⚠️ Disclaimer
This article and the sample text below are examples only. They do not constitute legal advice.
You, as the customer, remain solely responsible for complying with all applicable laws, and for making sure the final wording and configuration match how you actually use Aqurate and any other technologies on your site.
Implementation checklist: 10 steps to go live
Governance and contracts
Review Aqurate's Privacy Policy and DPA, and check the listed sub-processors and their locations (all EU regions).
Add Aqurate to your Records of Processing Activities.
Legal bases and wording
3. Decide and document your legal basis: consent, plus contract or legitimate interests if applicable to logged-in personalization.
4. Update your Privacy Policy and Cookie Policy. Examples below.
CMP and Consent Mode v2
5. Add Aqurate as a vendor in your CMP under "Personalization" (and "Analytics," if you group it there). Block Aqurate's scripts and cookies until consent is given, and disable them if consent is withdrawn.
6. If you use Google tags, confirm Consent Mode v2 is enabled and sending signals. Test both the EEA default state and the per-purpose toggles.
Cookie and SDK inventory
7. List every Aqurate storage item (cookie or localStorage name, purpose, duration) in your Cookie Policy. Aqurate typically uses _sp_id, _sp_ses, and _sp_cookie.
Retention and data lifecycle
8. Check how long your systems retain event and profile data, and align this with Aqurate's default retention period.
9. Define and document how data is deleted or anonymized after consent withdrawal or once retention ends.
Rights handling
10. Make sure your access, export, deletion, and objection workflows cover Aqurate data too. Provide a contact channel and response times (SLAs).
What you need to disclose about Aqurate
Identity and roles: You are the controller. Aqurate is your processor, under a Data Processing Agreement.
Purpose: On-site product and content recommendations, email personalization, and the related analytics, performance reporting, and service improvement.
Data categories: Pseudonymous identifiers (cookie, SDK, user, or session IDs); contact identifiers if provided (e.g. email); device and browser data (IP, user agent, OS, language, screen); interaction data (pages and products viewed, clicks, carts, purchases, email opens and clicks). No special category data is processed.
Legal bases: Consent for non-essential cookies and trackers and the personalization/analytics built on them. Marketing emails require consent (or soft opt-in, where permitted). If you also rely on contract or legitimate interests for some logged-in personalization, document that separately and offer a way to object.
Profiling: Explain the logic in plain language, and make clear there are no solely automated decisions with legal or similarly significant effects.
Recipients and transfers: Aqurate as processor, using EU-based cloud sub-processors (Google Cloud EMEA, Microsoft Azure Ireland, AWS EMEA).
Retention: State how long you keep event data, profiles/segments, and email engagement data, with clear durations or criteria.
Rights and choices: How users manage cookie preferences, withdraw consent, object to personalization based on legitimate interests, unsubscribe from marketing, and exercise their GDPR rights.
Security: A high-level statement covering encryption and access controls.
Changes: How you'll notify users when this changes.
Privacy Policy (example)
Update anything in square brackets to match your actual setup.
Section: Personalization with Aqurate.ai
Provider and role
We use Aqurate, provided by MACHINE LEARNING SOLUTIONS SRL, 2-4 Calea Circumvalatiunii, office 210, Timisoara, Timis, Romania ("Aqurate"), to personalize our website [and our marketing emails]. Aqurate acts as our data processor under a data processing agreement and processes personal data only on our instructions.
What we use it for
On-site recommendations: tailoring product listings, recommendations, and content to your interests.
[Email personalization: tailoring the content of our marketing emails and newsletters.]
Categories of personal data
Identifiers: pseudonymous cookie/SDK IDs, session ID, [customer/account ID], [email address, if provided/hashed].
Technical data: IP address, device and browser information (type, OS, language, screen resolution), timestamps, referrer parameters.
Interaction data: pages and products viewed, clicks, searches, add-to-cart/checkout events, purchases/returns, [and email opens/clicks (for our emails)].
Inferences and segments based on the above. We do not use special category data.
Legal bases
We rely on your consent for the non-essential cookies and technologies Aqurate uses, and the related personalization and analytics (GDPR Art. 6(1)(a)). You can manage or withdraw consent at any time via [Cookie settings link].
For marketing emails, we rely on your consent (or soft opt-in, where permitted). You can unsubscribe at any time.
[If applicable] Some logged-in personalization may be necessary to perform our contract (Art. 6(1)(b)), or based on our legitimate interest in improving our services (Art. 6(1)(f)). You can object at any time by contacting us at [email] or via [account settings link].
Profiling and how it affects you
We analyze your interactions (pages viewed, clicks, purchases) together with device and account/order data to infer your interests. Our models predict which products or content are most relevant to you, and may change the order and selection of items you see on our site and in our emails. We do not make decisions with legal or similarly significant effects solely by automated means. You can withdraw consent or object as described above.
Recipients and transfers
Aqurate processes data on our behalf and may use EU-based cloud providers (Google Cloud EMEA, Microsoft Azure Ireland, Amazon Web Services EMEA). Contact us for details.
Retention
Browsing and event data used for personalization: kept for up to [X months] after collection.
Email engagement data: kept while you're subscribed, and for up to [Y months] after.
Aggregated or anonymized data may be kept longer.
Your choices and rights
Manage cookies or withdraw consent: [Cookie settings link].
Object to personalization where we rely on legitimate interests: contact [email].
Unsubscribe from marketing: use the link in any marketing email, or contact us.
Exercise your GDPR rights (access, rectification, erasure, restriction, portability, objection): contact [email]. We'll work with Aqurate to fulfill your request.
Security
We and Aqurate apply appropriate security measures, including encryption in transit and at rest, and access controls.
Cookie Policy (example)
Update anything in square brackets to match your actual setup.
Aqurate entry
Vendor: Aqurate (MACHINE LEARNING SOLUTIONS SRL)
Purpose: Personalizing on-site content and product recommendations; related performance reporting and service improvement; personalizing marketing email content (for subscribers).
Technologies used: First-party cookies and/or local storage, to hold a pseudonymous user/visitor ID and session ID, plus event tracking for interactions (product views, clicks, carts, purchases). Personal data processed: pseudonymous IDs, device/browser data (including IP address), URLs and on-site events, purchase events, and aggregated performance metrics.
Type: Non-essential. Only set with your consent.
Retention: User identifier, up to [X months]. Session identifier, until the session ends or after [Y minutes]. Adjust if you clear cookies or withdraw consent.
Control: Grant or withdraw consent at any time via [Cookie settings link]. Disabling the "Personalization" [and/or "Analytics"] category stops Aqurate's cookies and tracking from running.
Google Consent Mode v2 (for your Cookie Policy and CMP)
If you use Google tags, your CMP must send Consent Mode v2 signals in the EEA/UK: ad_storage, analytics_storage, ad_user_data, ad_personalization.
Aqurate should be governed by your CMP's "Personalization" category (and "Analytics," if you group it there). Block your Aqurate loader/tag until "Personalization" consent is granted, and disable it if consent is withdrawn.
Your Cookie Policy should make two things clear:
Turning off "Personalization" stops Aqurate from setting or reading non-essential identifiers.
Your Google tags respect Consent Mode v2 signals (
analytics_storage/ad_storage/ad_user_data/ad_personalization). These signals apply to Google technologies; Aqurate follows your CMP's "Personalization" setting instead.
Implementation tips:
Default to denied in the EEA/UK until consent is given.
On any consent change, immediately enable or disable Aqurate, and delete its identifiers if you've implemented deletion on withdrawal.
Document how your CMP choices map to tag behavior, for audits.