Privacy policy clauses for Matrix (Element)
Matrix (Element) is a decentralized, open-source messaging protocol that enables end-to-end encrypted communication. Websites integrate Element to offer secure, federated chat functionality where message content remains encrypted and users maintain control over their data across distributed servers.
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What data Matrix (Element) collects
Your privacy policy must disclose each of the following data types when you use Matrix (Element).
When does Matrix (Element) trigger privacy obligations?
Obligations triggered by Matrix (Element) integration
Adding Matrix (Element) to your site or app creates immediate data processing obligations because user identifiers, display names, and room membership metadata flow to your homeserver (whether self-hosted or federated) the moment a user registers or joins a room. Encrypted message content itself is not readable by the server, but metadata is.
### GDPR Article 13/14 disclosure requirement
If you operate a homeserver or direct users to register on one, you are a data controller. GDPR Articles 13 (at collection) and 14 (indirect collection) require you to disclose: the identity of your controller, processing purposes, legal basis, recipients (including The Matrix.org Foundation if federated), retention periods, and user rights. This applies if your user base includes EU residents—no threshold minimum.
