On Tue, Jan 08, 2019 at 08:38:01PM +0100, Benjamin Berg wrote:
> > We can certainly implement a setup that does not collect or store the
> > UUID together with the IP address or timestamp. Send the UUID as a
> > HTTP header, don't log it, send the UUID off to a counting service
> > (*). If we make sure the UUID is protected in transit, sent only to
> > our own servers (or servers configured by the user), and not collected
> > or stored in a personally identifiable way, I suspect that we're
> > meeting our obligations under the GDPR, though we'd need to
> > double-check any selected solution carefully.
> 
> You are right that it is possible to immediately discard or obfuscate
> the information.
> 
> But, as Nicolas pointed out, the argument here is that the UUID itself
> likely needs to be considered "personal data" in the GDPR sense. And
> even doing something as minimal as that seems to imply "processing"[1]
> the data in the GDPR sense.

  Nb. “UUID” sounds terribly technical. Can we use some term which
is already known and understood by users, e.g. Advertising ID?
-- 
Tomasz Torcz                                                       72->|   80->|
xmpp: zdzich...@chrome.pl                                          72->|   80->|
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