RoPA Pilot

Hotjar and GDPR: hosting, non-EU transfer and DPA

Hotjar is published by Hotjar Ltd. 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)
Hotjar Ltd
Headquarters
European Union
EU hosting
EU by default
Non-EU transfer
No
Transfer mechanism
European Union
Category
Analytics
Typical personal data
usage data, technical data
Detected domains
insights.hotjar.com, hotjar.com
Official DPA
Open the official DPA

Does using Hotjar mean a non-EU transfer?

No. Hotjar Ltd keeps the data inside the European Union: no structural transfer to document under Chapter V.

What to write in your Article 30 record

Purpose: Analytics. Categories of personal data: usage data, technical data. Recipient: Hotjar Ltd. Transfer: European Union. Retention: aligned with the contract or the account lifetime, whichever is shorter.

How RoPA Pilot handles it

RoPA Pilot detects Hotjar 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.

Install the free extension See a sample register

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