Use Google Analytics without cookies? And cookieless web analytics

Published on Mar 22, 2022 and edited on Sep 26, 2022 byImage of Iron BrandsIron Brands

It has been the talk of the town lately. “Google Analytics might be banned in Europe.”

The DSB in Austria was the first to openly question the legal use of Google Analytics. Various popular news outlets such as Hacker News & TechCrunch picked up on the news and spread the word.

Not so long after the DSB, their french counterpart, CNIL, also stated that Google Analytics conflicts with GDPR. A few months later, Italy (Garante) and Denmark (Datatilsynet) joined the club.

Organizations, especially within the EU, are questioning themselves now if they could still use Google Analytics legally. And what happens if they can’t? Will they lose all the valuable insights as well?

In other words: Will there be life after Google Analytics?

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Don't be so dramatic (animated)

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Let’s find out 👇

  1. How does Google Analytics work?
    1. Does Google Analytics use cookies?
    2. Is Google Analytics using first or third-party cookies?
    3. How long do Google Analytics cookies last?
    4. How do I anonymize Google Analytics?
    5. Can an IP address be anonymized?
    6. Can cookies be anonymized?
    7. Can I use Google Analytics without cookie consent?
    8. Do I need a cookie banner when using Google Analytics?
    9. Do I need to include Google Analytics cookies in your privacy policy
    10. Can you I Google Analytics without cookies?
  2. Website analytics without cookies
    1. What data does Simple Analytics collect?
    2. How can Simple Analytics count unique visitors?
    3. Can you still track events?
  3. Cookieless web analytics vs. Cookie based web analytics
  4. When should you consider a privacy-first alternative?

1. How does Google Analytics work?

Google Analytics is by far the most used analytics tool on the planet. At least 86% of the websites that use an analytics tool use Google Analytics. It’s a free tool, but it comes at a cost.

To understand why Google Analytics has come under pressure lately, it’s key to know how it works and what implications it brings.

1.1 Does Google Analytics use cookies?

If you install Google Analytics to track your website performance, you need to set first-party cookies to:

  • Identify unique visitors
  • Identify unique sessions
  • Identify traffic source information
  • Determine the start and end of a session

Want to learn more about what cookies are? Check out this blog post.

You can access the cookies when you open the developer toolbar (right-click + inspect). By navigating to the ‘application’ (or ‘storage’) tab and clicking on ‘cookies,’ you can see which cookies are used by the specific website.

Cookies of Indeed.com inspected via browser

Cookies of indeed.com inspected via browser

As you can see from the screenshot above (taken from the Indeed homepage), the cookie’s name is indicated as ‘_ga’. The second arrow on the screenshot indicates the value:

GA.1.2.1680553188.1645472981

It consists of a version name, the first part, and a unique ID, which is the second part.

The version name: GA.1.2.

The unique identifier: 1680553188.1645472981

The unique identifier consists of two parts. The first part is a randomly generated number. The second part is a timestamp for the first time the visitor visited the page. That way, Google can identify whether someone is a unique visitor or not.

Whenever someone visits a website, Google Analytics looks for the cookie, which is provided by the web browser. If there is a cookie stored, Google knows that the visitor is not unique. If Google can’t find a cookie, it means it’s a first-time visitor that visited the website. This is how Google Analytics distinguishes between unique visitors and pageviews.

1.2 Is Google Analytics using first or third-party cookies?

Google Analytics uses first-party cookies. The difference is that first-party cookies are only issued when the user is directly using the website. The website that issues the cookies is also to only one that can read them.

In contrast, third-party cookies are issued by other websites than the one you are visiting. They are mainly used for remarketing purposes.  If you see ads from a website you visited in the past, it means that third-party cookies are tracking you.

1.3 How long do Google Analytics cookies last?

Both first and third-party cookies can be used with or without an expiration date. Cookies that are set with an expiration date are called persistent cookies. They stay on your device even after you close the web browser. Cookies without expiration date are called temporary cookies and are removed after you end your web session.

_ga is the main cookie for Google Analytics. It’s a persistent cookie that stays for two years(!). However, you can change the cookie’s duration to, for example, one year by following these steps.

You can overwrite the default of two years directly in the script (if you have an old Google Analytics script on your website). All you need to do is add the following ‘cookieExpires’ parameter to the script that issues the cookie: {‘cookieExpires’: 31536000}. The value here is noted in seconds and precisely a year.

You can also change it in Google Tag Manager, which is even easier:

  • Navigate to the Google Analytics Page View Tag
  • Check this box: Enable overriding settings in this tag
  • Click on: open more settings
  • Open Fields to Set
  • Click on: Add Field and fill out the two fields below. Indicate 31536000 in the value box to change the duration to one year.

1.4 How do I anonymize Google Analytics?

Long story short: you don’t. Here’s why.

The GDPR sets a high bar for anonymization, and for good reason: Since the GDPR itself only applies to personal data, any anonymized data falls outside the scope of the GDPR and is not protected.

Data is considered anonymized when “the data subject is not or no longer identifiable”. Crucially, data is considered to be identifiable as soon as the data subject can be singled out- that is, as soon as “he or she is distinguished from all other members” of a group of  persons. This means that data can be personal even if it tells us absolutely nothing about a data subject.

Google Analytics stores two distinct types of personal information from a website’s user: cookies and IP address. As we will see, neither of these can be anonymized.

1.5 Can an IP address be anonymized?

GA provides its customers with an IP anonymization option which anonymizes IP addresses by setting a portion of each address to zeros before storing it.

However, as noted by the Italian DPA in its recent decision banning GA, Google can make the data subject identifiable by combining the truncated IP address with other data they control, such as cookies or credentials from the user’s Google account. GA’s so-called IP anonymization is not proper anonymization under the GDPR, but rather pseudonymization. Unlike anonymized data, pseudonymized data is still personal data under the GDPR.

Bottom line: GA’s IP anonymization falls short of proper anonymization under the GDPR. If Google really wanted to enhance user privacy with regards to IP address, they could just not store it to begin with, as doing so is not strictly necessary.

1.6 Can cookies be anonymized?

Every cookie contains two pieces of information: a version number and a unique identifier. Because they contain a unique identifier, cookies can single out a user and are always personal data. It doesn’t matter whether or not you can actually identify a user- that is, trace back their identity through the identifier alone, or by combining it with other data about the user. Being able to single out users is enough to make cookies personal data, and unique identifiers make this possible by definition.

Of course, you could theoretically anonymize a cookie by removing the identifier, but that will leave you with no information other than the cookie’s version name, which would make it perfectly useless.

Bottom line: no, you cannot anonymize cookies. This goes for all cookies, not just GA cookies.

No. Under the ePrivacy Directive, all cookies require the user’s consent except for strictly necessary cookies. Cookies for web analytics always require the user’s consent, whether they are from GA or from a different software. If you use cookie-based analytics without a cookie banner, you are violating the GDPR. And if your website features deceptive cookie banners or “cookie walls”, you are also violating the GDPR by collecting invalid consent- but that’s a story for another day.

When you install Google Analytics, you need to show a cookie banner to ask for consent. To ensure Google Analytics works in compliance with privacy regulations, you need to take the following steps:

  1. Don’t store cookies if you don’t have consent.
  2. Make sure Google Analytics cookies are only activated after users have given their consent
  3. Be transparent regarding the details of the Google Analytics cookies you are using. According to privacy regulations, consent is only valid if it constitutes an informed decision. You need to explain what type of cookies you are using.
  4. Compile detailed information in your privacy policy. You need to include all Google Analytics cookies and other personal data tracking mechanisms in the privacy policy
  5. Turn on IP anonymization in your Google Analytics account and make sure that it uses pseudonymous identifiers.

Not only are cookies privacy-invasive (that’s the reason for the cookie banner), but you will also lose data.

If a website visitor does not consent to be tracked, the cookie won’t be stored on the visitor’s device. This means your website metrics are not as accurate as they may seem. The numbers you see in your dashboard are underperforming your actual numbers.

This is true for Google Analytics and for every web analytics tool that uses cookies.

More and more people become aware that they are being tracked around the internet, meaning that it is very likely that fewer people will give consent. This results in less accurate data.

1.9 Do you need to include Google Analytics cookies in your privacy policy

If your website issues Google Analytics cookies, you need to include this in your privacy policy. By law, you must be transparent about the cookies your website issues. If third-party cookies are issued, you need to address this separately in your privacy policy. It is also against Google’s terms & conditions not to disclose that you are using cookies. If this is not addressed in your privacy policy, you illegally use Google Analytics.

1.10 Can I use Google Analytics without cookies?

Yes, but you probably don’t want to. Here’s why.

Google Analytics is a tool to show you how your website is performing by tracking specific metrics. For those metrics to show accurate results, Google Analytics needs cookies to be installed on your website. If you want to try using Google Analytics without cookies, you are left with a broken analytics tool.

Google introduced a Consent mode to try and lessen GA’s dependence on cookies. The option was introduced two years ago and is still in beta. When the option is active, GA works in a different way- mainly, when a user refuses consent, it doesn’t install new cookies or read existing ones. At the same time, GA will track certain events on a website and use them along with other data Google controls in order to estimate conversion rates through machine learning models.

In order to do so, GA generates synthetic data based on actual data it collects from users. According to Google’s own documentation, this data comes from users who do accept GA’s cookies on each website, and from users monitored through Google’s AAID tracker.

If Consent mode is using data from cookies, then websites will still need to gather consent from users. In such a scenario, Consent mode can be useful when you want better data about users who do not consent to being tracked. But as long as cookies are in use for a portion of the user base, Compliance mode does not make GA any less invasive or help with compliance in any way. Websites still need a cookie banner and policy and are still processing personal data through GA.

A website could also set GA to run in Consent mode by default for all users, which will leave them relying on AAID data alone. AAID is a tracker embedded on any Android system. While not technically a cookie, it essentially functions like one. Each AAID is unique for each device and is tracked by default by Google unless the user opts out through system settings. We are willing to bet that this opt-out system implemented by Google violates a laundry list of data protection rules, chiefly the consent requirements of the ePrivacy Directive, the principles of transparency and privacy by default, and the duty of information of the controller under the GDPR. Unsurprisingly, AAID is currently being investigated by the French supervisor. Long story short: AAID is unethical, shady and probably illegal. And just to be clear: if you rely on AAID, you are violating the law as well and may be held liable for Google’s non-compliance.

Additionally, Android is only available on mobile. User experience is radically different between mobile and computers, so GA may create inaccurate synthetic data when relying on tracking from AAID alone. We can’t be 100% sure about this since only Google knows how their machine learning algorithms work- but it looks like a reasonably safe bet.

Finally, it should be mentioned that GA still processes personal data in Consent mode by collecting IP addresses. This is an issue because personal data will be forwarded to the U.S. without adequate safeguards for the users’ privacy. European supervisors are starting to ban Google Analytics for this reason- and if you’re curious, we have a blog about that, too.

If you are looking for website analytics without cookies, you should probably look at some alternative solutions.

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Rowan Atkinson as Mr. Bean with his classic eyebrows (animated)

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2. Website analytics without cookies

The biggest difference between website analytics with cookies and web analytics without cookies is the trade-off between privacy and data:

The deeper you want to analyze on the individual level, the less-privacy-friendly you will need to be.

2.1 What data does Simple analytics collect?

At Simple Analytics, we lean heavily towards the privacy side of the trade-off.

After installing Google Analytics scripts for several years, Adriaan, our founder, didn’t feel quite right to pass on so much data to Google for free. So he came up with a solution to provide insights without invading the privacy of website visitors.

This means that website visitors don’t need to interact with an annoying cookie banner before they enter your website. It also means that we are ‘out-of-the-box’ compliant with GDPR

I hear you think… “This sounds good, but what data will I be missing? Can you still identify unique visitors if you don’t use cookies? And can you still track events?

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Well… Yes, you can, but don’t just take my word for it. See for yourself.

2.2 How do we identify unique visitors?

We have to be honest here. Calculating unique visitors is a lot more difficult without cookies. As explained earlier in this post, Google Analytics can spot a unique visitor based on the fact if it has already placed a cookie or not.

Other “privacy-friendly” alternatives in the space anonymize IP addresses to check for unique visitors. While from a privacy perspective, this is more privacy-friendly, it is still considered personal data.

We do it even better.

We use the referral domain to see if someone is a unique visitor. When a user navigates to your website, the browser sends information about the referrer along.

Let’s look at the illustration below. Someone visits a particular website (randomwebsite.com) and navigates to your website (yourwebsite.com). The browser sends the referrer (randomwebsite.com) to yourwebsite.com. This referrer is very useful to figure out where traffic is coming from.

When a user lands on your website without visiting another website, we record it as a unique visit:

2.3 Can you still track events?

It is one of the most common questions we get. With Simple Analytics, it is still possible to track event counts. It is based on aggregate data, meaning that we can’t collect data on individuals triggering the event.

You can add our automated events script or add your custom events to see your event counts. We can estimate a conversion based on the traffic to that specific page (and we are working on a user-flow section).

In addition, you can still use URL Parameters to see where your traffic is coming from. For example, if you want to see the traffic to a blog post or newsletter.

The general take on cookieless web analytics tools is that you trade more privacy for fewer data. This is true because you collect fewer data points. However, it does not necessarily mean that analytics without cookies is less accurate. Cookie-based web analytics tools are not bulletproof.

The use of adblockers affects your Google Analytics data.

Adblockers block Google Analytics scripts. They prohibit the issuance of cookies on your device. Adblocker users visiting your website will be missed by Google Analytics.

The use of adblockers is rising. Adblock, a popular adblocking tool, counted 735 million (!) users in 2019 and grew significantly among young people. Internet users are getting more aware of their digital fingerprints and the importance of digital privacy. This will only be accelerated in the future.

Adblockers can block the Simple Analytics script (however, to a lesser extent). We have created an adblocker bypass to ensure that we are not blocked and that you get the complete picture.

Cookie banners allow visitors to opt-out of your Google Analytics data

When using Google Analytics, you need to display a cookie banner on your website. Next to the fact that cookie banners hinder your user experience, they also affect your analytics.

Visitors indicating they do not want to be tracked will not be visible to Google Analytics. You will miss this data. Research suggests that most visitors still consent without even reading the cookie statement. However, this is about to change. Privacy laws are hammering down on consent practices. Google is introducing new options to reject tracking cookies.

It has been straightforward to give consent and accept cookies by pressing a button. However, indicating that you don’t want to be tracked has been extremely difficult. You need to open the settings and configure multiple pages. This is also why most internet users ‘just’ give consent to not deal with the hassle. If saying ‘no’ becomes as easy as saying ‘yes,’ we expect fewer people to give consent.

Effectively, this means less accurate data in the Google Analytics dashboard. This is not an issue with Simple Analytics, as you don’t need to ask for consent. We do not use cookies. Therefore, our page views are more accurate than page views in Google Analytics.

Internet users removing their cookies are miscounted as unique visitors

After removing their cookies, Google Analytics will mistakenly report returning visitors as unique visitors. As privacy awareness grows, more internet users will often remove their cookies. This will result in less accurate data concerning unique visitors in Google Analytics.

Internet browsers block third party cookies

Multiple browsers such as Safari and Brave don’t allow the use of third-party cookies, and even Google Chrome will stop supporting third-party cookies in 2023. Brave is a new kid on the block and identifies itself as the “anti-advertising” browser.” Brave users can block ads and first-party cookies as well. It currently has 50 million monthly active users and is growing rapidly. Another indication that the future will be cookieless.

4. When should you consider a privacy-first web analytics tool?

Ask yourself the question, what data do you really need? Do you need to track every individual move of a website visitor? If that’s the case, Simple Analytics might not be your tool.

We are here for companies that want to be part of the future. Companies that want to see the big picture while acting in the best interest of their visitors.

So if you are looking for a solution, that is…

…GDPR-compliant ‘out of the box’

…Cookieless by design

…Gives you the big picture

…And Simple to understand and use (see our live dashboard)

You might want to give us a try.