Is Influ2 GDPR compliant?

What does Influ2 do?

Person-based advertising that aims campaigns at named individuals inside target accounts and reports back who saw and clicked each ad. Naming the recipient makes this unambiguously personal data.

Does Influ2 need consent?

Yes. Influ2 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 Influ2 send data outside the EEA?

Yes. Influ2 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 Influ2?

We load your page in a real browser as a first-time visitor who clicks nothing, then look at what it contacted. Influ2 is recognised by requests to influ2.com, and we report whether it merely loaded or actually sent data, and whether it set a cookie before any choice was made.