According to the GDPR
Article 4 specifies:
‘Personal data’ means any information relating to an identified or identifiable natural person; an ‘identifiable natural person’ is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’.
Regarding Piano Analytics
The table below describes the various types of personal data you may find in our solutions.
TYPES OF PERSONAL DATA
|
|
Data included in raw data and non-available in the solution |
Data included in Available Raw Data |
Data included in processed data and available in the solution |
|
|
Data collected by default by the Piano Analytics marker and required for the main end purpose. |
IP address |
✔ Anonymisation option activatable at customer's request (deletion of final octet) |
✘ |
✘ |
|
Cookie ID |
✔ (Depends on the platform visited) |
Transformation into Visitor ID |
||
|
Mobile ID |
✔ (Depends on the platform visited) |
|||
|
Digital analytics data relative to the above identifiers |
✔ |
✔ (enriched) |
||
|
Data type which may be collected by the Piano Analytics marker, at the customer’s initiative and for their personal additional end purposes |
GPS (if used with SDK) |
✔ |
✔ |
|
|
User ID (connected user) |
✔ |
✔
|
||
|
Transaction ID |
✔ |
✔ |
||
|
Emailing- recipient |
✔ |
✔ |
||
|
Digital analytics data relative to the above identifiers |
✔
|
✔
|
||
Note
As specified in the table under the lines ‘Digital analytics data relative to the above identifiers’, all analytic data is considered by default to be personal data. It may always, by default, be cross-referenced with properties meeting the definition of Article 4 of the GDPR.
Note
Piano Analytics also provides:
- A list of dimensions and metrics specifying navigation data which is collected from internet users via our solution.
- A list of cookies used in the framework of our solution for the web part.
- Data on mobile identifiers (native applications) available in our tagging guide for iOS and Android
Cookies and other trackers
Trackers are considered to be personal data.
The CNIL uses the term ‘tracker’ for what is more generally called a cookie, i.e. the reading and/or writing of data on the user terminal, whether on a computer browser, a smartphone, a vocal assistant, a connected TV or any other connected object.
- In France, the CNIL specifies « Cookies, Fingerprinting, Pixels or any other identifier»
- In the UK, the ICO specifies « Cookies and similar technologies »
- In Germany, the DSK specifies « Pixel, Fingerprinting-Methods, IP-Adresses, Cookie-IDs, Advertising-IDs or Unique-User-IDs »
Their placement must be subject to a request for consent, as specified in the article "Consent Management".