Is FullStory GDPR compliant?

What does FullStory do?

Session replay for whole user journeys, including form interaction. Everything said about Hotjar applies with more force here, because the default capture is broader and retention is longer.

Does FullStory need consent?

Yes. FullStory is Session replay, 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 FullStory send data outside the EEA?

Yes. FullStory 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

What can I use instead of FullStory?

How do we detect FullStory?

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