Treasure Data
Treasure Data is an enterprise Customer Data Platform that unifies first party data from many sources into persistent customer profiles. Its JavaScript SDK sets cookies and captures events and identifiers for identity resolution and large scale profiling. Because of non essential cookies and extensive profiling, it requires consent under GDPR and ePrivacy and a DPIA is likely.
What does Treasure Data do?
What Treasure Data is
Treasure Data is an enterprise Customer Data Platform, a CDP. It collects first party data from websites, apps, and back end systems and unifies it into a single persistent profile for each customer. Through identity resolution it links events and identifiers from many sources, so the platform can power segmentation, personalization and activation across marketing channels. It operates at large scale and its core purpose is building and enriching unified customer profiles.
Data and cookies collected
The Treasure Data JavaScript SDK, known as td-js-sdk, sets first party cookies prefixed with td such as _td and _td_global, and captures page views, events, and identifiers. These cookies store a persistent identifier that is used to stitch behaviour to a unified profile, which may also include data ingested from other systems. Because the profile relates to identifiable individuals and uses persistent identifiers, it is personal data under the GDPR.
GDPR and ePrivacy implications
The cookies the SDK sets are not strictly necessary, so Article 5(3) of the ePrivacy Directive requires consent before they are stored or read. The unification and profiling also need a lawful basis under the GDPR, and for marketing personalization the appropriate basis is consent under Article 6(1)(a). Because the CDP combines data and profiles at scale, transparency and purpose limitation are especially important, and individuals must be able to exercise their rights across the unified profile.
Consent and data transfers
Consent must be freely given, specific, informed and unambiguous, and the SDK should only collect non essential data after acceptance. Treasure Data runs on global infrastructure, with processing possible in the United States, Japan and other regions depending on the instance. These transfers require safeguards such as Standard Contractual Clauses or the EU US Data Privacy Framework, supported by a transfer risk assessment.
Practical compliance steps
Configure the SDK to collect only after consent through a consent management platform, propagate consent signals into the CDP so downstream activation respects choices, and document the cookies in your cookie policy. Sign a data processing agreement, map data sources and retention, verify the processing regions and transfer safeguards, and carry out a Data Protection Impact Assessment given the large scale profiling and identity resolution.
Treasure Data and the GDPR
Treasure Data 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 under Article 6(1)(a) GDPR combined with Article 5(3) ePrivacy Directive for non essential cookies and for large scale profiling and identity resolution in the CDP.
- Risk level
- high
- Applicable regulations
- GDPR, ePrivacy Directive (Cookie Law), national ePrivacy implementations
Impact assessment (DPIA)
Treasure Data unifies data from many sources and performs large scale identity resolution and profiling, which is precisely the kind of processing that triggers a Data Protection Impact Assessment. Assess the scale of profiling, the combining of online and offline data, the use of persistent identifiers, transfers to the United States and Japan, and the rights of individuals across the unified profile.
Sample text for your banner
We use Treasure Data, a customer data platform, to combine information about your interactions into a unified profile and to personalize our services. This involves cookies and profiling. Do you consent to this processing?
What Treasure Data sets and contacts
- Tracking method
- JavaScript SDK with first party cookies plus server side ingestion. The td-js-sdk sets cookies and captures events, page views and identifiers, feeding an enterprise Customer Data Platform that unifies first party data into persistent customer profiles.
- Server location
- Global cloud infrastructure with processing in the United States, Japan and other regions depending on the contracted instance.
- Data transferred outside the EU
- Treasure Data processes data on global infrastructure, with possible processing in the United States, Japan and other regions. Transfers rely on Standard Contractual Clauses and, where applicable, the EU US Data Privacy Framework.
Cookies set (3)
| Name | Type | Duration | Purpose |
|---|---|---|---|
| _td | HTTP cookie | Persistent (up to 1 year) | Stores a persistent visitor identifier used by the SDK to capture events and stitch behaviour to a unified customer profile. |
| _td_global | HTTP cookie | Persistent (up to 1 year) | Stores a global identifier shared across properties to support cross site identity resolution in the CDP. |
| _td_ssc | HTTP cookie | Persistent | Supports server side cookie linking for identity resolution and event collection. |
Third-party domains contacted (3)
treasuredata.comin.treasuredata.comcdn.treasuredata.com
Frequently asked questions about Treasure Data
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What cookies does Treasure Data set?
The Treasure Data JavaScript SDK, td-js-sdk, sets first party cookies prefixed with td such as _td and _td_global. They store a persistent identifier used to capture events and page views and stitch behaviour to a unified customer profile in the CDP.
Is consent required to use Treasure Data?
Yes. The SDK cookies are not strictly necessary and the platform performs large scale profiling, so under Article 5(3) ePrivacy and Article 6(1)(a) GDPR you must obtain prior, freely given and informed consent before collection begins.
What is the legal basis for Treasure Data?
The appropriate basis is consent under Article 6(1)(a) GDPR, combined with consent for cookie storage under Article 5(3) ePrivacy. Given the scale of profiling and identity resolution, consent is generally required for the marketing personalization use cases.
Does Treasure Data transfer data to the United States?
Treasure Data runs on global infrastructure, with processing possible in the United States, Japan and other regions depending on the instance. Transfers require Standard Contractual Clauses or the EU US Data Privacy Framework plus a transfer risk assessment.
Do I need a DPIA for Treasure Data?
Yes, a Data Protection Impact Assessment is likely required. Treasure Data unifies data from many sources and performs large scale profiling and identity resolution, which is the kind of high risk processing that triggers a mandatory DPIA.
How do I implement Treasure Data compliantly?
Collect only after consent through a consent management platform, propagate consent signals into the CDP so activation respects choices, document the cookies, sign a data processing agreement, map sources and retention, verify transfer safeguards and complete a DPIA.
What are the alternatives to Treasure Data?
Alternatives include other enterprise customer data platforms and lighter first party data approaches that minimise profiling. Any CDP that unifies and profiles at scale raises the same consent, governance, transfer and DPIA questions, so assess data location and minimisation.
How should I update my cookie policy for Treasure Data?
List the td prefixed cookies set by the SDK, describe their purpose of building a unified profile, state their duration, name Treasure Data as a processor, and disclose transfers to the United States, Japan and other regions with the safeguards used.
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