Thank you for your follow up.

1. Glad we're in agreement!

2. We agree it is not GDPR compliant to transmit IP address data to the US. This is why we salt and hash all PII data so no IP address data is sent to the US. Please see our data policy.

https://beamanalytics.io/data

3. Thank you for your suggestion. We have already consulted privacy professionals and have been assured no DPO is required.

Thank you for this conversation about GDPR. We appreciate your interest in Beam's work.

>salt and hash all PII data

Can you share more detail on this? On this page[1], I see this:

  hash(pepper(salt(ip address + user agent data))) = anonymized hashed data

Both the ipv4 space and typical user agent possibilities are pretty small, so it feels like you could easily de-anonymize it when you want to. That is, assuming the "salt" and "pepper" are stored somewhere. I assume you do store them, otherwise it's not helpful to identify repeat visits.

[1] https://beamanalytics.io/data

Are you saying there is no way to use AWS and be GDPR compliant? Or the way that OP is using AWS isn't GDPR compliant?

There is a way to use AWS assuming you can assure no Personal Data is processed in plain text on AWS.

There was a case of Doctolib in the EU. French authority investigated Doctlib for using AWS.

They got off the hook because data was encrypted in the EU, outside of AWS and the encryption keys were inaccessible to AWS.

Similarly Sendinblue uses GCP and AWS as dumb storage of externally encrypted backups.

There are valid use cases. But these are very limited.

Aula - a system used for communication between parents and schools in Denmark - is using AWS. They use encryption and ensures that only European datacenters are used. Source (in Danish): https://aulainfo.dk/guide-til-projektledere/sikkerhed-i-aula...

IANAL but as I understand it there is, currently, no way to legally use a service for personal data handling that falls under the US CLOUD act.

In theory Amazon could license their brand and software to an independent (!) European company to offer a EU-AWS.

Basically if an American judge/agency can order Amazon to hand over European private data and they have the ability to comply without involving a European court the service is not GDPR compliment.

Now in practice this isn't how things are done but to the best of my knowledge the law hasn't changed (yet) and national dpas are starting to tighten the screws (slowly).

If I recall correctly there are EU-US talks to create Privacy Shield #3.