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remon | 1 year ago

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.

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