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Protection des données et sécurité

Privacy policy text block: revenue reconciliation

Your privacy policy must name revenue reconciliation as a purpose of its own alongside tracking, with the legal basis (legitimate interest under Art. 6(1)(f) GDPR), the data, Metrunio as processor, the retention period and how to object. Metrunio’s privacy policy does not inform your buyers. The block below is a draft for you to adapt.

What does my privacy policy need to say about revenue reconciliation?

Your buyers read your privacy policy, not Metrunio’s. If you use revenue reconciliation, it therefore belongs in your own: separate from tracking, so that nobody takes a refusal in the banner for the end of all processing. Fill in the details in square brackets; they must match your additional instruction. The German version addresses buyers formally, as is usual in privacy policies.

The text block

Revenue reconciliation. We reconcile our shop’s revenue with the measurement service Metrunio so that our revenue figures are complete, duplicate transactions are detected and refunds are matched to the right order. This purpose is separate from tracking and advertising measurement. It concerns orders for which you made no decision about tracking [or refused tracking]. Your decision in the cookie banner still applies: without your consent, your order is not linked to your visit, your browser or an advertisement and is not passed on to advertising platforms.

Data processed: order number [or an order key derived from it], type of transaction (order, subscription renewal or refund), amount and currency, and the day of the order without the time. Name, address, email address, customer number, the subscription ID, ordered items, identifiers of your browser or device, IP address and click or advertising identifiers are not processed for this purpose. The data remains personal data, because we can link the order number to your order.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest is to record our revenue completely and in a way that can be reconciled with our shop, to detect duplicate transactions and to match refunds. Metrunio, a service of Kokolorum GmbH, Industriering Ost 66, 47906 Kempen, Germany, processes the data on our behalf under Art. 28 GDPR [with the sub-processors named in the data processing agreement]. The individual records are deleted [N] days after the day of the order.

Objection: you may object to this processing at any time on grounds relating to your particular situation (Art. 21(1) GDPR). To do so, write to [contact] stating your order number. We will then delete the data for this order at Metrunio and block the order number for further transmissions. Withdrawing your consent to tracking ends tracking; it does not affect an order we transmitted without your consent solely for revenue reconciliation. That is what the objection is for.

What you adapt

  • The bracketed part about refusals only if the additional instruction is activated for your account. Without it, only orders without a decision count.
  • Order key, retention period and sub-processors as stated in your additional instruction and your data processing agreement.
  • The contact for objections. How to carry one out is explained in the article “Additional instruction for revenue reconciliation”.

Legal note

The text block does not replace a review of your privacy policy or your own balancing of interests. Whether the legitimate interest supports the processing after an explicit refusal of tracking in your shop is for that balancing to decide.

Dernière vérification le 16 oct. 2026

Également demandé

  • Shop privacy policy: orders without consent
  • Do I have to mention revenue reconciliation in my privacy policy?
  • Metrunio privacy policy text block
  • How can buyers object to revenue reconciliation?
  • Legal basis for orders without consent

Articles connexes

  • Additional instruction for revenue reconciliation

    When do orders count after a refusal in the cookie banner?

    Orders your shop reports server-side after a refusal in the banner only count if the additional instruction for revenue reconciliation is activated for your account. You fill it in and sign it, and then we activate it; without it Metrunio rejects such orders. Orders with no decision in the banner at all count even without the instruction.

  • Does consent apply to server events too?

    Do I need consent when I send server-side?

    Yes, because server-side processing does not mean exemption from consent: pass consent_state and consent_purposes in the event; without matching consent an event is rejected. The exception is purchases and refunds with consent_state unknown: they are stored for revenue reconciliation, with their order number and without browser, customer or advertising identifiers, count towards measured revenue and appear as not attributed with the reason “No consent”. With denied this only applies if the additional instruction for revenue reconciliation is activated for your account. You can switch revenue reconciliation off in the portal under Privacy; such an order can only be attributed via the checkout, if you switch that on.

  • Do I need a cookie banner for Metrunio?

    Do I need consent and an entry in the cookie banner for Metrunio?

    Yes: Metrunio measures visits and ad contacts only with consent, so it belongs in your cookie banner and your privacy policy together with its storage entries. Without consent it accepts at most purchases and refunds for revenue reconciliation, without browser, customer or advertising identifiers. The legal framework is Section 25 TDDDG: storing and reading information on a device generally requires consent.

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