GDPR and privacy controls

Our GDPR approach

UserTrail is built to support privacy-conscious website analytics. This page explains controls and responsibilities relevant to GDPR and UK GDPR. It is not legal advice and should be reviewed with your legal team before relying on it for compliance.

Roles

For visitor analytics collected on customer websites, the customer is typically the controller and UserTrail acts as a processor. For UserTrail account, billing, security, and product usage data, UserTrail may act as a controller.

Customer responsibilities

• Identify and document the lawful basis for using UserTrail on your website.
• Provide clear privacy notices to visitors.
• Obtain consent before non-essential analytics/tracking where required.
• Configure masking and private-element exclusions before collecting data.
• Respond to visitor data rights requests where you are the controller.

Product controls

• Password and payment fields should be excluded from collection.
• Private elements can be marked for masking or exclusion.
• Customers can configure tracking settings, survey behaviour, and team permissions.
• Role-based permissions help limit access to analytics data.
• The tracking script is designed to be lightweight and configurable.

Data minimisation

UserTrail aims to collect behaviour signals needed for analytics while avoiding unnecessary sensitive data. Customers should review pages, forms, surveys, and masking rules before enabling tracking on production websites.

Consent mode

Consent mode is implemented by the customer on the customer website. Where consent is required, customers should not load tracker.js until valid consent has been granted. Customers can do this by dynamically adding the UserTrail tracking script after their consent management platform or custom consent flow confirms consent.

If consent is withdrawn, customers should stop loading the tracking script on future page views and should follow their own consent-management process for any additional cleanup or data rights requests.

Data subject rights

Customers are responsible for handling visitor requests when they are the controller. UserTrail can assist customers with access, deletion, correction, or export requests where technically possible and where the relevant identifiers are available.

Security

• Access to dashboard data is authenticated.
• Team permissions restrict who can read, write, administer, or own a site.
• Infrastructure should be configured with internal-only databases, protected secrets, and least-privilege access.
• Database backups are performed daily.
• Staff do not have direct access to customer data as part of normal operations.
• Production access is limited to operational needs and should follow least-privilege controls.
• Customers should limit team access to people who need it.

Breach response and incident process

• UserTrail follows a standard incident response process: identify and triage the issue, contain the incident, investigate scope and impact, remediate the cause, restore normal service, document findings, and improve controls.
• Where a personal data breach is confirmed, UserTrail assesses whether notification is legally required and will notify affected customers without undue delay where UserTrail acts as processor.
• Customers remain responsible for regulatory and data subject notifications where they act as controller, with UserTrail providing reasonable assistance where required.

Data Processing Agreement

Customers that use UserTrail to process personal data may need a Data Processing Agreement. Contact info@usertrail.io if you need a DPA or have processor/subprocessor questions.

International transfers and subprocessors

UserTrail may rely on hosting, storage, email, security, payment, and infrastructure providers. Customers should review subprocessor and transfer details before using UserTrail for regulated data.

Contact

For GDPR questions, contact info@usertrail.io.