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1. mikekc+(OP)[view] [source] 2018-09-20 08:49:26
The key is to determine under which lawful basis you are processing that data. "Necessary data" is not a get out of jail free card. Because the analytics are not necessary to perform the contract (in any way that I can imagine), you can't claim contract lawful basis. Probably you are stuck with legitimate interest.

So I think you would have to notify the user that you are sending their IP address to the processor under legitimate interest and have a way for them to "object" to that use (i.e. turn off analytics). For legitimate interest, the objection can be after the fact, so having a configuration screen that stores a cookie that allows them to turn off analytics when they are on the site would probably do it.

replies(1): >>zaarn+L
2. zaarn+L[view] [source] 2018-09-20 09:03:19
>>mikekc+(OP)
Since in my case, the processor is me, there is no data being sent elsewhere. I don't have a notification since all data collected is either heavily anonymized in client if possible or on the server side or simply not identifying. Since the data I collect is used to optimize the website experience, I think it's a good enough legitimate interest with no privacy impact.
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