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Privacy and GDPR for cookieless analytics

How Privatus Analytics measures without cookies or persistent identifiers, what happens to IP addresses, and what it means for GDPR and cookie banners.

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Note: This section explains how the product works and gives templates. It isn't legal advice. Your obligations depend on your jurisdiction and your other processing. Check with your own counsel.

The data journey#

  1. Browser: the tracker sends one request per pageview or event with the page URL, referrer, screen width, language, the GPC and DNT signals, a yes/no flag for whether any input was seen on the page, and the properties you choose. With the default engagement module it also sends visible time and scroll depth. It stores nothing on the device (except an opt-out flag the visitor sets themselves), sets no cookies and uses no fingerprinting APIs.
  2. Ingest (US): the request passes through our network provider, Cloudflare, and arrives at our servers in the United States with the visitor's IP address and User-Agent, as every HTTP request does. This is the same for every visitor, including visitors from the EU/EEA, the UK and Switzerland. In memory only, while the request is handled, the IP and User-Agent are used to:
    • check for bots,
    • apply your IP-range traffic rules,
    • compute the daily visit key HMAC(daily salt, site, IP, User-Agent).

The visitor's country comes from the CF-IPCountry header that Cloudflare adds to the request. Location is country only: no region, city or coordinates are collected.

  1. Minimization: the URL is stripped of query parameters (except your allowlist: campaign parameters are read into their own fields), the PII scrubber redacts emails, ids and tokens, your path masks and traffic rules apply, and the User-Agent is reduced to browser and OS (name and major version) and device type.
  2. Storage (US): only the minimized event is stored. The IP address and the raw User-Agent are never written to our database, logs, queues or backups. The visit key is kept only in our in-memory store (Redis) with an expiry of at most one UTC day, never in the database.

Key facts#

The Privacy tab of the site settings, with the options that control what is collected.
The Privacy tab of the site settings, with the options that control what is collected.
Question Answer
Cookies or device storage? None (only the visitor's own opt-out flag)
Persistent identifiers? None. Visit ids are random and last at most one UTC day
Cross-site or cross-device tracking? No. The visit key includes the site, the IP address and the User-Agent, and changes every day
Visitor IP addresses stored? Never, not even for bots or blocked hits. (Sign-in sessions and the audit log of your own team members do record the member's IP address, as our Privacy Policy describes)
Data sold or shared? Never, and not used for advertising
Where is data stored? United States. See Where data lives
Affiliate referrals? Attributed without cookies or click logs. See Affiliate program
Can we re-identify a visitor? Not from stored data: the daily salt that could link a visit key to an IP expires 30 minutes after the UTC day ends and is never saved

We describe this data as pseudonymous, heavily minimized data, not as "anonymous": for one day, a visit key could in theory be linked to an IP by someone holding the salt. See How visitors are counted.

That is your decision, and it depends on your jurisdiction and on everything else your site loads. We can't decide it for you. The facts that matter for Privatus Analytics:

  • ePrivacy / PECR consent rules are about storing or reading information on a device. The tracker sets no cookies and stores nothing on the device. The only exception is the opt-out flag a visitor sets themselves.
  • GDPR still applies to the transient processing of IP addresses, so you need a legal basis. Customers typically consider legitimate interests (Art. 6(1)(f)). Use our LIA template to document your assessment, and describe the processing in your privacy policy (templates).
  • US state laws (CCPA/CPRA and others): we act as your service provider/processor and don't sell or share personal information. We honor Global Privacy Control by default.

Some regulators and some organizations take stricter views. The opt-out and GPC/DNT handling exist for them.

Our role#

You're the controller of your visitors' data, and we're your processor. Our Data Processing Agreement (with the EU Standard Contractual Clauses and the UK addendum) is part of the Terms and is published at /legal/dpa, with the subprocessor list. The DPA includes our technical and organizational measures.

In this section#