Is Adobe Analytics GDPR compliant?

What does Adobe Analytics do?

Enterprise measurement, usually arriving through Adobe's tag manager. Its audience-manager component sets cross-site identifiers, which puts it closer to advertising than to plain traffic counting.

Does Adobe Analytics need consent?

Yes. Adobe Analytics is Analytics, which is never strictly necessary for a website to function. Under ePrivacy Article 5(3), and its national transpositions, storing or reading anything on the device for that purpose requires consent first, and that consent has to be as easy to refuse as it is to give.

ePrivacy Art. 5(3) · TDDDG § 25 (DE) · TKG 2021 § 165(3) (AT) · GDPR Art. 6(1)(a)

Does Adobe Analytics send data outside the EEA?

Yes. Adobe Analytics processes data outside the European Economic Area, so you need a transfer mechanism under Chapter V and you have to say so in your privacy policy. In practice this means standard contractual clauses, or a provider certified under the EU-US Data Privacy Framework.

GDPR Art. 44 · GDPR Art. 46

What can I use instead of Adobe Analytics?

How do we detect Adobe Analytics?

We load your page in a real browser as a first-time visitor who clicks nothing, then look at what it contacted. Adobe Analytics is recognised by requests to omtrdc.net, demdex.net and adobedtm.com, and we report whether it merely loaded or actually sent data, and whether it set a cookie before any choice was made.