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Trovo

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Trovo Live is a livestreaming platform owned by Tencent, originally positioned as an alternative to Twitch and YouTube Live for gaming creators. When a website embeds a Trovo player, chat widget or follow button, the iframe loads scripts from trovo.live, sets third party cookies and shares signals with the Tencent advertising and audience stack. Because data is processed in the United States, Singapore and mainland China, Trovo embeds are treated as a high risk advertising tracker under the GDPR and ePrivacy Directive.

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Overview

What does Trovo do?

What Trovo is

Trovo Live is a Tencent operated livestreaming platform launched as a global alternative to Twitch. It is used by gaming and lifestyle creators who embed their channel, latest VOD or follow widget on a personal website or blog. The Trovo embed loads an iframe from player.trovo.live and ancillary scripts from trovo.live and Tencent CDN domains.

What data Trovo collects

As soon as the iframe loads, Trovo sets third party cookies on trovo.live (TROVO_LOGIN_INFO, TROVO_GUEST_ID, _ga, persistent advertising IDs synced with Tencent advertising). The player exchanges authentication tokens, viewing telemetry, IP address, user agent and locale with Trovo servers. The chat widget and follow button transmit similar data plus the user logged in account when the visitor is signed into Trovo.

GDPR and ePrivacy implications

The cookies fall under Article 5(3) ePrivacy. The advertising profiling and audience activation by Tencent fall under Article 6(1)(a) GDPR. Legitimate interest cannot be used because Trovo cookies are integrated with the Tencent advertising and recommendation engine. The fallback to user choice and the click to load pattern are both required, not optional.

Consent requirements

Trovo embeds must be placeholders by default and only load after explicit consent. The consent message must mention Tencent, advertising cookies and the transfer to the United States, Singapore and mainland China. A clear refuse option must be available, and the choice must be revocable at any time.

International data transfers

Tencent processes data in the United States, Singapore and mainland China. Mainland China has no adequacy decision under Article 45 GDPR, no DPF equivalent and is exposed to the Cybersecurity Law, Data Security Law and PIPL. Transfers therefore require Standard Contractual Clauses, supplementary measures and, in practice, explicit consent under Article 49(1)(a) GDPR for occasional transfers.

Practical compliance steps

Use a placeholder image and click to load pattern that lists Tencent and the destination countries, sign the Trovo/Tencent terms of service and look for an explicit Standard Contractual Clauses based DPA, document the transfer impact assessment, list Trovo in the privacy and cookie policies, and consider self hosting the video on Bunny.net or Mux EU instead, or switching to YouTube nocookie embeds when livestreaming is not required.

Compliance

Trovo and the GDPR

Trovo is classified as “Marketing”. 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
Prior, freely given, specific, informed and unambiguous consent under Article 6(1)(a) GDPR for the cookies set by Trovo, the Tencent advertising tracking and the international transfer. Explicit consent under Article 49(1)(a) GDPR for the transfer to mainland China.
Risk level
high
Applicable regulations
GDPR, ePrivacy Directive, French CNIL guidelines, German TTDSG, Spanish LSSI, Italian Garante guidelines, EDPB Schrems II guidance for non adequate countries, Chinese PIPL

Impact assessment (DPIA)

A DPIA is recommended whenever Trovo embeds are placed on EU facing websites, due to the cross border transfer to mainland China, integration with the Tencent advertising platform and persistent cookies for visitors who never log in to Trovo.

Sample text for your banner

This page contains a Trovo Live player operated by Tencent. Loading the player will set advertising cookies and transfer your IP address and browsing data to servers in the United States, Singapore and mainland China. Click Accept to display the video, or click Decline to keep the player blocked.
Cookies and trackers

What Trovo sets and contacts

Tracking method
Trovo embed iframe (player.trovo.live), JavaScript tag for chat and channel widgets, third party cookies on trovo.live, Tencent advertising and analytics pixel, cross site identifier shared with the Tencent advertising stack
Server location
Trovo Live is operated by Tencent Holdings Limited. Production data is mainly hosted in the United States and Singapore, with replication to mainland China for the Tencent advertising platform.
Data transferred outside the EU
Embedding Trovo content transfers personal data to the United States, Singapore and mainland China. Mainland China is not covered by an adequacy decision and Tencent processing in China is exposed to the Cybersecurity Law and the Personal Information Protection Law (PIPL). Standard Contractual Clauses with supplementary measures and explicit consent under Article 49(1)(a) GDPR are typically required.

Cookies set (4)

NameTypeDurationPurpose
TROVO_LOGIN_INFOpersistent1 yearStores the Trovo authentication token used to keep a logged in user signed in across sessions and pages that embed Trovo content.
TROVO_GUEST_IDpersistent1 yearPersistent guest identifier assigned to non logged in visitors so that Trovo can attribute viewing telemetry, recommendations and advertising signals.
TROVO_QUALITYpersistent1 yearRemembers the playback quality preference and player layout chosen by the visitor.
TROVO_CSRFsessionSessionAnti CSRF token used by the Trovo player and chat widget to protect form submissions and API calls.

Third-party domains contacted (5)

  • trovo.live
  • player.trovo.live
  • static.trovo.live
  • trovo.tencent-cloud.com
  • aegis.qq.com
Questions

Frequently asked questions about Trovo

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What cookies does Trovo set?

Trovo sets the third party cookies TROVO_LOGIN_INFO, TROVO_GUEST_ID, TROVO_QUALITY, TROVO_CSRF and persistent advertising identifiers synchronised with the Tencent advertising platform. The cookies persist for several months and are read on every page that loads a Trovo iframe.

Do I need consent to embed Trovo?

Yes. The Trovo embed sets advertising cookies under Article 5(3) ePrivacy and transfers personal data to the United States, Singapore and mainland China under Article 6(1)(a) GDPR. The iframe must be placeholders by default and only load after explicit, granular opt in consent.

What is the legal basis for Trovo?

Consent (Art. 6(1)(a) GDPR + Art. 5(3) ePrivacy) is the only valid basis. Explicit consent under Article 49(1)(a) GDPR is also required for the transfer to mainland China, since the country has no adequacy decision and Tencent is subject to Chinese national security laws.

Does Trovo transfer data to the US or China?

Yes. Tencent processes data in the United States, Singapore and mainland China. The mainland China leg has no adequacy decision, no DPF equivalent, and is exposed to the Cybersecurity Law, Data Security Law and PIPL. SCC plus supplementary measures plus explicit consent are typically needed.

Do I need a DPIA for Trovo?

Yes for any meaningful EU deployment. The combination of advertising profiling by Tencent, transfers to a non adequate country and persistent cookies for non logged in visitors triggers the DPIA criteria of WP248 and the EDPB threshold guidance.

How do I implement Trovo embeds compliantly?

Use a click to load placeholder, mention Tencent and the destination countries (US, Singapore, China) in the consent message, sign the Trovo terms with an explicit SCC based DPA, document a transfer impact assessment, list Trovo in the privacy and cookie policies and consider alternatives when a high risk vendor is not strictly necessary.

What are the alternatives to Trovo?

For livestreaming, Twitch (US, DPF) and YouTube Live (US, DPF, with the YouTube nocookie embed for VOD) reduce risk compared to Trovo because they avoid mainland China. For self hosted streaming with EU residency, Mux EU, Bunny Stream, OVHcloud Streaming and Cloudflare Stream are options. Replacing the embed by a static thumbnail with a deep link to Trovo limits the data leakage to the moment the visitor opts in.

How do I update the cookie policy for Trovo?

List Trovo Live with the operator (Tencent), the purpose (livestreaming embed and analytics), the cookies and persistent identifiers, the legal basis (consent and Article 49(1)(a) explicit consent for mainland China), the transfer destinations (US, Singapore, mainland China) and the safeguards (SCC, supplementary measures, transfer impact assessment).

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