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Anonymous data is not subject to the the GDPR. See recital 26. [0] IANAL, but as far as I know, companies can collect anonymous data ("what versions are our cu

by eddyg 7y ago

Anonymous data is not subject to the the GDPR. See recital 26. [0] IANAL, but as far as I know, companies can collect anonymous data ("what versions are our customers running?") without involving the GDPR. > This Regulation does not therefore concern the processing of such anonymous information, including for statistical or research purposes. [0] https://gdpr-info.eu/recitals/no-26/ https://gdpr-info.eu/recitals/no-26/

simpss 7y ago
the thing is, it's pretty difficult to guarantee the data is indeed anonymous. In this specific case, as they are not willing to explain what data is actually processed and say it's somewhere in the Tos, privacy policy[1] etc... we'll take that as the gospel. ---------------- The Usage Data that we collect may include information such as your device data, including your mobile devices, sensor data, device signals, device parameters, device identifiers that may uniquely identify your devices, including your mobile device, web request, Internet Protocol address, browser type, browser language, referring/exit pages and URLs, platform type, the date and time of your request, and one or more cookies that may uniquely identify your devices or browser.[1] ---------------- This data is certainly not anonymous by GDPR standards. Identifiers that uniquely identify a device will in some cases(ex, single-user devices) also be unique identifiers to a single person. That is enough for the data to be considered Personal Data in the context of GDPR. ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person[2] [1] - https://www.ui.com/legal/privacypolicy/ https://www.ui.com/legal/privacypolicy/ [2] - https://gdpr-info.eu/art-4-gdpr/ https://gdpr-info.eu/art-4-gdpr/
tgsovlerkhgsel 7y ago
I bet they will not actually be GDPR compliant. They will likely get away with it because enforcement is lacking, but anonymization is hard to get right and I would be surprised if they did get it right.
- thelittleone 7y ago
  Is there a way to file GDPR complaints? Enforcement might be lacking but with enough data and support surely it would be possible or be sufficient to make Ubiquiti move to opt in.
  - simpss 7y ago
    contact your local DPA[1] and file a complaint. There's plenty of info on the original thread[2] on what they're doing wrong. [1] - https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en https://ec.europa.eu/info/law/law-topic/data-protection/refo... [2] - https://community.ui.com/questions/UI-official-urgent-please-answer/14259289-e4c3-4c5e-aaa0-02a5baa6cbbe#answer/f0f5de22-396c-4cb3-aad5-9d6038539980 https://community.ui.com/questions/UI-official-urgent-please...
zimbatm 7y ago
There is no such thing as completely anonymous data. If the data is of interest is has some uniquely identifying feature. Even anonymized data always contain some bits of information that can be correlated to de-anonymize a user.

by eddyg 7y ago

simpss 7y ago

the thing is, it's pretty difficult to guarantee the data is indeed anonymous. In this specific case, as they are not willing to explain what data is actually processed and say it's somewhere in the Tos, privacy policy[1] etc... we'll take that as the gospel. ---------------- The Usage Data that we collect may include information such as your device data, including your mobile devices, sensor data, device signals, device parameters, device identifiers that may uniquely identify your devices, including your mobile device, web request, Internet Protocol address, browser type, browser language, referring/exit pages and URLs, platform type, the date and time of your request, and one or more cookies that may uniquely identify your devices or browser.[1] ---------------- This data is certainly not anonymous by GDPR standards. Identifiers that uniquely identify a device will in some cases(ex, single-user devices) also be unique identifiers to a single person. That is enough for the data to be considered Personal Data in the context of GDPR. ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person[2] [1] - https://www.ui.com/legal/privacypolicy/ https://www.ui.com/legal/privacypolicy/ [2] - https://gdpr-info.eu/art-4-gdpr/ https://gdpr-info.eu/art-4-gdpr/

tgsovlerkhgsel 7y ago

I bet they will not actually be GDPR compliant. They will likely get away with it because enforcement is lacking, but anonymization is hard to get right and I would be surprised if they did get it right.

thelittleone 7y ago
Is there a way to file GDPR complaints? Enforcement might be lacking but with enough data and support surely it would be possible or be sufficient to make Ubiquiti move to opt in.
- simpss 7y ago
  contact your local DPA[1] and file a complaint. There's plenty of info on the original thread[2] on what they're doing wrong. [1] - https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en https://ec.europa.eu/info/law/law-topic/data-protection/refo... [2] - https://community.ui.com/questions/UI-official-urgent-please-answer/14259289-e4c3-4c5e-aaa0-02a5baa6cbbe#answer/f0f5de22-396c-4cb3-aad5-9d6038539980 https://community.ui.com/questions/UI-official-urgent-please...

zimbatm 7y ago

There is no such thing as completely anonymous data. If the data is of interest is has some uniquely identifying feature. Even anonymized data always contain some bits of information that can be correlated to de-anonymize a user.