It is now possible to configure Clicky – Web Analytics directly in Complianz, without needing a separate plugin or a manual implementation. After choosing “Clicky” as analytics tool in the wizard you can add your Site ID. This is how Complianz adds your Clicky script:
Due to Clicky’s native settings it is not possible to configure Clicky to be set prior to consent. This is due to the fact it will set a UserID cookie, even when configured for GDPR in Clicky’s dashboard. The below explanation from Clicky is not supported by e-Privacy guidelines, whereby legitimate interest is not possible as a legal basis;
The one exception is a tracking cookie containing a randomly generated Unique ID (“UID”). This cookie does not identify who a visitor actually is or reveal anything else about them, but the General Data Protection Regulation (“GDPR”), as well as the California Consumer Privacy Act (“CCPA”), consider a UID to be “personal data”. However, per Article 6 of the GDPR, this cookie does not require a visitor’s direct consent as it is well within the “legitimate interests” of any web site to know how many unique visitors they have, which is best accomplished with a UID cookie. The CCPA is an opt-out law, so UID are allowed by default. The ePrivacy Regulation (ePR) is not yet law as of May 2018, but we don’t anticipate any further impact.
We however still recommend to use the Clicky’s privacy settings, which can be found under user preferences.
Using Clicky without consent
We don’t recommend using Clicky without consent, but the possibiliy is still there. Instead of answering Clicky as analytics tool under Cookies – Statistics, you can choose: “Yes, Anonymous”
Now you can add the following script yourself to make sure it will fire on any consent level: