Parallel Tracking GDPR Information

This GDPR information document only applies to the Google Analytics 4 Parallel Tracking service. For GDPR information for other products and services, please contact our support.

Last update: 2023-02-22

GDPR here refers to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). Link

This document is not legal advice and Reflective Data doesn’t take responsibility for how certain courts and other legal institutions may interpret GDPR and other related laws and regulations. The final decision on whether to use this solution and whether it complies with GDPR and other laws and regulations is made by the Client and the Client also takes full responsibility in case this solution is declared not compliant with GDPR or any other laws and regulations.

The purpose of this document is to help anyone in deciding whether Parallel Tracking is a viable solution for their company to collect Google Analytics 4 data in a GDPR-compliant manner.

Definitions

GDPR – General Data Protection Regulation. Link

Parallel Tracking – Service offered by Reflective Data that enables the Client to collect Google Analytics 4 data in their BigQuery dataset without sending any data outside of the European Union.

Client – Legal entity that is using Reflective Data services.

User – User/visitor of the Client’s website.

Facts

Data is processed within the European Union.
Data is stored in Client’s BigQuery dataset that the client can choose to locate within the European Union.
Reflective Data doesn’t store any Client data on its servers.
No data is sent to Google Analytics 4.
No data is sent outside of the European Union.
The Client is responsible for the correct cookie consent and cookie storage configuration.

How Parallel Tracking Works

Parallel Tracking setup doesn’t require any new tracking to be configured. Instead, it leverages the existing Google Analytics 4 configuration. The only piece of setup required to enable Parallel Tracking is one new tag in Google Tag Manager that detects all Google Analytics 4 HTTP requests and modifies them so that instead of Google’s servers, those requests are sent to Reflective Data’s servers located in the European Union.

In order to stay GDPR-compliant, the Client can request Reflective Data for a Parallel Tracking snippet that completely disables any data from being sent to Google Analytics data processing endpoint that is located in the United States. In that case, all data is processed on the Google Cloud instance that is located within the European Union and Client’s data never leaves the European Union.

Once data is processed, Reflective Data loads it into Client’s BigQuery dataset which can be located within the European Union.

Cookies

Parallel Tracking doesn’t create any new cookies, nor does it modify or directly read any existing cookies. Instead, Parallel Tracking relies on the GDPR-compliant first-party cookies set and used by Google Analytics 4.

Further reading on how Google Analytics 4 uses cookies. Link

In order to stay GDPR-compliant, the Client should use proper cookie consent and cookie storage configuration.

Recap

It is Reflective Data’s understanding that the only reason why several European Union countries have declared Google Analytics 4 not compliant with the GDPR is that it processes and stores Client and User data outside of the European Union. Using Parallel Tracking, Clients can skip the step of sending any data outside of the European Union and instead receive it in their BigQuery dataset that is located within the European Union.

Have a question about the GDPR compliancy or other terms and conditions that apply for the data pipeline and parallel tracking services? Please fill a form on this page or write us an email at [email protected].