Snoobi Analytics and cookieless tracking

The basis of all privacy regulations is about protecting the individual.
Using that guidance, one of the underlying principles for the foundation of Snoobi Analytics is providing as much analytics information as is possible without 'tracking' or conflicting with privacy.

When used completely cookieless, Snoobi Analytics complies with the GDPR conditions. This is how:

No personal data means GDPR is not applicable

The ePrivacy directive and GDPR describe the concept of an individual as: '..user means any natural person using a publicly available electronic communications service..' and the concept of personal data. That means that if the collected data cannot be traced back to an individual (i.e., completely anonymized), it falls outside the scope of the GDPR. Why?
  1. The GDPR protects personal data, not aggregated or anonymized data.
  2. Complete anonymization means that even with additional information or reasonable effort, no one can identify the user or combine analytics with other data to identify a user who does not agree.

Snoobi only records statistics without any individual detail.

Here is what our Snoobi Cookieless analytics is about, as 'no cookies' is only one aspect of our privacy-conscious analytics:

  • No cookies
  • Data is generated only on the server
  • No identifiers are written to or read from the device
  • No unique user data is collected
  • No browser storage, no cookies, no local storage in any form
  • No fingerprinting
  • No unique signals
  • No IP-address storage
  • No user location data is collected
  • Data is only available for the website owner

All this means that analytics data can never be traced back to an individual

Cookieless analytics is equivalent to "necessary cookies"

Analytics serving to improve site functioning and measure technical performance anonymously can be considered a legitimate interest with minimal privacy impact, provided users remain unidentifiable. Session-based cookies may be placed without consent under these conditions.

Snoobi Analytics offers this through its Privacy Dashboard. To ensure full anonymity, a cookieless or hybrid option using Cookiebot is also available.

There is no data sharing with third parties

When your analytics solution operates independently, meaning not linked to external parties or accessible beyond your team, then no third-party data sharing occurs. This Snoobi architecture also prevents data transfer outside the EU, eliminates profiling by other services, and protects against commercial reuse.

Your data remains yours alone, ensuring processing stays within GDPR's permitted and proportionate limits.

Transparency remains important

Even if consent is not required, you must of course be transparent about what is being measured.
A clear explanation in your privacy statement or cookie policy is sufficient, mentioning what type of data you collect and for what purpose and it should include how you guarantee anonymization.

Legal confirmation in guidelines

Although not formalized in new European-wide legislation, regulators such as the EDPB, and national authorities such as CNIL (France), Autoriteit Persoonsgegevens (Netherlands) and Traficom (Finland) have confirmed that:
Fully anonymous analytics used exclusively by the website operator may be exempt from the cookie consent requirement.
The rights of a user under GDPR to have insight and access into the information that is collected from them is therefore also not applicable as there is no method in which Snoobi can identify an individual user.

Snoobi recommendation

When used without cookies, Snoobi Analytics does not use cookies or tracking IDs.
Since Snoobi cannot control how the Snoobi Analytics code is used on the website, we do not provide any binding legal advice, however we recommend that website owners using the cookieless Analytics option use the following statement on their website.

"This website uses Snoobi Analytics to anonymously analyze the use of our website. No cookies are placed and no personal data is collected or shared with third parties in any way. All data (such as IP addresses) are anonymized directly at the source."

Do you also want to get better analytics results? Contact your partner, or request a free Snoobi Trial.

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