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Privacy & measurement

Does cookieless analytics need consent or a cookie banner?

The quick answerSometimes. The absence of cookies alone does not decide whether consent is needed. The answer depends on what information is accessed or processed, why it is used, the applicable rules and the rest of your website’s setup.

What our standard tag actually does

Visitor Tracking’s standard pageview tag does not set tracking cookies or persist a visitor ID in localStorage or sessionStorage. It sends page and browser information to the analytics service. The server processes the connection’s IP address for identifier creation and geolocation, but does not save raw IP addresses in the analytics database.

Anonymous identifiers group activity using the website, IP address, browser user-agent and a rotating salt. Event-level activity is retained for reporting. These technical choices explain the product; they are not a certification that every installation qualifies for a consent exemption.

What the current UK guidance says

The ICO describes a statistical purposes exception for certain uses of storage and access technologies. Conditions include using aggregate information to improve the service, providing clear information and offering a simple, free way to object. Individual monitoring, advertising purposes and retaining individual-level information beyond the necessary aggregation process can fall outside the exception.

This is narrower than “all analytics is exempt”. Do not assume Visitor Tracking qualifies automatically: its reporting retains event-level activity. Review your actual implementation, data handling and purpose against the guidance. Personal-data processing can also bring separate UK GDPR obligations.

Read the ICO’s current exceptions guidance

Review the whole website before changing a banner

Changing your analytics tool does not change what your advertising pixels, video embeds, chat widgets or other scripts do. A website may still need a consent mechanism for those technologies. The requirements can also differ between the countries where you and your visitors are located.

If your implementation requires consent, arrange for collection to follow that choice. If you rely on an applicable objection mechanism, ensure it actually stops the relevant collection when used. A sentence in a privacy notice does not, by itself, change how a script behaves.

  • List the scripts and embedded services that run on your pages.
  • Record what each collects, its purpose, and whether browser information is stored or accessed.
  • Review the applicable rules and any exemption conditions for that purpose.
  • Make your notice and consent or objection controls match the actual implementation.

Read our cookieless measurement approach

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