Google Ads Conversion Upload

The parameter is as specified in the documentation target_achievement. This is independent of the parameter in the URL.

According to the ePrivacy Opinion, the upload of etracker analytics to Google Ads can be justified by the overriding legitimate interest, as no personal data is transferred, but only statistical data on the number and value of conversions.

The linking of campaigns and conversions is carried out using Google Click ID. The data protection experts do not regard the Google Click ID as personal data. The Click ID is used exclusively to measure success and enables the assignment of conversions to corresponding Google Ads ads. Remarketing in the sense of allocation to individual users and their targeted advertising is therefore excluded. The use of imported conversion data for target group segments is not possible. The data processor therefore has no way of identifying the user behind the click ID and it is therefore not possible for the website operator to identify data subjects using the Google Click ID. Against this background, the conversion data uploaded to Google Ads does not relate to a natural person and the Click ID is not an online identifier as defined by https://dsgvo-gesetz.de/erwaegungsgruende/nr-30/.

A combination of conversion data with user data for Google’s own purposes, which remain hidden from the advertising company, cannot be ruled out in principle. This is because every click that comes via an ad is evaluated by Google with an individual Google Click ID (GCLID). Google could theoretically use this to merge the conversion with the other tracking data for the respective user if Google matches the generated click ID and user IDs. However, the fact that “target group segments” and “remarketing” using GCLID are excluded and require the transfer of other identifiers or the implementation of Google tags speaks against this, see e.g. https://support.google.com/google-ads/answer/9199250?hl=de. Although Google does not explicitly exclude aggregation, it has published documents in which the upload via Click ID is explicitly advertised as meeting strict data protection requirements, see https://www.thinkwithgoogle.com/_qs/documents/4066/comdirect_Offline_Conversion_Tracking_07.pdf. We therefore consider it responsible to see this as credible confirmation that purely Google-internal identification using the Google Click ID does not take place.

In principle, using the conversion upload with management accounts is not a problem.
The decisive factor is the constellation.

The following options are available:

• Everything at individual account level: conversion campaigns plus upload
• Everything about the management account: Conversion actions plus upload
• Alternative: Actions at individual level, upload via management account

Please note: Actions at management account level, upload via individual accounts is not possible!

With regard to etracker accounts, there are these variants:

• A Google single account assigned to the etracker account → Everything at single account level
• Multiple Google accounts assigned to one etracker account → All about the management account

When restructuring, care must be taken to ensure that the actions are created at the correct level and the upload is set up (always renew the token).

etracker deems it justifiable to justify the conversion upload to Google Ads by etracker on the legal basis of Art. 6 para. 1 lit. f) or lit. a) GDPR to justify it. § Section 25 TDDDG is not relevant in cookie-less mode or with the use of cookies, taking into account the consent of the data subject, due to the lack of access to information in the user’s end device. This is the conclusion reached by the legal opinion of ePrivacy Consult as part of the review and award of the ePrivacy Seal for standard data processing with etracker analytics.

Google’s Consent Mode does not offer an option for the legal basis of legitimate interest. Therefore, the assignment to the consented status “granted” is functionally appropriate, as the processing is lawful according to the EU GDPR and TDDDG or Cookie Directive. It does not matter which purposes are associated with this, because the data set for the upload is deliberately reduced in such a way that purposes beyond conversion tracking are excluded. Functions such as “target group segments” and “remarketing” are not possible using the conversion upload and would require the transfer of other identifiers or the implementation of Google tags, see e.g. https://support.google.com/google-ads/answer/9199250?hl=de. Google itself has published documents in this regard in which the upload is explicitly advertised as meeting strict data protection requirements, see https://www.thinkwithgoogle.com/_qs/documents/4066/comdirect_Offline_Conversion_Tracking_07.pdf.

The legality of the assignment to “granted” would only be problematic if consent for the conversion upload was explicitly requested in the consent dialog and the associated data processing with etracker analytics was not justified in the privacy policy by the overriding legitimate interest, but by the consent. Only in this case would the conversion upload with the status “granted” contradict the actual declaration of intent or legal basis for the web analysis. This was already the case before the introduction of Google Consent Mode. In this respect, Consent Mode does not change the legal assessment. In connection with the conversion upload, Consent Mode only changes the fact that the legality of the associated data processing must also be made clear in the upload.