KVKK Compliance in Web Analytics: Google Analytics 4, Matomo and Alternatives
Web analytics tools for digital marketing and user experience measurement are essential; However, by late 2025, the article reports closer scrutiny of these tools’ KVKK/GDPR compliance in both…
⏱️ Reading time: 13 min · 📁 Category: KVKK & Web Analytics
KVKK Compliance in Web Analytics: Google Analytics 4, Matomo and Alternatives
Web analytics tools for digital marketing and user experience measurement are essential;
However, by late 2025, the article reports closer scrutiny of these tools’ KVKK/GDPR compliance in both the EU and Türkiye.
In particular, Google Analytics 4 (GA4) and similar US-based solutions face complaints concerning
international data transfers and technical identifiers
, according to the article.
Organisations therefore need to assess analytics tools for legal compliance and data transfer risks, as well as their technical capabilities.
The article summarises a position attributed to European authorities in 2025: Google Analytics requires appropriate additional measures for GDPR compliance. 1. GA4 and Data Protection Agenda: Why is it So Controversial?GA4 offers more advanced anonymization than previous versions; however, some risks remain:
- IP address processing: the article describes uncertainty about GA4’s stated anonymisation in the EU
- Risk of data transfer to the United States (due to Google infrastructure)
- Behavioral profiles created with event-based monitoring
- Integration with 3rd party advertising systems
Server-side tagging routes analytics processing through a server and can improve control over data sent outside the EU or Türkiye, depending on the configuration.
KVKK-related advantages of server-side tagging:- User IP masking is done more effectively
- Data transferred to 3rd party is minimized
- Personal data categories can be filtered
- Cookie lifetime and scope can be controlled
This does not make Google Analytics risk-free; the article describes it as a potentially sufficient technical measure in Board audits, subject to the specific implementation and legal assessment.
Server-side processing does not remove cookie obligations; the article states that advertising and analytics cookies still require explicit consent. 3. IP Masking (Anonymization): What Does It Mean in terms of KVKK?IP addresses are treated as personal data under KVKK. Masking them is therefore important for GA4 and other tools.
IP masking models:- Automatic masking: described as GA4’s default, though the article notes technical uncertainty
- Server-side masking: truncating the final octet of an IP address
- Proxy-based masking: preventing the IP address from being sent to a third party
Common findings of EU data protection authorities:
- SCC + GA4 is not enough -> DTIA mandatory
- U.S. surveillance risks (FISA 702) should be considered
- IP masking alone does not ensure sufficient anonymity
- Google’s data centres may replicate data outside the EU
- GA4 cannot be executed without user consent
The article presents self-hosted Matomo as avoiding international transfer risks by keeping data on company servers; this depends on server location, integrations and access arrangements.
Advantages:- Data does not go outside EU/Turkey
- A cookieless mode is available
- IP masking can be customized
- Profiling is limited
- requires more technical setup
- may offer less advanced reporting than GA4
These tools minimise data collection through cookieless analytics.
Featured features:- The article describes these tools as processing no personal data, with anonymised IP addresses and no fingerprinting; the actual configuration must be assessed.
- May operate without a cookie banner, depending on configuration and applicable requirements
- Low risk for GDPR/KVKK
These solutions are especially ideal for content sites, blogs and basic reporting needs.
7. Technical and legal measures for KVKK-compliant web analytics- Separate cookie categories: essential, analytics and advertising
- explicit consent mechanism (mandatory for analysis cookies)
- Application of IP masking
- Server-side tagging control
- DTIA documentation for third-party tools such as GA4
- Storing data transfer logs
- Update of privacy notice
- Cookieless analytics solutions will become more widespread
- Technical measures requirements for GA4 use will increase
- Migration to self-hosted analytics will accelerate
- EDPB may publish specific guide to analytics tools
Sources and related documents
These documents provide references for the methods and rules discussed in this article.
