To meet the requirements of the GDPR regarding appropriate technical measures, as part of the processing contract (art. 28), regarding the security of the processing (art. 32), or simply for "privacy by design and default", Piano applies data minimisation and anonymisation principles to its products:
Piano Analytics
|
Data |
Mechanism |
Standard or option |
How is it done? |
PA property concerned |
Example / Description |
|---|---|---|---|---|---|
|
Terminal ID |
Pseudonymisation |
Standard |
Hashing the original value |
Visitor ID |
The value GW_33!BG87-6 stored on Client side (e.g. Cookie), becomes xw_tr78opUI-451 within the Piano Analytics interfaces. |
|
Visitor ID |
Anonymisation |
Standard |
Aggregation of the opt-out traffic |
Visitor ID |
All the opt-out traffic data is aggregated under the same Visitor ID value => "opt-out" |
|
Visitor ID |
Anonymisation |
Standard |
Nulling the concerned value |
Visitor ID |
If an End-User would like to apply its right to be forgotten (deletion), we null the concerned value (e.g. xw_tr78opUI-451 become NULL). |
|
Visitor ID |
Anonymisation |
Option |
Masking of the property |
None |
The Visitor ID is no longer available within the Piano Analytics interfaces. |
|
User ID |
Pseudonymisation |
Option |
Random value |
User ID |
When Visitors logged in on a platform, the customer can assign a single identifier to recognise him across devices. It is highly recommended that the customer provide Piano Analytics with a random ID via the tag (instead of email address for instance), and keep a matching table on his side (e.g. Firstname.Lastname@company.com become 123456). |
|
IP Address |
Anonymisation |
Option |
IPv4 : Truncation of the last octet. For IPv6 : Truncation of the last 10 octets |
None |
The IP address is truncated before being used for the processing of geolocation for instance. |
|
GPS coordinate |
Anonymisation |
Standard |
Rounding (to 1 decimal) |
None |
If used, the GPS coordinate are rounded before being used for the processing of geolocation (e.g. 48.86000061 / 2.33999991 become 48.8 / 2.3). |
|
Any information |
Anonymisation |
Standard |
Nulling the concerned value |
Concerned property |
If an End-User would like to apply its right to be forgotten (deletion), we null the concerned value (e.g. 12345 or Order_101 become NULL). |
|
Any information |
Anonymisation |
Option |
Emptying the concerned value |
Concerned property |
The data controller can empty property during the processing, so no information is stored (see Privacy Flags and Data Manager) |
Other minimization mechanisms
"Contains personal data" flag
Each of the user interactions you measure with Piano Analytics can be qualified using properties.
You can quickly manage hundreds of properties, some of which contain personal information that requires special attention.
To help you ensure good data governance, we provide ""Contains personal data" flag", which simply indicate which properties require particular vigilance from a Privacy point of view when they are used.
Note: these personal data indicators are essential to the proper functioning of the "Extended opt-out" consent management mode.
Data Management for Privacy
Correction and deletion of unwanted data using the Data Management interface of Piano Analytics;
Data Retention
ePrivacy Exemption
Piano Subscriptions
|
Data |
Mechanism |
How is it done? |
Example / Description |
|---|---|---|---|
|
IP Address |
Pseudonymisation |
Hashed wherever displayed within the solutions |
Stored in an obfuscated form |
|
Location / Address |
Anonymisation |
Audit records display geolocation information instead of the raw address |
— |
|
IP Address |
Restriction of transmission |
No longer transmitted to payment providers |
Applies to subsequent transactions |
|
Complete address |
Retention limitation |
Retained in raw logs for one month only |
For security and fraud investigation |
|
Device characteristics |
Restriction of collection |
Scrubbed when device consent is absent |
— |
|
Geolocation data |
Restriction of collection |
Removed, no lookup performed when geo consent is absent |
— |
Piano Audience
|
Data |
Mechanism |
How is it done? |
Example / Description |
|---|---|---|---|
|
Browser/Device ID |
Pseudonymisation |
Random value assigned, no direct link to a real identifier |
— |
|
IP Address |
Restriction of storage |
Transmitted but not stored on Piano servers |
— |
|
Identifier (browser/device) |
Retention limitation |
Expires six months after the last recorded event |
Confirmed in the Piano Audience, Insight and CCE Platform Privacy Policy |
|
Unique identifier |
Retention limitation / Anonymisation |
Removed after twelve months |
Data retained afterward for analysis only, without the identifier |
|
Reporting data |
Anonymisation |
Aggregated |
See the Piano Audience privacy policy |