> Overheat and GDPR: EU data storage, session recording privacy, heatmap tracking and the consent requirements to check before using it on a European site.
>
> Canonical: https://www.flowconsent.com/en/services/personalization/overheat

Personalization

# Overheat

Analytics

Overheat is a European privacy-focused session recording and heatmap tool designed as a GDPR-compliant alternative to Hotjar. It captures user interactions to help website owners understand how visitors navigate their site. With EU-based infrastructure and privacy-by-design principles, Overheat eliminates the third-country transfer risk associated with US-based analytics tools. Consent is still required before session recordings begin under the ePrivacy Directive.

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At a glance

- Category

  [Personalization](https://www.flowconsent.com/en/services/personalization)

- Consent

  Analytics

- Prior consent

  Required

- Documented cookies

  2

- Third-party domains

  2

- Servers

  European Union (Overheat is a European privacy-focused analytics tool)

Overview

## What does Overheat do?

## **What is Overheat?**

Overheat is a European privacy-focused session recording and heatmap analytics tool that provides website owners with visual insights into how visitors interact with their pages. It records mouse movements, clicks, scroll depth, and navigation patterns to create heatmaps and session replays. Overheat is specifically designed as a GDPR-compliant alternative to US-based tools like Hotjar and Microsoft Clarity, with EU-based data storage and privacy-by-design features such as automatic masking of sensitive input fields.

## **What data does Overheat collect?**

Overheat records mouse movements, click positions, scroll depth, page navigation sequences, and session duration. It may also capture form interaction data (fields focused, not necessarily values). IP addresses and browser information are collected. Sensitive form fields such as passwords and payment inputs are automatically masked. Session recordings are stored on EU-based servers.

## **GDPR compliance and EU advantage**

Overheat's EU data storage eliminates the primary GDPR risk associated with US-based session recording tools. No transfer mechanism is required. The privacy-by-design approach including automatic form field masking reduces the risk of inadvertently capturing sensitive personal data in recordings. The ePrivacy Directive still requires consent before session recording begins, as recording user behaviour constitutes non-essential data collection regardless of storage location.

## **Consent requirements**

Consent is required before Overheat scripts load and session recording begins. The consent notice should explain that session recordings and heatmaps are used to improve the website, describe the data captured, and confirm EU data storage. Given the EU location, no US transfer disclosure is needed. Users who decline must not have their sessions recorded.

## **Data location and transfers**

All data is processed in the EU. No transfer mechanism required. This makes Overheat suitable for organisations with strict data localisation requirements who need session recording analytics.

## **Practical compliance steps**

Obtain ePrivacy consent before Overheat loads. Verify automatic form field masking is active. Update your privacy policy to describe Overheat as a processor with EU data storage. Sign a DPA with Overheat. Configure session recording sampling rates and retention periods to minimise data collection. Document the processing in your RoPA noting the EU data location.

Compliance

## Overheat and the GDPR

Overheat is classified as “Analytics”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.

- Legal basis

  Consent (Art. 6(1)(a) GDPR) for session recordings and heatmap tracking as these involve systematic observation of individual user behaviour. Legitimate interest (Art. 6(1)(f)) may apply to aggregate, anonymised heatmap data with a documented balancing test.

- Risk level

  medium

- Applicable regulations

  GDPR, ePrivacy Directive

### Impact assessment (DPIA)

A DPIA is advisable when Overheat session recordings capture sensitive user interactions at scale, such as form completions, health-related page visits, or financial account pages. The EU data location significantly reduces risk compared to US-based alternatives.

### Sample text for your banner

> We use Overheat to record and analyse how visitors use our website through session recordings and heatmaps. Overheat collects interaction data including mouse movements, clicks, and scroll behaviour. Data is processed in the EU. Please accept to enable session recording and heatmap analytics.

Cookies and trackers

## What Overheat sets and contacts

- Tracking method

  JavaScript snippet, session recording, heatmap tracking, click and scroll event capture, first-party cookies

- Server location

  European Union (Overheat is a European privacy-focused analytics tool)

- Cookieless mode available

  Yes

### Cookies set (2)

| Name        | Type       | Duration | Purpose                                                                                           |
| ----------- | ---------- | -------- | ------------------------------------------------------------------------------------------------- |
| oh\_session | session    | Session  | Session identifier used to maintain the active session recording and associate interaction events |
| oh\_uid     | persistent | 1 year   | Visitor identifier used to stitch sessions across page loads for complete session replay          |

### Third-party domains contacted (2)

- `overheat.io`
- `cdn.overheat.io`

Questions

## Frequently asked questions about Overheat

Can't find your question? Write to us, we answer fast.

[Write to us](https://www.flowconsent.com/en/demo)

### What does Overheat record?

Overheat records mouse movements, click positions, scroll depth, page navigation sequences, and session duration. Sensitive form fields such as passwords and payment inputs are automatically masked. Recordings are stored on EU-based servers.

### Does Overheat require consent under GDPR?

Yes. Session recording and heatmap tracking are non-essential and require prior ePrivacy consent regardless of EU data location. Users who decline must not have their sessions recorded.

### What is the legal basis for using Overheat?

Consent (Art. 6(1)(a)) is required for session recordings and individual heatmap tracking. Legitimate interest may apply to aggregate, anonymised heatmap data with a documented balancing test.

### Does Overheat transfer data outside the EU?

No. All data is processed within the EU. No GDPR Chapter V transfer mechanism is required, a major advantage over US-based tools like Hotjar or FullStory.

### Do I need a DPIA for Overheat?

Advisable when recordings capture sensitive interactions at scale (health, finance, legal pages). The EU data location significantly reduces the risk profile versus US alternatives.

### How do I implement Overheat compliantly?

Obtain ePrivacy consent before loading. Verify automatic form masking is active. Sign a DPA with Overheat. Update your privacy policy noting EU data storage. Configure retention periods and document the processing in your RoPA.

### How does Overheat compare to Hotjar for GDPR compliance?

Overheat stores all data in the EU, eliminating the US transfer risk. Hotjar requires SCCs; Overheat does not. Both require ePrivacy consent. For EU organisations, Overheat is the simpler compliance choice.

### How do I add Overheat to my cookie policy?

List the Overheat session cookie under analytics, note the EU data storage, reference Overheat as processor, and link to their privacy policy. No third-country transfer disclosure is required.

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