Umami’s cookie-free design does not by itself establish that a site can skip consent or other privacy obligations. Its session documentation says the session identifier is a hash generated using a visitor’s IP address, user agent, and website ID. To assess a deployment, review what it collects, how that identifier is handled, where data is stored, and how long it remains there; then assess the relevant GDPR and ePrivacy rules for the site’s jurisdiction.
What Umami collects—and why “cookie-free” is not the whole answer
Umami says its tracking code uses no cookies. Its FAQ also lists page views, referrer URLs, browser, operating system, device type, and country of origin among the information collected. Its Sessions documentation, available since Umami v2.13.0, describes a session as a unique hash generated from the visitor’s IP address, user agent, and website ID.
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These details matter because the absence of cookies does not mean that no personal data is processed. Nor does the word “hash” establish that an identifier is anonymous. A hash can be pseudonymous rather than anonymous if a person can still be singled out or identified by means reasonably likely to be used. The EDPB discusses this general issue for salted or keyed hashes in its Guidelines 02/2025 on processing of personal data through blockchain technologies; that guidance is not an assessment of Umami specifically.
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Choose a deployment and map who controls the data
Umami offers self-hosted and Cloud deployment paths. It says self-hosting gives the operator control over infrastructure and data. That control also means the operator needs to account for the systems they run. The official Umami overview describes the deployment options, but the sources cited here do not establish current Umami Cloud retention, processing locations, subprocessors, or transfer arrangements. Check current service terms for those details before relying on Cloud.
| Question | Self-hosted | Umami Cloud |
|---|---|---|
| Who controls the analytics infrastructure and database? | The operator controls the infrastructure and data, according to Umami. | Check current service and contractual documentation; not established by the cited sources. |
| Who implements retention and deletion? | The operator must set a retention period and carry out deletion. | Check current Cloud terms and service documentation; a specific retention period is not established here. |
| What else should be reviewed? | Application version, proxy or CDN path, database, backups, server logs, telemetry settings, and access permissions. | Processing locations, processor terms, subprocessors, international transfers, retention, and available compliance documentation. |
| Operational trade-off | More direct control, alongside responsibility for operation, upgrades, backups, security, and deletion. | Service operation is provided through Umami Cloud; verify the current terms and evidence needed for your own assessment. |
Reduce collection in the tracker
Umami documents tracker controls for respecting a visitor’s Do Not Track setting, excluding URL fragments, and inspecting or cancelling outgoing event payloads. These controls can reduce or suppress collection, but they are not a consent-management system. Consult the Tracker configuration documentation for the syntax supported by your installed version.
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data-do-not-track="true"makes the tracker respect a visitor’s browser Do Not Track setting.data-exclude-hash="true"prevents collection of the URL hash.data-before-sendlets a callback inspect or modify an event payload; returning a false-y value cancels that payload.
Umami documents automatic pageview and click tracking. Check whether those events, along with any custom events, are necessary for the stated purpose. Test representative routes and payloads for personal or sensitive data in paths, query strings, referrers, and event properties—for example, names, email addresses, account identifiers, or search terms. A tracker option does not help if those values are sent through another route or captured elsewhere in the deployment.
Understand the IP-derived session hash and IP exclusions
The session description means an IP address contributes to an identifier; do not describe this as proof that the raw IP is never processed or that the resulting hash is necessarily anonymous. The status of an identifier depends on the full context, including whether people can reasonably be singled out or identified from it and other available data.
Umami’s environment-variable documentation says SALT_ROTATION controls how often the anonymous session salt rotates and documents month as the default. Salt rotation is not the same as deleting historical analytics records, and the documentation says deterministic IDs derived from analytics data are unchanged by the UUID setting. Confirm the behavior and available variables against the version you have deployed.
The same documentation describes IGNORE_IP as a comma-delimited list of IP addresses and CIDR ranges to exclude from data collection. That can be useful for excluding known internal or test traffic. It is not documented as a general-purpose IP anonymization control or as a substitute for deciding whether consent is required.
Set a retention period and make deletion real
Umami’s FAQ says self-hosted data is retained indefinitely unless the operator manually deletes it. The cited FAQ does not specify an automatic self-hosted retention interval. If you self-host, choose a period that fits the analytics purpose and applicable obligations, document it, and implement a deletion process for the analytics database. Include backups and logs under your control in that review, and verify deletion behavior on the installed version.
Do not assume that Cloud uses the same retention rule or assign it a period without checking current Cloud service documentation and contractual terms. The available sources cited here do not establish Umami Cloud’s current retention period.
Assess consent, legal basis, and notice separately
“No cookies” is not a blanket answer to whether consent is required. The GDPR legal basis for processing is a separate question from whether a tracker stores information on, or accesses information from, a visitor’s device under applicable ePrivacy rules. The EDPB lists six GDPR legal bases and explains that the appropriate one depends on the context in its Legal basis guidance.
The French data protection authority, CNIL, describes a conditional consent exemption for certain audience-measurement tools, including conditions such as truncating the last byte of an IP address. This is French regulator guidance, not a blanket exemption for every Umami installation or every EU/EEA jurisdiction. Assess the actual tracker behavior and the rules applicable where your site operates; do not assume that an IP-derived hash satisfies CNIL’s IP-truncation condition.
Your privacy notice should describe the analytics actually in use: its purpose, data categories, retention, and applicable rights. Avoid blanket statements that Umami is anonymous, collects no personal data, or never needs consent unless those claims are established for the specific deployment and jurisdiction.
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Website visitor analytics and telemetry sent by the Umami application are different data flows. Umami’s environment-variable documentation says the application collects anonymous telemetry to improve the product and documents DISABLE_TELEMETRY=1 as an opt-out. If you want to minimize external calls, review this setting and confirm its behavior for your installed version; changing it does not configure visitor tracking.
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