Do they own your data? Hotjar Privacy Policy Reviewed.
Hotjar achieves a 6/10 enterprise readiness score - partially ready for large organizations. While excelling in user analytics and heatmap capabilities, it faces challenges with advanced security features and enterprise-grade compliance requirements.
Final Enterprise Readiness Rating: 6/10
⚠️ Partially ready (Reviewed 2026).
|
Area |
Verdict |
Notes |
|---|---|---|
|
Data Residency & Storage |
⚠️ Partial |
Data is 'mostly' stored in EU but may be transferred outside with only standard contractual clauses as protection |
|
AI Model Use |
❌ High Risk |
No mention of AI model usage, training on customer data, or LLM integrations despite being an analytics platform |
|
Data Minimization |
⚠️ Partial |
Collects comprehensive behavioral data including device info, usage patterns, and session recordings with limited customer control over scope |
|
Privacy Controls |
✅ Good |
Comprehensive GDPR rights implementation but no mention of workspace-level privacy controls for enterprise admins |
|
Compliance & Auditability |
⚠️ Partial |
Strong GDPR compliance with detailed legal bases, but no mention of SOC 2, ISO 27001, or HIPAA certifications |
|
Consent Handling |
✅ Good |
Clear consent mechanisms and legal basis documentation, though focused on direct user consent rather than enterprise consent management |
|
Model Explainability |
❌ High Risk |
No mention of how behavioral analytics algorithms work or what insights are derived from collected data |
|
Data Retention & Deletion |
✅ Good |
30-day deletion for most data, with specific retention periods for different data types and clear account deletion processes |
|
Third-Party Sharing |
✅ Good |
Clear commitment to never sell data, with limited sharing to vetted service providers and parent company |
⚠️ Recommendation for Enterprises:
Adopt Hotjar with caution. Be especially careful if you handle:
- Health records or HIPAA-regulated data
- Financial services data requiring SOC 2
- Highly confidential IP or trade secrets
- EU-only data residency requirements
Instead, consider AI tools that:
- Provide SOC 2 Type II and ISO 27001 certifications
- Offer guaranteed EU-only data processing
- Implement enterprise admin privacy controls
- Provide AI/ML model transparency and governance
Better Alternative:
✅ BuildBetter.ai — GDPR, SOC 2 Type 2, and HIPAA compliant
✅ Zero training on customer data
✅ You own your data. Fully opt-in privacy model.
🔍 Hotjar Privacy Policy – Enterprise Risk Assessment
Audience: Security-conscious enterprise organizations evaluating User behavior analytics with heatmaps and session recordings for internal use in highly sensitive or regulated environments (e.g. legal, healthcare, finance, tech/IP-heavy orgs).
⚠️ Where Hotjar Falls Short – Critical Gaps
🔒 1. Data Residency & Storage
Quote: "In most cases, Personal Data We collect is stored in the EU. However, in some limited cases, customer information may be accessed from, or other Personal Data (e.g., email, etc.) may be transferred outside of the EU."
Risk: For enterprises handling regulated data, 'mostly' isn't good enough. The vague language around 'limited cases' of international transfers creates compliance uncertainty and potential regulatory risk.
Enterprise Issue:
- No guaranteed EU-only data residency option
- Vague criteria for when data leaves EU
- No on-premises or private cloud deployment options
Verdict: ⚠️ Insufficient data residency guarantees
🧠 2. AI Model Use
Risk: Modern analytics platforms increasingly use AI/ML models. The complete absence of AI governance details in their privacy policy suggests either poor disclosure practices or lack of enterprise-grade AI controls.
Enterprise Issue:
- No AI model transparency
- Unknown if customer data trains models
- No bring-your-own model options
Verdict: ❌ Complete blind spot for enterprise AI governance
📊 3. Data Minimization
Quote: "We may temporarily store the name of their internet service provider, IP address, the website they visited Us from, the parts of Our Site they visit, the date and duration of the visit, and information from the device (e.g. device type, operating system, screen resolution, language, country you are located in, and web browser type)"
Risk: For enterprises handling sensitive data, the broad data collection scope combined with session recordings creates significant privacy exposure. Limited ability to configure minimal data collection increases compliance burden.
Enterprise Issue:
- No granular data collection controls
- Session recordings capture potentially sensitive information
- Broad device and behavioral data collection
Verdict: ⚠️ Extensive data collection with limited minimization controls
⚙️ 4. Privacy Controls
Quote: "you have a right to access and to be informed about what Personal Data is processed by Hotjar, a right to rectification/correction, erasure/anonymization and restriction of processing"
Risk: While individual privacy rights are well-covered, enterprises need administrative controls to manage privacy settings across their organization. Lack of workspace-level controls creates operational challenges.
Enterprise Issue:
- No enterprise admin privacy controls
- No bulk privacy management capabilities
- Limited organizational-level consent management
Verdict: ✅ Strong individual rights but weak enterprise administration
📦 5. Compliance & Auditability
Quote: "We use a select number of trusted external service providers for certain technical data analysis, processing and/or storage offerings (e.g., IT and related services). These Third Party service providers are carefully selected and meet high data protection and security standards."
Risk: Enterprise customers need third-party security certifications to meet their own compliance requirements. The absence of SOC 2 Type II makes vendor risk assessments difficult and may disqualify Hotjar for regulated industries.
Enterprise Issue:
- No SOC 2 Type II certification mentioned
- No HIPAA compliance
- Vague subprocessor security standards
Verdict: ⚠️ GDPR compliant but missing key enterprise certifications
📬 6. Consent Handling
Quote: "In some cases, We may ask you for consent to collect, use or share Personal Data for other purposes... In such cases, there will always be the ability to deny or revoke consent if desired."
Risk: Good individual consent handling, but enterprises need tools to manage consent at scale across their user base. The policy doesn't address enterprise consent delegation or bulk consent management needs.
Enterprise Issue:
- No enterprise consent delegation features
- Limited bulk consent management
- No automated consent compliance reporting
Verdict: ✅ Solid consent framework with clear legal bases
🔍 7. Model Explainability
Risk: For enterprises, especially in regulated industries, algorithmic transparency is crucial for compliance and risk management. The lack of explainability makes it difficult to assess potential bias or compliance risks in analytics outputs.
Enterprise Issue:
- No algorithmic transparency
- No audit trails for analytics processing
- Unknown data processing methodology
Verdict: ❌ Analytics black box with no algorithmic transparency
🧼 8. Data Retention & Deletion
Quote: "Any other Personal Data We were processing relating to Our Customer, Tester and/or Users of that Hotjar account will be deleted permanently within thirty (30) calendar days."
Risk: Good data lifecycle management reduces enterprise compliance burden. The clear deletion timelines and account deletion processes help meet data minimization requirements.
Enterprise Issue:
- No configurable retention periods
- Research data retention timeline unclear
- Limited enterprise bulk deletion capabilities
Verdict: ✅ Clear retention policies with reasonable deletion timelines
🤝 9. Third-Party Sharing
Quote: "We will NEVER sell Your Personal Data to Third Parties. Hotjar will only share or disclose Personal Data as described in this Privacy Policy."
Risk: The strong anti-sale commitment and controlled sharing framework reduces enterprise data exposure risk. However, sharing with parent company Contentsquare could expand data access beyond original purpose.
Enterprise Issue:
- Data sharing with parent company Contentsquare
- Limited subprocessor transparency
- No enterprise veto over specific sharing arrangements
Verdict: ✅ Strong no-sale commitment with controlled sharing
✅ What Hotjar Does Right (Credit Where It's Due)
- Strong GDPR compliance with detailed legal bases
- Clear no-sale commitment for customer data
- Reasonable data retention and deletion timelines
- Comprehensive individual privacy rights implementation
- Transparent disclosure of data collection practices
Disclaimer: This evaluation is based solely on publicly available information and documentation. For formal enterprise vetting, always request a vendor's latest DPA, security whitepaper, and third-party audit reports.