Is Common Room GDPR compliant?

What does Common Room do?

Go-to-market intelligence that stitches visits on your site to community, social and CRM profiles. Joining site behaviour to an external identity is profiling and cannot rest on legitimate interest alone.

Does Common Room need consent?

Yes. Common Room 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 Common Room send data outside the EEA?

Yes. Common Room 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

How do we detect Common Room?

We load your page in a real browser as a first-time visitor who clicks nothing, then look at what it contacted. Common Room is recognised by requests to cr-relay.com and commonroom.io, and we report whether it merely loaded or actually sent data, and whether it set a cookie before any choice was made.