Security & GDPR
GDPR-compliant tracking — no IP, no third-party cookie
Most measurement tools have a GDPR problem because they measure people. A short link measures a campaign: who clicked is none of our business; what the click brought in is.
Three zeros, written in the policy
0 stored IP address
0 device fingerprint
0 third-party cookie
The IP is read in memory to determine the country and filter out bots, then discarded — it is never written to the database. Fingerprinting is forbidden by the product’s design, not merely discouraged.
Advertising pixel vs. measured link
The pixel follows a person across websites. The link counts passes through a door you own. That difference changes everything under scrutiny.
| Advertising pixel | Subtraq link | |
|---|---|---|
| What is measured | the person, across websites | the pass through your link |
| Where it lives | in your site’s pages | on our domain — nothing on yours |
| Third-party cookie | often | never |
| Device fingerprint | common | forbidden by design |
| IP address | sent to the provider | read then discarded, never stored |
| Survives ad blockers | less and less | yes — a link cannot be blocked |
| Referrer kept | full URL, often | host only, never the path |
Subtraq column: privacy policy, sections 3 and 4. Pixel column: publicly documented generic behavior — each provider differs.
A design choice
Data we never collect
Each point is a choice, not a technical constraint — and it is written in the contractual document, not just on this page.
The referrer, truncated
We keep instagram.com, never the full path — it can contain personal data, so we do not take it.
No cross-device tracking
No one is stitched together across their phone and their computer, beyond what your own application explicitly identifies.
Raw data expires, aggregates stay
Raw clicks live thirteen months; aggregated statistics no longer contain anyone — that is why they can stay.
Who is responsible for what
Your rules. We apply them.
For the clicks and sales from your campaigns, your agency is the data controller and Subtraq acts as data processor under Article 28 — on your instructions, nothing else.
In practice, it is your responsibility to inform your visitors of the tracking in place, and ours to process only what is necessary. A Data Processing Agreement (DPA) is available on request.
For your DPO
Data hosted at Hetzner in the European Union and stored there only, publisher established in the United States (transfers detailed in §6 of the policy), IP never written to the database, raw clicks purged at thirteen months, anonymous aggregates, DPA on request at [email protected]. This paragraph is designed to be copied into their questionnaire.
The full policyA DPO’s questions
Where is the data hosted?
At Hetzner, in the European Union. There is no American CDN in front of the database, no replication of personal data outside the EU (only link destinations are copied to Cloudflare's network for redirection), and no third-party analytics tool connected to it.
Do we need a checkbox in our cookie banner?
The link itself sets no third-party cookie. The optional SDK writes a click identifier in the localStorage of your client’s domain — a first-party store, to be mentioned in their privacy policy. That is your responsibility as publisher, and the policy says so plainly.
Can a visitor be identified?
Not by us. No IP, no fingerprint, no full referrer URL: raw clicks carry no identity. An identity only appears if your own application calls lead() or identify() — and it then lives in your workspace, under your responsibility.
How long does the data live?
Raw events: thirteen months. Statistical aggregates (daily, country, device totals): indefinitely, because they no longer contain personal data.
What happens if we leave?
Your data exports to CSV, the workspace is deleted on request, and the deletion is real — not a “deactivated account” that keeps everything.
Show this page to your DPO
If a line is missing, write to us: the policy is a living document, corrected and dated. And if everything checks out, the free account takes two minutes to create.
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