---
title: "Privacy by Design Principles"
description: "How Sealmetrics maps to the seven Privacy by Design principles — with the concrete architectural choice behind each one."
canonical_url: "https://docs.sealmetrics.com/security-privacy/privacy-by-design"
lang: "en"
date_generated: "2026-09-21T08:45:24.602Z"
source_hash: "881bebbbf9c0694735232084d33bcbcd6997e39991e1d479dddc3313ae867b1b"
content_type: "trust-and-legal"
owner: "legal"
llm_priority: "critical"
source_file: "security-privacy/privacy-by-design.mdx"
publisher: "Sealmetrics"
---

# Privacy by Design Principles

Canonical page: https://docs.sealmetrics.com/security-privacy/privacy-by-design

Privacy by Design is the framework [GDPR Article 25](https://eur-lex.europa.eu/eli/reg/2016/679/oj) refers to as *data protection by design and by default*. Sealmetrics satisfies it the blunt way: by not collecting personal data, so there is no personal data to protect, disclose or lose. The seven principles below map to specific architectural choices rather than to policies.

## How does Sealmetrics map to the seven principles?

| Principle | How it shows up in Sealmetrics |
|-----------|-------------------------------|
| **1. Proactive, not reactive** | Privacy constraints are structural. The system cannot start identifying visitors later without a redesign, because there is no identifier to switch on. |
| **2. Privacy as the default** | Anonymous measurement from the first page load. Visitors do not opt in to anything, and there is no less-private mode to fall back to. |
| **3. Full functionality** | Traffic, attribution, conversions, revenue and aggregate engagement are all reported without personal data. What is genuinely lost — unique visitors, session duration, cross-session journeys — is [documented rather than worked around](/security-privacy/consentless-analytics#what-consentless-analytics-can-and-cannot-measure). |
| **4. End-to-end security** | EU-only storage in Dublin, Ireland; encryption in transit and at rest; role-based access control; short retention enforced by database TTLs. See [Data Location & Retention](/security-privacy/data-location). |
| **5. Visibility and transparency** | The complete field list and its retention is published in [What We Track](/security-privacy/what-we-track). The tracker is client-side and inspectable. |
| **6. Respect for user privacy** | No cookies, no device storage, no stored or persistent fingerprint, no cross-day, cross-session or cross-site linking. The session identifier is a device-characteristics hash re-keyed on the server with a daily salt that is destroyed on rotation, and it incorporates the publisher account, so the same browser yields different identifiers on different sites. |
| **7. Accommodate all legitimate interests** | Site owners get the measurement they need for business decisions; visitors are not identified to provide it. |

## Is privacy by design a certification?

Two claims worth keeping straight, because vendor reviews turn on them: privacy by design is an architectural property, **not a certification**. Sealmetrics holds no ISO 27001 or SOC 2 certification, and no supervisory authority certifies analytics tools. The pages under [compliance](/compliance) are our own self-assessments against published criteria, and a Data Processing Agreement is included at [sealmetrics.com/dpa](https://sealmetrics.com/dpa/).

**Note:**
- Sealmetrics satisfies GDPR Article 25 (data protection by design and by default) by collecting no personal data, so each of the seven principles maps to an architectural choice.
- Anonymous measurement is the default and only mode: no cookies, no device storage, no stored or persistent fingerprint, EU-only storage in Dublin with short retention enforced by TTLs.
- Privacy by design is an architectural property, not a certification — Sealmetrics holds no ISO 27001 or SOC 2 and no supervisory authority certifies analytics tools.

## Related documentation

- [What We Track vs What We Don't](/security-privacy/what-we-track) — the field-by-field disclosure behind principle 5
- [What is Consentless Analytics?](/security-privacy/consentless-analytics) — the model and its legal basis
- [How Sealmetrics Protects User Privacy](/security-privacy/how-we-protect-privacy) — the same protections in plain language
- [Data Location & Retention](/security-privacy/data-location) — the security and retention detail behind principle 4
- [GDPR and Cookieless Analytics](/compliance/gdpr-cookieless-analytics) — the regulatory analysis