LGPD Compliant Web Analytics
Brazil's Lei Geral de Proteção de Dados Pessoais (LGPD, Law No. 13,709/2018) is a comprehensive data protection law that closely mirrors GDPR in structure and scope. Effective since September 2020 and enforced by the Autoridade Nacional de Proteção de Dados (ANPD), LGPD applies to any processing of personal data of individuals in Brazil, regardless of where the processing organization is located. The law defines personal data as information related to an identified or identifiable natural person, and sensitive personal data includes health, genetic, biometric, ethnic, religious, political, and sexual orientation data. LGPD establishes ten legal bases for processing (compared to GDPR six), including consent, legitimate interests, and the protection of credit. Penalties include fines of up to 2% of the organization revenue in Brazil per infraction, capped at 50 million reais per infraction. The ANPD has been progressively building its enforcement capacity and has begun issuing regulatory guidance on cookies and tracking technologies. ActionLab is LGPD compliant because it processes no personal data of Brazilian individuals — no identifiers, no tracking cookies, and no information that could identify or single out any person.
Compliance Summary
ActionLab Analytics is LGPD-compliant out of the box. Because ActionLab uses no cookies, collects no personal data, and never tracks users across sites, most LGPD requirements simply don't apply. No consent banners needed, no DPA required, no data processing agreements to negotiate.
LGPD Requirements
Jurisdiction: Brazil
- Legal basis for processing personal data — LGPD Article 7 establishes ten legal bases, with consent and legitimate interests being the most common for analytics, each requiring specific conditions to be met.
- Purpose limitation and data minimization — personal data must be collected for specific, explicit, and legitimate purposes, and limited to what is necessary for those purposes.
- Data subject rights including access, correction, and deletion — LGPD Articles 17-22 grant data subjects comprehensive rights over their personal data, including access, correction, anonymization, portability, and deletion.
- Data protection by design and default — LGPD Article 46 requires organizations to adopt technical and administrative measures to protect personal data from the design stage and by default.
- Data breach notification — organizations must notify the ANPD and affected data subjects of security incidents that may create risk within a reasonable timeframe.
- Appointment of Data Protection Officer (Encarregado) — organizations that process personal data must appoint a DPO responsible for compliance oversight and communication with the ANPD.
How ActionLab Complies with LGPD
Legal basis for processing
No personal data is processed by ActionLab. The aggregate analytics data it stores — page view counts, referrer tallies, device type distributions, and geographic region summaries — does not constitute personal data under LGPD Article 5 because it cannot be used to identify any individual. Since no personal data is processed, no legal basis under Article 7 is required. The complex analysis of whether consent or legitimate interest applies is entirely avoided.
Data minimization
ActionLab collects only the aggregate traffic metrics necessary for web analytics — the absolute minimum for useful audience measurement. IP addresses are used transiently for geographic lookup and immediately discarded, never stored in any form. No individual browsing patterns, session histories, or device fingerprints are retained. This exceeds the data minimization standard by collecting zero personal data rather than the minimum personal data necessary.
Data subject rights
No personal data is stored in ActionLab, so there is nothing for data subjects to access, correct, anonymize, port, or delete. If a Brazilian data subject exercises their LGPD rights regarding analytics, the response is straightforward: no personal data related to them exists in the analytics system. This eliminates the operational overhead of building and maintaining data subject rights fulfillment procedures for analytics.
Summary
ActionLab Analytics is compliant with LGPD by design. Because no personal data is collected, no cookies are used, and no cross-session tracking occurs, the compliance burden associated with analytics is eliminated entirely. You do not need consent banners, data processing agreements, or complex configuration to use ActionLab in Brazil.
Practical LGPD Compliance Guide
For organizations serving Brazilian users, LGPD compliance for web analytics requires evaluating whether your analytics tool processes dados pessoais (personal data) as defined by Article 5. The LGPD definition is broad: "information related to an identified or identifiable natural person." Cookie identifiers, IP addresses, and online behavioral data that can be linked to individuals qualify. If your analytics tool processes personal data, you need: a documented legal basis, privacy notices in Portuguese, procedures for data subject rights, a Data Protection Officer (Encarregado), and incident response procedures. The ANPD is progressively building enforcement capacity and has indicated that cookie and tracking compliance is an area of focus. ActionLab eliminates analytics from the LGPD compliance equation by processing no personal data. Practical steps: install ActionLab, update your privacy policy (politica de privacidade) to state that analytics does not collect personal data, and remove analytics from your LGPD processing records. For organizations also subject to sector-specific regulations (financial services, healthcare, telecommunications), ActionLab zero-data approach provides a clean analytics solution that does not intersect with sector-specific data protection requirements.
Frequently Asked Questions
Is ActionLab compliant with Brazilian privacy law?
Yes. ActionLab collects no personal data (dados pessoais) as defined by LGPD Article 5. The aggregate traffic statistics it stores cannot identify any individual Brazilian resident. Because no personal data is processed, LGPD requirements for legal basis, consent, data subject rights, DPO appointment, and breach notification do not apply to ActionLab analytics data. This compliance is architectural rather than configurational — the system is designed so that personal data collection is technically impossible, providing the strongest form of LGPD compliance available.
How is the ANPD approaching cookie regulation?
The Autoridade Nacional de Proteção de Dados has been developing its regulatory framework progressively and has indicated that cookies and online tracking are areas of regulatory attention. While detailed cookie-specific guidance is still evolving, the ANPD general approach aligns with GDPR principles: personal data processing requires a legal basis, and consent must be meaningful and informed. ActionLab approach of using no cookies and collecting no personal data positions it safely regardless of how the ANPD cookie guidance develops, because it does not engage in the activities that regulation targets.
Does LGPD apply to foreign companies?
Yes. LGPD applies to the processing of personal data of individuals located in Brazil, regardless of where the processing occurs. If your website serves Brazilian visitors and your analytics tool collects personal data about them, LGPD applies. By using ActionLab, which collects no personal data from any visitor, you eliminate analytics as an LGPD compliance consideration for Brazilian visitors. This extraterritorial scope means that even non-Brazilian companies must consider LGPD when choosing analytics tools for websites with Brazilian traffic.
What about the DPO requirement?
LGPD requires organizations that process personal data to appoint an Encarregado (DPO). The appointment requirement is triggered by personal data processing, not by business activity in general. Because ActionLab does not process personal data, it does not independently trigger the DPO requirement. However, if your organization processes personal data through other means (customer databases, email marketing, user accounts), you should have an Encarregado regardless of your analytics tool choice.
How does ActionLab handle the "legitimate interest" analysis?
Under LGPD, legitimate interest (Article 7, X) is a legal basis that requires balancing the organization interest against the data subject rights and expectations. Cookie-based analytics often relies on legitimate interest claims, which require documentation, proportionality analysis, and can be challenged by data subjects. ActionLab avoids this analysis entirely because no personal data is processed. There is no need to argue legitimate interest because there is no personal data processing that requires a legal basis.