> Imperva WAF and DDoS protection under the GDPR: strictly necessary security cookies, data transfers and how to disclose Imperva in your privacy notice.
>
> Canonical: https://www.flowconsent.com/en/services/security/imperva

Security

# Imperva

Essential · [Official website](https://www.imperva.com)

Imperva is a leading web application firewall (WAF) and DDoS protection provider used by European banks, governments, retailers and SaaS companies to defend their web infrastructure. It sits in front of the customer's website as a reverse proxy or DNS-routed CDN, inspecting every HTTP request for attacks. Imperva sets a small number of strictly necessary security cookies (such as the incap\_ses\_\<id> and visid\_incap\_\<id> cookies) which are exempt from prior consent under Art. 5(3) ePrivacy.

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At a glance

- Category

  [Security](https://www.flowconsent.com/en/services/security)

- Consent

  Essential

- Prior consent

  Not required

- Documented cookies

  3

- Third-party domains

  4

- Servers

  Imperva, Inc., San Mateo, California, United States. Global PoPs including European cities (Frankfurt, Paris, Dublin, London)

Overview

## What does Imperva do?

## **What is Imperva**

Imperva (originally Incapsula) is a leading WAF, DDoS protection, bot management and API security provider. Deployed as a reverse proxy or DNS-routed CDN, it inspects every HTTP request before it reaches the origin server, blocking attacks (SQL injection, XSS, credential stuffing, layer 7 DDoS) and validating suspicious traffic with CAPTCHA challenges.

## **Cookies and data**

Imperva typically sets incap\_ses\_\<id> (session identifier for security context), visid\_incap\_\<id> (visitor security identifier across sessions), and nlbi\_\<id> (load-balancing cookie). All are classified as strictly necessary for security. Imperva also processes IP, User-Agent, request bodies, headers and behavioural signals on the WAF level.

## **GDPR and ePrivacy**

Imperva's security cookies fall under the strictly necessary exemption of Art. 5(3) ePrivacy. They do not require prior consent. The processing of request data relies on legitimate interest (Art. 6(1)(f)) and the legal obligation in Art. 32 GDPR. EDPB guidance treats security cookies as strictly necessary as long as they remain proportionate.

## **Data transfers and PoP routing**

Imperva has European PoPs (Frankfurt, Paris, Dublin, London). You can request EU-only routing for traffic from European visitors. The central threat intelligence is in the US; aggregated and anonymised attack signatures are shared globally, covered by SCCs and EU-US DPF. For high-sensitivity deployments, document the routing and the threat-sharing in your security policy.

## **NIS2 and incident response**

For essential and important entities under NIS2, Imperva is a key technical measure. Integrate Imperva alerts and logs into your SIEM and incident response runbook. Configure log retention to match NIS2 reporting obligations (significant incidents must be reported within 24 hours).

## **Practical compliance checklist**

1\. Sign the Imperva DPA. 2. Configure EU PoPs for European traffic. 3. Document Imperva in your Record of Processing Activities as a security measure. 4. Disclose Imperva in your privacy notice. 5. Integrate logs with your SIEM. 6. Map Imperva to your NIS2 incident response runbook. 7. Configure log retention to match obligations.

Compliance

## Imperva and the GDPR

- Legal basis

  Legitimate interest (Art. 6(1)(f) GDPR) and legal obligation under Art. 32 GDPR to ensure security of processing

- Risk level

  low

- Applicable regulations

  GDPR, ePrivacy Directive (strictly necessary cookie exemption), NIS2 Directive

### Impact assessment (DPIA)

Imperva processes visitor IP, User-Agent, request URLs, request bodies and headers for inspection, plus aggregated threat telemetry. Key DPIA considerations: (1) cookies set are strictly necessary for security and may rely on the consent exemption of Art. 5(3) ePrivacy; (2) request inspection processes personal data, justified by legitimate interest and Art. 32 GDPR; (3) data may be processed in Imperva PoPs (some in EU, some elsewhere); (4) US threat intelligence sharing covered by SCCs; (5) NIS2 incident response obligations may apply. A streamlined DPIA is sufficient.

### Sample text for your banner

> Our site is protected against attacks and bots by Imperva. Imperva inspects each request and sets strictly necessary cookies (incap\_ses\_\<id>, visid\_incap\_\<id>) to remember which visitors have already passed security challenges. This processing is based on our legitimate interest in security and our legal obligation under Art. 32 GDPR.

Cookies and trackers

## What Imperva sets and contacts

- Tracking method

  Web application firewall and DDoS protection. Sits in front of the website as a reverse proxy or DNS-routed CDN. Sets a small number of security cookies for bot detection and challenge persistence

- Server location

  Imperva, Inc., San Mateo, California, United States. Global PoPs including European cities (Frankfurt, Paris, Dublin, London)

- Data transferred outside the EU

  Visitor IP, request metadata, security challenge results and aggregated threat telemetry are processed in Imperva PoPs and shared with the central Imperva threat intelligence in the US. Transfers covered by 2021 SCCs and EU-US DPF.

### Cookies set (3)

| Name                | Type               | Duration | Purpose                                                                                                                       |
| ------------------- | ------------------ | -------- | ----------------------------------------------------------------------------------------------------------------------------- |
| incap\_ses\_\<id>   | Strictly necessary | Session  | Imperva security session identifier used to recognise visitors that have already passed the WAF and bot challenges.           |
| visid\_incap\_\<id> | Strictly necessary | 1 year   | Persistent visitor identifier across sessions, used to maintain security context and prevent re-challenging trusted visitors. |
| nlbi\_\<id>         | Strictly necessary | Session  | Load-balancing cookie that pins a visitor to the same Imperva PoP for consistent inspection.                                  |

### Third-party domains contacted (4)

- `imperva.com`
- `incapdns.net`
- `incap.io`
- `cloudwaf.io`

Questions

## Frequently asked questions about Imperva

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

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

### Cookies Imperva sets?

incap\_ses\_\<id>, visid\_incap\_\<id>, nlbi\_\<id>. All strictly necessary for security.

### Consent needed?

No, security cookies fall under the strictly necessary exemption of Art. 5(3) ePrivacy.

### Legal basis?

Legitimate interest (Art. 6(1)(f)) and Art. 32 GDPR security obligation.

### US transfers?

Threat intelligence is centralised in the US, covered by SCCs and DPF. Traffic can be EU-routed.

### DPIA?

A streamlined DPIA is sufficient; full DPIA recommended for NIS2 critical entities.

### Compliant deployment?

Sign DPA, EU PoP routing, document in Record of Processing Activities, integrate with SIEM, NIS2 runbook.

### Alternatives?

EU-friendly WAF/DDoS: Cloudflare (US, EU PoPs), Akamai (US, EU PoPs), Fastly (US, EU PoPs), DataDome (France), Variti (Switzerland).

### Policy updates?

Disclose Imperva as a security processor, mention the US threat intelligence transfer with SCCs, list the security cookies as strictly necessary.

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