Is Bombora GDPR compliant?

What does Bombora do?

B2B intent data: it records which topics a visitor researches across a publisher network and sells that signal on to sales teams. Building a topic profile this way needs consent and an honest entry in your policy.

Does Bombora need consent?

Yes. Bombora is Advertising, which is never strictly necessary for a website to function. Under ePrivacy Article 5(3), and its national transpositions, storing or reading anything on the device for that purpose requires consent first, and that consent has to be as easy to refuse as it is to give.

ePrivacy Art. 5(3) · TDDDG § 25 (DE) · TKG 2021 § 165(3) (AT) · GDPR Art. 6(1)(a)

Does Bombora send data outside the EEA?

Yes. Bombora processes data outside the European Economic Area, so you need a transfer mechanism under Chapter V and you have to say so in your privacy policy. In practice this means standard contractual clauses, or a provider certified under the EU-US Data Privacy Framework.

GDPR Art. 44 · GDPR Art. 46

How do we detect Bombora?

We load your page in a real browser as a first-time visitor who clicks nothing, then look at what it contacted. Bombora is recognised by requests to ml314.com and bombora.com, and we report whether it merely loaded or actually sent data, and whether it set a cookie before any choice was made.