International privacy compliance

snorklee is designed to support privacy-first audience measurement: no analytics cookies, no persistent visitor identifier, no advertising, no resale and no replay. This is a strong basis for documented GDPR/ePrivacy use in an international context, but it is not an official certification.

#International position

The European baseline is GDPR + ePrivacy: limit collection to audience measurement and ordinary site administration, avoid persistent identifiers, reduce stored data and document the purpose. snorklee is designed for that use case.

The starting point is simpler than an exemption: Article 5(3) of the ePrivacy Directive only requires consent to read or write information on the visitor's device. snorklee neither stores nor reads any cookie or local storage for measurement purposes — so the consent obligation is never triggered. The absence of retained personal data (no IP, a non-reversible daily pseudonym) reinforces this finding.

National authorities can interpret some details differently. As a complement and only in France, the CNIL "audience measurement" framework provides an additional self-assessment grid; it is neither the primary basis for the absence of a banner nor a certification. Outside the EU, validate the configuration with your DPO or local counsel if your risk is high.

#What lowers risk

• No analytics cookies.
• No cross-site identifier.
• No advertising profile.
• No UTM / campaign parameters collected: they are stripped on receipt and never stored, keeping measurement focused on audience statistics rather than marketing targeting.
• IP and User-Agent used transiently server-side, not stored raw in analytics events.
• Referrers and outbound links kept as hostnames only.
• Dashboard data shown as statistics, not visitor timelines.
• Opt-out, DNT and GPC honored.

#What you must do

• Mention snorklee in your privacy notice.
• Describe the purpose: audience measurement and site improvement.
• Do not send emails, customer numbers, CRM identifiers or sensitive data in events.
• Keep snorklee for audience measurement, not advertising targeting.
• Document your legal basis, often legitimate interests with a balancing test.
• If you re-combine these statistics with your own data (orders, CRM, server logs) to re-identify a visitor, that re-combination is your own processing, under your responsibility — it falls outside snorklee's anonymous scope.

#Simple wording

You can describe snorklee as an audience measurement tool with no analytics cookies, no advertising identifier and limited retention. The goal is to explain the setup simply: understand site usage, improve content and follow overall performance, without advertising profiles or visitor timelines.