notice can link to a more detailed document, such as a privacy policy page.

  Examples

  Let’s take the example of a website which tracks the non-anonymised full IP address, and using User ID functionality to keep track of logged-in users. Under GDPR, the owner of the website will have to choose either to process personal data based on “Legitimate interests” or on “Consent”. Here is how it will look like :

  Example of a privacy notice under GDPR Legitimate interests

  This site uses Matomo to analyze traffic and help us to improve your user experience.

  We process your email address and IP address and cookies are stored on your browser for 13 months. This data is only processed by us and our web hosting platform. Please read our Privacy Policy to learn more.

  Example of a privacy notice under GDPR Consent

  This site uses Matomo to analyze traffic and help us to improve your user experience.

  We process your email address and IP address and cookies are stored on your browser for 13 months. This data is only processed by us and our web hosting platform.

  [Accept] or [Opt-out]

  Please read our Privacy Policy to learn more.

  Once that information is provided to the user, you can then link it to your privacy policy where you will provide more details about it. Soon we will issue a blog post dealing with how to write a privacy policy page for Matomo.

  The post How should I write my privacy notice for Matomo Analytics under GDPR ? appeared first on Analytics Platform - Matomo.

• 11 ways Piwik Analytics helps you to protect your visitors privacy

  11 janvier 2017, par InnoCraft — Community

  At Piwik and at InnoCraft, we think Privacy matters. From the beginning, Piwik has had a strong focus on privacy and ensures the privacy of your visitors and analytics data. As a result, Piwik has been recommended as a privacy-compliant analytics tool for example by the Independent Center for Privacy Protection in Germany (ULD) and by the Center for Data Privacy Protection in France (CNIL). In France, Piwik is the only web analytics tool that does not require Cookie Consent.

  Here are some ways how you can ensure your users and visitors privacy by using Piwik.

  1. You own the data

  Whether you host Piwik on premise yourself, managed on premise by InnoCraft, or whether you use our Piwik cloud, when you use Piwik, YOU keep control of your data and nobody else. This also means you can decide where your data should be located physically.

  2. Anonymized IP addresses

  For better privacy by default, Piwik will not record the full IP address of your visitors because otherwise the browsing history could be easily tracked across several days and even across websites within the same Piwik server. Some countries even require to anonymize the IP address, considered Personally Identifiable Information (PII).

  To change the IP anonymization settings go to “Administration > Privacy”. Optionally, you can use the full IP to still get for example accurate location data.

  

  3. Delete old visitor logs

  The visitor logs contain information all the collected raw data about every visitor and every action. You can configure Piwik to automatically delete logs from the database. When you delete old logs, only the real time and visitor log reports will no longer work for this old time period, all other aggregated reports will still work.

  For privacy reasons, we highly recommend that you keep the detailed Piwik logs for only 3 to 6 months and delete older log data. This has one other nice side effect : it will free significant database space, which will, in turn, slightly increase performance !

  

  4. Support Do Not Track preference

  Do Not Track enables users to opt out of any tracking by websites they do not visit, including analytics services, advertising networks, and social platforms. By default, Piwik respects users preference and will not track visitors which have specified “I do not want to be tracked” in their web browsers. Get more information about DoNotTrack.

  To make sure Do Not Track is respected, go to “Administration => Privacy”.

  5. Include an Opt-Out Feature on your website or app

  By embedding the Opt-Out feature in your website, you give your visitors the possibility to opt-out of the tracking. When you go to “Administration > Privacy”, you will be able to copy and paste an HTML Iframe code to embed the opt-out feature for example into your privacy policy page or in your ‘Legal’ page. Your users can then click on a link to opt-out.

  On the Piwik Marketplace there are also some plugins available to customize the Opt-Out experience. For example AjaxOptOut and CustomOptOut.

  

  6. Disable Live features

  The Real-Time, Visitor Log and Visitor Profile features give you insights into the tracked raw data by showing you details about every visitor and every action they performed. To protect the privacy of your visitors you may decide to prevent access to such features by disabling the “Live” plugin in “Administration => Plugins”. This way only aggregated reports will be shown in your Piwik.

  7. Disable fingerprinting across websites

  By default, when one of your visitors visits several of your websites, Piwik will create a fingerprint for this user that will be different across the websites to increase the visitors’ privacy. You can make sure that this feature is disabled by going to “Administration => Config file” and verifying that the value of “enable_fingerprinting_across_websites” is set to zero.

  8. Disable tracking cookies

  Piwik uses cookies to store some information about visitors between visits. In some countries, the legislation requires websites to provide a way for users to opt-out of all tracking, in particular tracking cookies. You can disable cookies by adding one line in the Piwik Javascript code.

  9. Custom development

  Piwik is an open platform that lets you extend and customize the tracking, the reporting and the Piwik user interface to your needs and to protect your visitors’ privacy the way you want or need it. Learn more in the Piwik Developer Zone. You may also have a look at our Piwik Marketplace where you can find several free and premium features to extend your Piwik.

  10. Transparency

  By default, all information and all collected data in your Piwik server are protected and nobody can access it. However, Piwik allows you to optionally make your collected data public and you can export any Piwik report including the whole dashboard to embed it into your website. This way you can show your users exactly which information you track. When you decide to make reports public, we do our best to protect privacy and automatically hide any Personally Identifiable Information such as the Visitor Profile and we make sure to not show any Visitor IP address and the Visitor ID.

  11. Privacy policy

  When you use Piwik to track your visitors, we recommend to update your Privacy Policy to explain how Piwik is used and what data it gathers. We provide a Privacy Policy template for Piwik users that you can copy on your site.

  Continuous privacy improvements

  We are always interested in improving the privacy. If you miss any feature or have an idea on how to improve the privacy, please let us know.

  More information about all the Piwik features

  If you want to learn more about all the features in Piwik, have a look at our User Guides and FAQ entries.

• Cortex-A7 instruction cycle timings

  15 mai 2014, par Mans — ARM

  The Cortex-A7 ARM core is a popular choice in low-power and low-cost designs. Unfortunately, the public TRM does not include instruction timing information. It does reveal that execution is in-order which makes measuring the throughput and latency for individual instructions relatively straight-forward.

  The table below lists the measured issue cycles (inverse throughput) and result latency of some commonly used instructions.

  It should be noted that in some cases, the perceived latency depends on the instruction consuming the result. Most of the values were measured with the result used as input to the same instruction. For instructions with multiple outputs, the latencies of the result registers may also differ.

  Finally, although instruction issue is in-order, completion is out of order, allowing independent instructions to issue and complete unimpeded while a multi-cycle instruction is executing in another unit. For example, a 3-cycle MUL instruction does not block ADD instructions following it in program order.

  ALU instructions	Issue cycles	Result latency
  MOV Rd, Rm	1/2	1
  ADD Rd, Rn, #imm	1/2	1
  ADD Rd, Rn, Rm	1	1
  ADD Rd, Rn, Rm, LSL #imm	1	1
  ADD Rd, Rn, Rm, LSL Rs	1	1
  LSL Rd, Rn, #imm	1	2
  LSL Rd, Rn, Rs	1	2
  QADD Rd, Rn, Rm	1	2
  QADD8 Rd, Rn, Rm	1	2
  QADD16 Rd, Rn, Rm	1	2
  CLZ Rd, Rm	1	1
  RBIT Rd, Rm	1	2
  REV Rd, Rm	1	2
  SBFX Rd, Rn	1	2
  BFC Rd, #lsb, #width	1	2
  BFI Rd, Rn, #lsb, #width	1	2
  NOTE : Shifted operands and shift amounts needed one cycle early.
  Multiply instructions	Issue cycles	Result latency
  MUL Rd, Rn, Rm	1	3
  MLA Rd, Rn, Rm, Ra	1	31
  SMULL Rd, RdHi, Rn, Rm	1	3
  SMLAL Rd, RdHi, Rn, Rm	1	31
  SMMUL Rd, Rn, Rm	1	3
  SMMLA Rd, Rn, Rm, Ra	1	31
  SMULBB Rd, Rn, Rm	1	3
  SMLABB Rd, Rn, Rm, Ra	1	31
  SMULWB Rd, Rn, Rm	1	3
  SMLAWB Rd, Rn, Rm, Ra	1	31
  SMUAD Rd, Rn, Rm	1	3
  1 Accumulator forwarding allows back to back MLA instructions without delay.
  Divide instructions	Issue cycles	Result latency
  SDIV Rd, Rn, Rm	4-20	6-22
  UDIV Rd, Rn, Rm	3-19	5-21
  Load/store instructions	Issue cycles	Result latency
  LDR Rt, [Rn]	1	3
  LDR Rt, [Rn, #imm]	1	3
  LDR Rt, [Rn, Rm]	1	3
  LDR Rt, [Rn, Rm, lsl #imm]	1	3
  LDRD Rt, Rt2, [Rn]	1	3-4
  LDM Rn, regs	1-8	3-10
  STR Rt, [Rn]	1	2
  STRD Rt, Rt2, [Rn]	1	2
  STM Rn, regs	1-10	2-12
  NOTE : Load results are forwarded to dependent stores without delay.
  VFP instructions	Issue cycles	Result latency
  VMOV.F32 Sd, Sm	1	4
  VMOV.F64 Dd, Dm	1	4
  VNEG.F32 Sd, Sm	1	4
  VNEG.F64 Dd, Dm	1	4
  VABS.F32 Sd, Sm	1	4
  VABS.F64 Dd, Dm	1	4
  VADD.F32 Sd, Sn, Sm	1	4
  VADD.F64 Dd, Dn, Dm	1	4
  VMUL.F32 Sd, Sn, Sm	1	4
  VMUL.F64 Dd, Dn, Dm	4	7
  VMLA.F32 Sd, Sn, Sm	1	81
  VMLA.F64 Dd, Dn, Dm	4	112
  VFMA.F32 Sd, Sn, Sm	1	81
  VFMA.F64 Dd, Dn, Dm	5	82
  VDIV.F32 Sd, Sn, Sm	15	18
  VDIV.F64 Dd, Dn, Dm	29	32
  VSQRT.F32 Sd, Sm	14	17
  VSQRT.F64 Dd, Dm	28	31
  VCVT.F32.F64 Sd, Dm	1	4
  VCVT.F64.F32 Dd, Sm	1	4
  VCVT.F32.S32 Sd, Sm	1	4
  VCVT.F64.S32 Dd, Sm	1	4
  VCVT.S32.F32 Sd, Sm	1	4
  VCVT.S32.F64 Sd, Dm	1	4
  VCVT.F32.S32 Sd, Sd, #fbits	1	4
  VCVT.F64.S32 Dd, Dd, #fbits	1	4
  VCVT.S32.F32 Sd, Sd, #fbits	1	4
  VCVT.S32.F64 Dd, Dd, #fbits	1	4
  1 5 cycles with dependency only on accumulator. 2 8 cycles with dependency only on accumulator.
  NEON integer instructions	Issue cycles	Result latency
  VADD.I8 Dd, Dn, Dm	1	4
  VADDL.S8 Qd, Dn, Dm	2	4
  VADD.I8 Qd, Qn, Qm	2	4
  VMUL.I8 Dd, Dn, Dm	2	4
  VMULL.S8 Qd, Dn, Dm	2	4
  VMUL.I8 Qd, Qn, Qm	4	4
  VMLA.I8 Dd, Dn, Dm	2	4
  VMLAL.S8 Qd, Dn, Dm	2	4
  VMLA.I8 Qd, Qn, Qm	4	4
  VADD.I16 Dd, Dn, Dm	1	4
  VADDL.S16 Qd, Dn, Dm	2	4
  VADD.I16 Qd, Qn, Qm	2	4
  VMUL.I16 Dd, Dn, Dm	1	4
  VMULL.S16 Qd, Dn, Dm	2	4
  VMUL.I16 Qd, Qn, Qm	2	4
  VMLA.I16 Dd, Dn, Dm	1	4
  VMLAL.S16 Qd, Dn, Dm	2	4
  VMLA.I16 Qd, Qn, Qm	2	4
  VADD.I32 Dd, Dn, Dm	1	4
  VADDL.S32 Qd, Dn, Dm	2	4
  VADD.I32 Qd, Qn, Qm	2	4
  VMUL.I32 Dd, Dn, Dm	2	4
  VMULL.S32 Qd, Dn, Dm	2	4
  VMUL.I32 Qd, Qn, Qm	4	4
  VMLA.I32 Dd, Dn, Dm	2	4
  VMLAL.S32 Qd, Dn, Dm	2	4
  VMLA.I32 Qd, Qn, Qm	4	4
  NEON floating-point instructions	Issue cycles	Result latency
  VADD.F32 Dd, Dn, Dm	2	4
  VADD.F32 Qd, Qn, Qm	4	4
  VMUL.F32 Dd, Dn, Dm	2	4
  VMUL.F32 Qd, Qn, Qm	4	4
  VMLA.F32 Dd, Dn, Dm	2	81
  VMLA.F32 Qd, Qn, Qm	4	81
  1 5 cycles with dependency only on accumulator.
  NEON permute instructions	Issue cycles	Result latency
  VEXT.n Dd, Dn, Dm, #imm	1	4
  VEXT.n Qd, Qn, Qm, #imm	2	5
  VTRN.n Dd, Dn, Dm	2	5
  VTRN.n Qd, Qn, Qm	4	5
  VUZP.n Dd, Dn, Dm	2	5
  VUZP.n Qd, Qn, Qm	4	6
  VZIP.n Dd, Dn, Dm	2	5
  VZIP.n Qd, Qn, Qm	4	6
  VTBL.8 Dd, Dn, Dm	1	4
  VTBL.8 Dd, Dn-Dn+1, Dm	1	4
  VTBL.8 Dd, Dn-Dn+2, Dm	2	5
  VTBL.8 Dd, Dn-Dn+3, Dm	2	5