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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.

• How to not process any personal data with Matomo and what it means for you

  22 avril 2018, par InnoCraft

  Disclaimer : this blog post has been written by digital analysts, not lawyers. The purpose of this article is to explain how to not process any personal data with Matomo in order to avoid going through the GDPR compliance process with Matomo analytics. This work comes from our interpretation of different sources : the official GDPR text and the UK privacy commission : ICO resources. It cannot be considered as a professional legal advice. So as GDPR, this information is subject to change. GDPR may be also known as RGPD in French, Spanish, Portuguese, Datenschutz-Grundverordnung, DS-GVO in German, Algemene verordening gegevensbescherming in Dutch, Regolamento generale sulla protezione dei dati in Italian.

  Are you looking for a way to not process any personal data with Matomo ? If the answer is yes, you are at the right place. From our understanding, if you are not processing personal data, then you shouldn’t be concerned about GDPR. Our inspiration came from this official reference :

  “The principles of data protection should therefore not apply to anonymous information, namely information which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable. This Regulation does not therefore concern the processing of such anonymous information, including for statistical or research purposes.“

  In this blog post we are going to see how you can configure Matomo in order to not process any personal data and what the consequences are.

  Which data is considered as personal according to GDPR ?

  From : eur-lex.europa.eu

  (1) “‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’) ; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person ;”

  (30) “Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identification tags. This may leave traces which, in particular when combined with unique identifiers and other information received by the servers, may be used to create profiles of the natural persons and identify them.”

  So according to your Matomo configuration, it may leave some traces within the following data :

  1. IP addresses
  2. Cookies identifiers
  3. Page URL or page titles
  4. User ID and Custom “personal” data
  5. Ecommerce order IDs
  6. Location
  7. Heatmaps & Session Recordings

  Let’s see each of them in more detail.

  1. IP addresses

  IP addresses can indirectly identify an individual. It can also give a good approximation of an individual’s location.

  IP addresses are therefore considered as personal data which means you need to anonymize them. To do so, a feature is available within Matomo, where you can anonymize the IP. We recommend you to anonymize at least the last two bytes :

  

  See our configuration guide for more information

  What are the consequences of using this feature ?

  When applying IP anonymization on two bytes, you will no longer be able to see the full IP in the UI.

  Moreover, there is a small chance that 2 different visitors with the same device and software configuration will be identified as the same visitor if the anonymised IP address is the same for both.

  2. Cookies

  It is not clear for us yet if all cookies are considered equal under GDPR. At this stage it is too early to make a definite decision.

  Did you know ? Matomo lets you optionally disable the creation of cookies by adding an extra line of code to your tracking code see below.

  

  See our configuration guide for more information

  What are the consequences of using this feature ?

  Matomo is using a few first party cookies, and the following cookies may hold personal data :

  • _pk_id : contains a visitor id used to identify unique visitors
  • _pk_ref : to identify from where they came from

  If Matomo cannot set cookies, it will use a technique called Fingerprint. It is based on several metadata such as the operating system, browser, browser plugins, IP address, browser language ; just to name a few to identify a unique visitor. As this feature is less accurate than the one using cookies, the number of visitors and visits will be affected.

  3. Page URLs and page titles

  URLs are not mentioned within the official GDPR text. However, we know that according to the different CMS you use, some of them may have URLs including personal identifiers.

  For example :

  

  As a result, you need to find a way to anonymize this data.

  There are several ways you can perform this action according to your website. If your website is adding the personal data through query parameters, you can define a rule to exclude them from Matomo.

  If the personal data are not included within query parameters, you can use the “setCustomURL” feature and write your code as follow :

  

  See our developer documentation for more information

  If you are also processing personal data within the title tag, you can use the following function : “setDocumentTitle”.

  What are the consequences of using this feature ?

  By anonymizing the URLs containing personal data, some of your  URLs will be grouped together.

  4. User ID and custom personal data

  User ID is a feature (a tracking code needs to be added) which allows you to identify the same user across different devices.

  A User ID needs a corresponding database in order to link a user across different devices, it can be an email, a username, a name, a random number… All those data are either direct or non direct online identifiers and are therefore under the scope of GDPR.

  It will be the same situation if you are using custom variables and/or custom dimensions in order to push personal data to the system.

  To continue using the User ID feature but not recording personal data, you can consider using a hash function which will anonymize/convert your actual User ID into something like “3jrj3j34434834urj33j3”.

  Alternatively, you can enable the feature “Anonymise User IDs”. This feature will be available starting in Matomo 3.5.0 :

  

  What are the consequences of using this feature ?

  Under GDPR, User ID is personal data. Anonymizing the User ID using a hash function or our built-in functionality make the User Id pseudo-anonymous, which means it can’t be easily identified to a specific user. As a result, you will still get accurate visits and unique visitors metrics, and the Visitor Profile, but without tracking the original User ID which is personal data.

  5. Ecommerce order IDs

  Order IDs are the reference number assigned to the products/services bought by your customers. As this information can be crossed with your internal database, it is considered as an online identifier and is therefore under the scope of GDPR. As for User ID, you can anonymize order IDs using our built-in functionality to Anonymise Order IDs (see section 4. about User Id).

  What are the consequences of anonymizing order ID ?

  It really depends on your former use of order IDs. If you were not using them in the past then you should not see any difference.

  6. Location

  Based on the IP address of a visitor, Matomo can detect the visitors location. Location data is problematic for privacy as this technology has become quite accurate and can detect not only the city a visitor is from, but sometimes an even more precise position of a visitor.

  

  In order to not leave any accurate traces, we strongly recommend you to enable the IP anonymization feature. Next, you need to enable the setting “Also use the anonymized IP address when enriching visits”. You find this setting directly below the IP anonymization. This is important as otherwise the full IP address will be used to geolocate a visitor.

  

  What are the consequences of anonymizing location data ?

  The more bytes you anonymize from the IP, the more anonymized your location will be. When you remove two bytes as suggested, the city and region location reports will not be as accurate. In some cases even the country may not be detected correctly anymore.

  7. Heatmaps & Session Recordings

  Heatmaps & Session Recording is a premium feature in Matomo allowing you to see where users click, hover, type and scroll. With session recordings you can then replay their actions in a video.

  Heatmaps & Session Recordings are under the scope of GDPR as they can disclose in some specific cases (for example : filling a contact form) personal data :

  

  To avoid this, Matomo will anonymize all keystrokes which a user enters into a form field unless you specifically whitelist a field. Many fields that could contain personal data, such as a credit card, phone number, email address, password, social security number, and more are always anonymized and not recorded.

  See our configuration guide for more information

  Note that a page may still show personal information within the page as part of regular content (not a form element). For example an address, or the profile page of a forum user. We have added a feature which allows you to set an HTML attribute “data-matomo-mask” to anonymize any personal content shown in the UI.

  What are the consequences of using this feature ?

  Mainly, you will not be able to see in plain text what people are entering into your forms.

  What should you do with past data ?

  Once more, we have to say that we are not lawyers. So do not take our answers as legal advice. From : ec.europa.eu/newsroom/article29/document.cfm ?doc_id=50053

  “For example, as the GDPR requires that a controller must be able to demonstrate that valid consent was obtained, all presumed consents of which no references are kept will automatically be below the consent standard of the GDPR and will need to be renewed.”

  Our interpretation is that, if you were previously relying on consent, unless you can demonstrate that valid consent was obtained, you need to get the consent back (which is almost impossible) or you need to anonymize or remove that data.

  To anonymize previously tracked data, we are actively working on a feature to do just that directly within Matomo. Alternatively, you may also set up the deletion of logs after a certain amount of time.

  We really hope you enjoyed reading this article. GDPR is still on the go and we are pretty sure you have a lot of questions about it. You probably would like to share our vision about it. So do not hesitate to ask us through our contact form to see how we are interpreting GDPR at Matomo and InnoCraft.

  The post How to not process any personal data with Matomo and what it means for you appeared first on Analytics Platform - Matomo.

• ffmpeg generate thumbnails on GPU

  22 juin 2018, par Oleksandr Kyrpa

  I try to generate thumbnails with acceleration on GPU, so compile ffmpeg 3.4.1 and run command :

  ./ffmpeg  -i ~/Videos/1080.mp4 -vf "hwupload_cuda,thumbnail_cuda=100,scale_cuda=107:60,hwdownload,format=yuv420p" -vframes 1 -y ~/Videos/thumbs/thumb%03d.jpg

  But I get wrong output picture (the color of thumbnail is green) :

  

  Correct image must be black.
  How to make first image with correct color ?

  

  log : -loglevel verbose

  ffmpeg version N-89707-g89b84cb Copyright (c) 2000-2018 the FFmpeg developers
  
    built with gcc 4.8 (Ubuntu 4.8.4-2ubuntu1~14.04.3)
  
    configuration: --cpu=native --enable-pthreads --extra-version=hd --enable-gnutls --enable-vaapi --enable-vdpau --enable-nonfree --enable-gpl --enable-swscale --enable-libx264 --enable-version3 --enable-nvenc --enable-libnpp --enable-cuda --enable-cuvid --enable-cuda-sdk --enable-filter=scale_cuda --enable-filter=thumbnail_cuda --extra-cflags=-I/usr/local/cuda-8.0/include --extra-ldflags=-L/usr/local/cuda-8.0/lib64
  
    libavutil      56.  7.100 / 56.  7.100
  
    libavcodec     58.  9.100 / 58.  9.100
  
    libavformat    58.  3.100 / 58.  3.100
  
    libavdevice    58.  0.100 / 58.  0.100
  
    libavfilter     7. 11.100 /  7. 11.100
  
    libswscale      5.  0.101 /  5.  0.101
  
    libswresample   3.  0.101 /  3.  0.101
  
    libpostproc    55.  0.100 / 55.  0.100
  
  [h264 @ 0x392ed40] Reinit context to 1920x1088, pix_fmt: yuv420p
  
  Input #0, mov,mp4,m4a,3gp,3g2,mj2, from '/home/alex/Videos/1080.mp4':
  
    Metadata:
  
      major_brand     : mp42
  
      minor_version   : 0
  
      compatible_brands: isommp42
  
      creation_time   : 2012-05-30T20:01:34.000000Z
  
    Duration: 00:01:14.21, start: 0.000000, bitrate: 5476 kb/s
  
      Stream #0:0(und): Video: h264 (High), 1 reference frame (avc1 / 0x31637661), yuv420p(left), 1920x1080 (1920x1088), 5321 kb/s, 29.97 fps, 29.97 tbr, 60k tbn, 59.94 tbc (default)
  
      Metadata:
  
        creation_time   : 1970-01-01T00:00:00.000000Z
  
        handler_name    : VideoHandler
  
      Stream #0:1(und): Audio: aac (LC) (mp4a / 0x6134706D), 44100 Hz, stereo, fltp, 152 kb/s (default)
  
      Metadata:
  
        creation_time   : 2012-05-30T20:01:34.000000Z
  
        handler_name    : IsoMedia File Produced by Google, 5-11-2011
  
  Stream mapping:
  
    Stream #0:0 -> #0:0 (h264 (native) -> mjpeg (native))
  
  Press [q] to stop, [?] for help
  
  [h264 @ 0x3a38280] Reinit context to 1920x1088, pix_fmt: yuv420p
  
  [Parsed_thumbnail_cuda_1 @ 0x4e3d8c0] batch size: 100 frames
  
  [graph 0 input from stream 0:0 @ 0x4e8b640] w:1920 h:1080 pixfmt:yuv420p tb:1/60000 fr:30000/1001 sar:0/1 sws_param:flags=2
  
  [auto_scaler_0 @ 0x4e8ca00] w:iw h:ih flags:'bicubic' interl:0
  
  [format @ 0x4e8b540] auto-inserting filter 'auto_scaler_0' between the filter 'Parsed_format_4' and the filter 'format'
  
  [Parsed_scale_cuda_2 @ 0x4e89380] w:1920 h:1080 -> w:107 h:60
  
  [swscaler @ 0x4ebf0c0] deprecated pixel format used, make sure you did set range correctly
  
  [auto_scaler_0 @ 0x4e8ca00] w:107 h:60 fmt:yuv420p sar:0/1 -> w:107 h:60 fmt:yuvj420p sar:0/1 flags:0x4
  
  Output #0, image2, to '/home/alex/Videos/thumbs/thumb%03d.jpg':
  
    Metadata:
  
      major_brand     : mp42
  
      minor_version   : 0
  
      compatible_brands: isommp42
  
      encoder         : Lavf58.3.100
  
      Stream #0:0(und): Video: mjpeg, 1 reference frame, yuvj420p(pc, left), 107x60, q=2-31, 200 kb/s, 29.97 fps, 29.97 tbn, 29.97 tbc (default)
  
      Metadata:
  
        creation_time   : 1970-01-01T00:00:00.000000Z
  
        handler_name    : VideoHandler
  
        encoder         : Lavc58.9.100 mjpeg
  
      Side data:
  
        cpb: bitrate max/min/avg: 0/0/200000 buffer size: 0 vbv_delay: -1
  
  [Parsed_thumbnail_cuda_1 @ 0x4e3d8c0] frame id #76 (pts_time=2.535867) selected from a set of 100 images
  
  No more output streams to write to, finishing.
  
  frame=    1 fps=0.9 q=3.1 Lsize=N/A time=00:00:02.56 bitrate=N/A speed=2.26x    
  
  video:2kB audio:0kB subtitle:0kB other streams:0kB global headers:0kB muxing overhead: unknown
  
  Input file #0 (/home/alex/Videos/1080.mp4):
  
    Input stream #0:0 (video): 115 packets read (134655 bytes); 101 frames decoded; 
  
    Input stream #0:1 (audio): 1 packets read (9 bytes); 
  
    Total: 116 packets (134664 bytes) demuxed
  
  Output file #0 (/home/alex/Videos/thumbs/thumb%03d.jpg):
  
    Output stream #0:0 (video): 1 frames encoded; 1 packets muxed (1864 bytes); 
  
    Total: 1 packets (1864 bytes) muxed

  UPDATE, working !
  Add format=nv12 before hwupload

  -vf "format=nv12,hwupload_cuda,thumbnail_cuda,scale_cuda=1280:72‌​0,hwdownload,format=‌​nv12"