Commanders Act TagCommander
TagCommander by Commanders Act is a French tag management system that loads and orchestrates third party tags through a single JavaScript container, with hosting in the European Union.
What does Commanders Act TagCommander do?
What is Commanders Act TagCommander?
TagCommander is the tag management module of Commanders Act, a French customer data and consent platform. The container is a JavaScript file loaded by the publisher that conditionally fires marketing, analytics and personalisation tags depending on consent and business rules.
How does TagCommander process personal data?
TagCommander sets a small number of first party cookies on the publisher domain, primarily TC_PRIVACY for consent state and TCID as a visitor identifier. The container itself collects only minimal data needed to evaluate rules. The tags it loads each have their own data flows and must be assessed individually.
Why does TagCommander require consent?
The TCID cookie is not strictly necessary for the website and supports analytics or personalisation use cases. Consent is therefore required for TCID and for any tag the container fires for non strictly necessary purposes. The TC_PRIVACY cookie, which stores the consent decision, is exempt.
International data transfers
Commanders Act hosts its production infrastructure in France within the European Union. No structural transfer outside the EEA is performed by TagCommander itself. The data flows of the loaded tags must be reviewed separately because many marketing tags will involve non EU vendors.
Compliance recommendations
Combine TagCommander with the Commanders Act CMP or another IAB TCF compatible CMP, configure the container to block non strictly necessary tags until consent is granted, document the tag inventory in your record of processing activities and re audit tags regularly.
Commanders Act TagCommander and the GDPR
Commanders Act TagCommander is classified as “Analytics”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.
- Legal basis
- consent
- Risk level
- medium
- Applicable regulations
- GDPR, ePrivacy Directive, French Data Protection Act
Impact assessment (DPIA)
A DPIA is not normally required for the TagCommander container itself, but the inventory of tags loaded through it should be assessed individually. The container is hosted in France within the EU.
Sample text for your banner
We use Commanders Act TagCommander to load advertising, analytics and personalisation tags only with your consent. TagCommander sets a small number of first party cookies on our domain. Do you accept?
What Commanders Act TagCommander sets and contacts
- Tracking method
- tag_management_first_party_cookies
- Server location
- France (EU)
- Cookieless mode available
- Yes
Cookies set (4)
| Name | Type | Duration | Purpose |
|---|---|---|---|
| TC_PRIVACY | necessary | 13 months | Stores the user consent decision for tag categories managed by TagCommander. |
| TC_PRIVACY_CENTER | necessary | 13 months | Stores detailed granular consent choices made in the preference centre. |
| TCID | analytics | 13 months | First party visitor identifier used by TagCommander to orchestrate tags and personalisation. |
| __tcs | analytics | session | Session identifier used by TagCommander for in container event tracking. |
Third-party domains contacted (4)
commandersact.comtagcommander.comcdn.tagcommander.comcollect.commander1.com
Frequently asked questions about Commanders Act TagCommander
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What cookies does TagCommander set?
TagCommander primarily sets TC_PRIVACY, which stores the consent decision and is exempt from consent, and TCID, a visitor identifier used for tag orchestration. Additional cookies may be set by the third party tags loaded by the container.
Is consent required before loading TagCommander?
The TagCommander container can be loaded before consent because it must orchestrate the consent decision. However, non strictly necessary tags configured in the container, including TCID for personalisation, must remain blocked until consent is granted.
What is the legal basis for TagCommander?
For the TC_PRIVACY cookie the legal basis is legal obligation and legitimate interest. For TCID and the non strictly necessary tags fired through the container the legal basis is the explicit consent of the data subject under Article 6(1)(a) of the GDPR.
Does TagCommander transfer data outside the EU?
No. Commanders Act hosts its production infrastructure in France within the European Union, so TagCommander itself does not perform structural transfers. The tags loaded by the container may involve non EU vendors and must be reviewed individually.
Is a DPIA required when using TagCommander?
A DPIA is not normally required for the TagCommander container itself because it processes very limited data. A DPIA may be needed for the combined inventory of tags it loads, especially when those tags perform large scale behavioural tracking.
How do I implement TagCommander compliantly?
Use TagCommander together with a CMP (preferably the Commanders Act CMP), block all non strictly necessary tags by default, expose granular purposes to the user, replay consent signals to downstream tags and maintain a documented tag inventory.
Are there privacy friendly alternatives to TagCommander?
Other EU based tag management systems exist, such as Piwik PRO Tag Manager, Matomo Tag Manager and Tealium running in EU regions. Server side tag managers can also reduce browser side data exposure.
How should I update my cookie policy to mention TagCommander?
List Commanders Act as a processor for tag management, mention the TC_PRIVACY and TCID cookies with their purpose and duration, state that hosting is in France within the EU and list the third party tags loaded through the container so users can make an informed choice.
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