> How Request Metrics handles GDPR and ePrivacy: cookieless real user monitoring, legitimate interest, the US data transfer and a clear privacy notice.
>
> Canonical: https://www.flowconsent.com/en/services/analytics/request-metrics

Analytics

# Request Metrics

Analytics · [Official website](https://requestmetrics.com)

Request Metrics is a web performance and real user monitoring tool that measures how fast your pages load for actual visitors, including Core Web Vitals, errors and slow requests. It is designed to be lightweight and privacy friendly: it does not set cookies and does not build a persistent visitor profile, so it generally does not need a consent banner. Because the company is based in the United States, the main consideration is the transfer of technical data such as the IP address to a third country.

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At a glance

- Category

  [Analytics](https://www.flowconsent.com/en/services/analytics)

- Consent

  Analytics

- Prior consent

  Not required

- Documented cookies

  0

- Third-party domains

  3

- Servers

  Operated by Request Metrics (United States). Technical performance data is processed in the US.

Overview

## What does Request Metrics do?

## What Request Metrics is

Request Metrics is a real user monitoring and performance analytics service. A small JavaScript beacon measures real page load timings, Core Web Vitals such as Largest Contentful Paint and Cumulative Layout Shift, JavaScript errors and slow network requests from the browsers of actual visitors, and reports them so you can find and fix performance problems. It is a performance tool rather than a behavioural analytics or advertising product.

## What data and cookies Request Metrics processes

Request Metrics is cookieless: it does not set cookies and does not store a persistent identifier on the device, so it does not follow a visitor across sessions or sites. It collects technical performance signals such as load timings, the page URL, the browser and device type, and the connection, along with the IP address that any web request carries. These signals are about how the page performs rather than who the visitor is.

## GDPR and ePrivacy implications

Because Request Metrics stores nothing on the device, the cookie consent requirement of article 5(3) of the ePrivacy Directive does not apply, so it can usually run without a consent banner. Under the GDPR, performance monitoring of this kind can rest on legitimate interest under article 6(1)(f), provided the data is limited to what is needed to keep the site fast. The IP address is personal data, so minimise or truncate it where possible.

## Data transfers and risk

Request Metrics is operated from the United States, so the technical performance data, including the IP address, is transferred to a third country and must rely on the EU US Data Privacy Framework or standard contractual clauses. Sign a data processing agreement, ask whether IP addresses can be truncated or dropped, and document the transfer and the legitimate interest assessment in your records of processing.

## Practical compliance steps

Confirm with developer tools that Request Metrics sets no cookie and stores nothing on the device. Sign a data processing agreement, enable IP truncation if available, set a short retention, and document the legitimate interest basis and the United States transfer. Mention Request Metrics as a cookieless performance monitoring tool in your privacy policy, and reassess if you ever start capturing more than technical performance data.

Compliance

## Request Metrics and the GDPR

- Legal basis

  Request Metrics stores nothing on the device, so the cookie consent requirement of ePrivacy art. 5(3) does not apply. Performance monitoring can rest on legitimate interest under GDPR art. 6(1)(f), provided the data is limited to technical signals; the IP address is personal data and should be minimised where possible.

- Risk level

  medium

- Applicable regulations

  GDPR, ePrivacy Directive 2002/58/EC, TTDSG (Germany), LOPDGDD (Spain), LIL (France)

### Impact assessment (DPIA)

Request Metrics is cookieless and collects technical performance data rather than behavioural profiles, so it is relatively low risk, but the transfer of the IP address to the United States should be assessed. A full DPIA is usually not required; document the legitimate interest assessment, the data minimisation, the retention and the transfer mechanism.

### Sample text for your banner

> This website uses Request Metrics, a cookieless performance monitoring tool, to measure how fast our pages load and to fix slow pages and errors. It sets no cookies and stores no identifier on your device. Technical performance data, including your IP address, is processed by Request Metrics in the United States under standard contractual clauses on the basis of our legitimate interest in a fast, reliable site. You can read more in our privacy policy.

Cookies and trackers

## What Request Metrics sets and contacts

- Tracking method

  Cookieless real user monitoring: a lightweight JavaScript performance beacon measuring page timings, Core Web Vitals and errors, without cookies or persistent identifiers

- Server location

  Operated by Request Metrics (United States). Technical performance data is processed in the US.

- Cookieless mode available

  Yes

- Data transferred outside the EU

  Request Metrics is operated from the United States, so the technical performance data, including the IP address, is transferred to a third country and must rely on the EU US Data Privacy Framework or the European Commission standard contractual clauses.

### Third-party domains contacted (3)

- `requestmetrics.com`
- `in.requestmetrics.com`
- `cdn.requestmetrics.com`

Questions

## Frequently asked questions about Request Metrics

Can't find your question? Write to us, we answer fast.

[Write to us](https://www.flowconsent.com/en/demo)

### Does Request Metrics set cookies?

No. Request Metrics is cookieless: it sets no cookies and stores no persistent identifier on the device. It measures technical performance signals such as load timings and Core Web Vitals, so it does not need the cookie consent required by article 5(3) of the ePrivacy Directive.

### Do I need consent to use Request Metrics?

Usually not for the ePrivacy cookie rule, because nothing is stored on the device. Under the GDPR, performance monitoring can rest on legitimate interest, so a consent banner is generally not required, but you should still address the transfer of the IP address to the United States.

### What is the legal basis?

Performance monitoring of this kind can rest on legitimate interest under GDPR article 6(1)(f), since the purpose is to keep the site fast and reliable and the data is limited to technical signals. Carry out and document a legitimate interest assessment, and minimise the IP address where possible.

### Does Request Metrics transfer data to the United States?

Yes. Request Metrics is a United States company, so the technical performance data, including the IP address, is transferred to the US under the EU US Data Privacy Framework or standard contractual clauses. Sign a data processing agreement and document the transfer.

### Do I need a DPIA?

Usually not. Cookieless performance monitoring of technical data is relatively low risk. Document the legitimate interest assessment, the minimisation and the US transfer, and reassess only if you start collecting more than performance data.

### How do I implement Request Metrics compliantly?

Confirm no cookie is set, sign a data processing agreement, enable IP truncation if available, set a short retention, and document the legitimate interest basis and the US transfer. Describe Request Metrics as a cookieless performance tool in your privacy policy.

### What are the alternatives to Request Metrics?

Other performance and real user monitoring tools include SpeedCurve, Sentry performance, Cloudflare Web Analytics and self hosted solutions. EU hosted or self hosted options remove the United States transfer question while still measuring Core Web Vitals.

### How do I keep my privacy policy up to date with Request Metrics?

State that you use Request Metrics for cookieless performance monitoring, that it sets no cookies, that technical data including the IP address is processed in the United States, and the legal basis. Review the description if you change what data is collected or the retention.

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