RoPA Pilot

Fathom Analytics and GDPR: hosting, non-EU transfer and DPA

Fathom Analytics is published by Conva Ventures Inc.. If your teams use it, it is a processor within the meaning of Article 28 GDPR and it must appear in your record of processing activities.

Vendor (processor)
Conva Ventures Inc.
Headquarters
Canada
EU hosting
EU optional (plan/config)
Non-EU transfer
Yes
Transfer mechanism
Adequate country
Category
Analytics
Typical personal data
usage data
Detected domains
app.usefathom.com, usefathom.com

Does using Fathom Analytics mean a non-EU transfer?

Yes, but to a country covered by an adequacy decision (Canada): no additional safeguard is required, the destination country must still be named in your register.

What to write in your Article 30 record

Purpose: Analytics. Categories of personal data: usage data. Recipient: Conva Ventures Inc.. Transfer: Adequate country. Retention: aligned with the contract or the account lifetime, whichever is shorter.

How RoPA Pilot handles it

RoPA Pilot detects Fathom Analytics from the domain name of the tab — never from page content — and pre-fills the record above in one click. The extension flags the record if the transfer mechanism is missing or unverified.

Indicative information from public sources. The transfer mechanism actually applicable to you is the one written in your contract.