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Cookie
Durée de conservation
Description
cases
and0
and1
13 months
Eulerian uses this for identification by creating an anonymous identifier tied to the user's device.
What is the legal basis for this retention period?
On the shelf life of tracers
Regarding the duration of conservation of tracers, Eulerian has chosen to apply by default
a shelf life of 13 months
.
Indeed, in its Deliberation No. 2020-092 of September 17, 2020, art.5, on the subject of audience measurement trackers exempt from consent, the CNIL recommends that "the lifespan of the trackers be limited to a period allowing a relevant comparison of audiences over time, as is the case with a period of thirteen months, and that it not be automatically extended during new visits"
On the retention of consent.
Eulerian applies by default
a 6-month retention of consent
.
Indeed, in its questions/answers on the Recommendation Cookies and other trackers of September 30, 2020, the CNIL confirmed that "retaining choices for a period of 6 months constitutes good practice."
Each customer can nevertheless request to apply a different retention period, if they do not wish to keep them for 6 months, upon simple request to their Eulerian Support.
It is essential that the configuration carried out by the Client on the Eulerian side is consistent with that set out by the Client's CMP and/or specified on the Client's website.
On the conservation of data in an active database
The " active base " corresponds to phase 1, that of the current use of the data. During this phase, the duration of data retention corresponds to the duration necessary to accomplish the determined purpose (i.e. the set objective).
In concrete terms, this is the period during which the data is available to the services responsible for implementation (for example, data relating to a patient will be accessible to authorized practitioners for the duration of their
supported).
Intermediate archiving occurs once the data processing objective has been achieved. The data has “fulfilled its initial role” but may prove necessary to meet a legal obligation, or constitute evidence in the context of litigation, for example.
The marketing data collected by Eulerian does not generally fall into categories where the retention period is set by a Law or a CNIL Recommendation.
According to the GDPR, and therefore the national privacy agencies (CNIL, AEPD, etc.), it is up to the data controller to determine the retention period based on the purpose of the processing that he himself has defined.
For the active database of each of its clients, Eulerian has chosen to apply by default
a data retention period of 24 months
, given the information provided by the CNIL.
In the CNIL Practical Guide of January 2020 on the retention period, it is specified that "commercial prospecting operations, prospect data may be kept in an active database until withdrawal of consent or 3 years from the last contact from the prospect". That is to say 3 "rolling" years.
Likewise for audience measurement trackers exempt from consent, in its Deliberation No. 2020-092 of September 17, 2020, art.5, the CNIL recommends that "the information collected through these trackers be kept for a maximum period of twenty-five months."
However, through the Privacy Center features, each customer must choose the duration of retention and purging of their data, by data type, if they do not wish to keep them for 24 months.
It is essential that the configuration carried out by the Client on the Eulerian side is consistent with that set out by the Client's CMP and/or specified on the Client's website.
In accordance with the E-Privacy regulation, the Client must inform its users about the installation of Eulerian cookies in its Cookies policy.
A specific opt-in/opt-out link will be provided to you by your Eulerian support upon request, if you wish to publish it on this page.
In a desire for harmonization between the different territories, Eulerian applies by default similar durations for all countries based on the recommendations of the CNIL, these being generally the strictest, and the servers being located in France.
A Eulerian cookie is placed on my site before the user interacts with my consent banner. Is this normal?
Yes. It is GDPR compliant that Eulerian places an ETUIX cookie before any consent. This is because Eulerian benefits from the consent-exempt collection method for audience measurement.
As such and following the directive of September 17, 2020, the CNIL authorizes Eulerian to place a cookie without consent if and only if it complies with the following specifications:
Have configured the Eulerian Privacy Center with exempt collection
Be limited to the sole audience measurement of the site or application.
Only used to produce anonymous statistics.
Must not lead to a cross-referencing of data with other processing.
Should not allow global tracking of the person's navigation using different applications or browsing different websites.
Data collected as part of audience measurement must be purged after 25 months.