Mandatory prerequisite

Mandatory pre-requisite: cookies and privacy

Sirdata Analytics Helper and Google Analytics are so-called “intelligent” tools in terms of privacy, in the sense that they are able, under certain conditions, to adapt to users' choices in terms of cookies and privacy.

This is the case, for example, if Google Consent Mode is activated or if a Consent Management Platform (CMP) compatible with the Transparency & Consent Framework () is present on the page.

When associating Sirdata Analytics Helper with a Google Analytics property, and even if you have not activated Google Consent Mode, in the absence of consent, the cookies linked to this property are deactivated by default as far as possible.

However, you must ensure that the cookies used by Google Analytics are not placed or accessed without consent.

If the user gives consent, an identifier dedicated to the Helper can then be stored in a so-called “first party” audience measurement cookie. This consent must be traceable and auditable, otherwise Sirdata Analytics Helper will ignore it and work without this cookie.

In the absence of consent or a consent signal, Sirdata Analytics Helper may generate a cookieless user ID dedicated to your site based on your legitimate interest.

Although not nominative, this dedicated identifier is based on personal data such as the IP address. The latter can also be used to locate a visitor in an imprecise way.

It is therefore mandatory to carry out all of this processing in accordance with the GDPR, in particular by explaining its purpose (audience measurement) to users, and by giving them the means to object to it.

To implement these prerequisites in terms of consent and the right to object to cookies and the right to object to the processing of personal data, you have four options, as explained below.

1) Use the Sirdata Consent Management Platform (CMP)

If your goal is both compliance and simplicity, we recommend using the Sirdata CMP.

The latter is chargeable, but may cost you nothing if you agree to share the behavorial data of your site users with Sirdata in return for its use.

It has the huge advantage of supporting both Google Consent Mode and the Sirdata Analytics Helper service: consent and the right to object are automatically managed, natively.

If you are not using it yet, all you have to do is create an account at https://cmp.sirdata.io and then generate your CMP configuration.

If you decide to install it, or if you already use it, check that you have selected the “Google Analytics” and “Sirdata Analytics Helper” partners in the “Configuration > Edit partners > Add partners” section.

The transparency and control given to users will then be managed automatically: you can go to(“activation of Sirdata Analytics Helper”).

2) Use 3rd party CMP with TCF

If you cannot use the Sirdata CMP, you can opt to work with any TCF certified CMP.You will find the updated list here: https://iabeurope.eu/cmp-list/Install the CMP and/or make the following settings:

• Publisher Purpose 1 must be enabled and consent-based.

• Publisher Purposes 8 and 10 must be enabled and based on consent or legitimate interest.

The cookieless mode will only work in the absence of consent if you have activated the signals of legitimate interest for purpose 8 (audience measurement).

Also consider declaring Google Analytics processing if you haven't already done so, but that's all you have to do: the Sirdata Analytics Helper service will be able to self-condition thanks to the CMP, and you can go in step III (“activation of Sirdata Analytics Helper”).

3) With a non-TCF certified CMP

If you only use a “cookie banner” or a limited non-TCF certified CMP, you will have to manually indicate the choice signals to the Helper script.You can opt for:

• a CMP that manages consent for cookies only, and manages the issue of personal data processing and the right of opposition via your privacy page

• or use a CMP that manages consent for cookies AND personal data processing based on consent or legitimate interest

In the absence of choice signals, the service will operate without cookies as indicated in section 4) below.

a) Cookie-based mode

To signal :

• consent for tracers AND for the processing of personal data

• OR a consent for the tracers AND a legitimate interest established via the CMP or the privacy page for the processing of personal data to which the user has not objected

Run this javascript code in your page or your Tag Manager:

<script>
    window.sd_gahc = window.sd_gahc || [];
    window.sd_gahc.push("consent");
</script>

b) Cookieless Mode

To report that the user has not (yet) accepted the tracers BUT that a legitimate interest has been established via the CMP or the privacy page for the processing of personal data AND that the user has not done so opposite, run this javascript code in your page or your Tag Manager:

<script>
    window.sd_gahc = window.sd_gahc || [];
    window.sd_gahc.push("no_consent_no_object");
</script>

c) Deactivation

To report that a user has refused tracers AND personal data processing, run this javascript code in your page or your Tag Manager:

<script>
    window.sd_gahc = window.sd_gahc || [];
    window.sd_gahc.push("no_consent");
</script>

A cookie and/or an entry in the local storage will be automatically created, with the name "ga_helper_optout" and the value "1".

They will allow the service to be deactivated, and pings will no longer be sent to the Sirdata proxy or to Google Analytics.

If your CMP does not manage the legal basis of legitimate interest, that you rely on this legal basis for the purpose of audience measurement, and that you wish to activate the cookie mode, you must indicate the nature of the processing in your privacy page and give the user the opportunity to object to the processing.

Here is an example of text to display, with an opt-out link:

In order to establish statistical analyzes relating to the use of our site in a form that does not allow you to be identified by name, we collect data relating to your browsing on our website, such as the timestamp, your IP address, technical data relating to your equipment and your browser). This data is pseudonymized and your IP address is anonymized before being transferred to our analysis tool (replacing the last octet of IPv4 addresses and the last 80 bits of IPv6 addresses with zeros). We carry out this processing on the basis of our legitimate interest (Article 6§1f. of the GDPR), which lies in the need to know our audience better in order to adapt our content, our functionalities and our offers. You can of course object to this processing by<a href="#" onclick="javascript:window.sd_gahc=window.sd_gahc||[];window.sd_gahc.push('no_consent');">clicking here</a> .

4) Without CMP

If you do not use any consent management tool, the service will operate entirely without cookies.

The statistics will work but will lose reliability and relevance.

We strongly advise you to migrate to a TCF certified CMP. If you cannot or do not wish to do so, you must then update your privacy page to:

• Explain which personal data is processed on the basis of your legitimate interest and why (purpose of audience measurement only)

• Give the user the means to oppose this processing by depositing a cookie (and/or an entry in the local storage) named “ga_helper_optout” and having the value “1”

Here is an example of text to display, with an opt-out link:

In order to establish statistical analyzes relating to the use of our site in a form that does not allow you to be identified by name, we collect data relating to your browsing on our website, such as the timestamp, your IP address, technical data relating to your equipment and your browser). This data is pseudonymized and your IP address is anonymized before being transferred to our analysis tool (replacing the last octet of IPv4 addresses and the last 80 bits of IPv6 addresses with zeros). We carry out this processing on the basis of our legitimate interest (Article 6§1f. of the GDPR), which lies in the need to know our audience better in order to adapt our content, our functionalities and our offers. You can of course object to this processing by<a href="#" onclick="javascript:localStorage.setItem('ga_helper_optout',1);">clicking here</a> .

The opt-out link can be, for example, a javascript function that creates an entry in local storage named “ga_helper_optout” and having the value “1”.

​If you have implemented one of these four preliminary solutions, you can proceed to the next step (“activation of Sirdata Analytics Helper”). Remember that this is a legal obligation , and that in the absence of such measures we reserve the right to terminate the service without notice.