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by tremon 487 days ago
fingerprint a unique user

I don't think this is correct, or at the least it's unfortunately phrased. If your fingerprint is so specific that it can distinguish unique users, it is covered under GDPR compliance. I don't know too much about the CCPA so not sure if it's the same there.

Yes, you are allowed to collect device statistics such as form factor, viewport size etc. But if you can distinguish between two different users with identical devices accessing your site at the same time, under GDPR you have an obligation to inform [14]. And if you can recognize a returning user across sessions, you also need consent.

[14] https://gdpr-info.eu/art-14-gdpr/

1 comments

If the random user ID is truly anonymous (so, cannot be linked back to an identifiable person even with other data you have), it is not personal data under GDPR and no obligation to inform or consent is needed. If the data processor stores any information that makes PII attribution possible then, and only then, does it fall under GDPR, CCPA, etc. That random ID being persisted on the device allowing for subsequent attribution is still not PII sensitive unless/until the aforementioned identifiability barrier is breached. This is exactly why prominent analytics platforms (Plausible, Matoma, Mixpanel if configured correctly, etc) all offer data hygiene barriers.

I suspect what's happening here is that the word "user" is making things ambiguous here. It was meant in the context of attributable session, not as the data subject as per GDPR language for example.