Is Cloudflare Turnstile GDPR compliant?

What does Cloudflare Turnstile do?

Cloudflare's challenge, which usually verifies without asking the visitor to solve anything. It sets no tracking cookie and is generally treated as strictly necessary where it protects a form.

Does Cloudflare Turnstile need consent?

No consent is needed for Cloudflare Turnstile on its own, because it does not store or read anything on the device beyond what is strictly necessary. That is not a free pass: it must still be named in your privacy policy, and the request itself still reveals the visitor's IP address to the provider.

GDPR Art. 13(1)(e)

Does Cloudflare Turnstile send data outside the EEA?

Yes. Cloudflare Turnstile 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 Cloudflare Turnstile?

How do we detect Cloudflare Turnstile?

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