Is Google Ads / DoubleClick GDPR compliant?

What does Google Ads / DoubleClick do?

Conversion tracking and remarketing for Google Ads. It links a visit to an ad click and builds advertising audiences, which is never strictly necessary, so it must not run before consent.

Does Google Ads / DoubleClick need consent?

Yes. Google Ads / DoubleClick is Advertising, 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 Google Ads / DoubleClick send data outside the EEA?

Yes. Google Ads / DoubleClick 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 Google Ads / DoubleClick?

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