Essential Mode

JENTIS Essential Mode is a product feature that enables simultaneous tracking of website data based on two user consent preference scenarios:

User provides consent

The access to a user device and storing of data on user device is enabled after the consent is received / user clicks “consent”.

User does not provide consent

In case a user does not give consent, as a fall back option and to maintain data quality, JENTIS system allows website operators to configure website tracking within the limitations of the access to and storage of data on user device based on “strictly necessary” exception under ePrivacy Directive.

JENTIS acts as the processor in relationship with the Customer (controller) because the system processes data only in accordance with the instructions that are enabled through JENTIS SaaS configuration by the Customer. JENTIS does not process this data for its own purposes, therefore handling data in the first party context.

Integration of a tag management in the first party context as well as loading of the CMP for the purposes of managing the user consent preferences, when implemented as a “container solution” falls under the ePrivacy “strictly necessary” exception.

Downstream processing of the “strictly necessary” data takes place on JENTIS Twin Server (server side) and enables Customers to process data based on legitimate interest in accordance with Art 6(1)(f) GDPR.

Relying on strict criteria of the German DSK (Orientierungshilfe 01.12.2021) for “strict necessity”, JENTIS embedded specific privacy enhancing elements into the Essential Mode feature. These privacy enhancing elements enable Customers and their data protection teams to configure “strictly necessary” access and storage to comply with the consent exception rules under Art. 5 para. 3 sentence 2 ePrivacy Directive (also see § 25 (2) TTDSG):

(a) Time of data storage

To increase page speed, JENTIS Essential mode allows for synchronous load of JENTIS Tag Manager and the CMP of Customer’s choice. By default, the reading of information & storage in the JENTIS systems is activated after the website visitor interaction with the consent banner.

(b) Content of the information

By default when the Essential Mode is activated, the data parameters are minimised and modified in the following ways:

JENTIS does not store User IP Address when Essential Mode is activated.
JENTIS shares only JENTIS Server IP Address in communication with third parties.
JENTIS substitutes third party client IDs with a randomly generated JENTIS client ID.
JENTIS makes it technically possible to remove all click IDs in URLs.
JENTIS does not merge IDs to avoid the risk of re-identification.
JENTIS allows to blur the timestamps to avoid the risk of re-identification.
JENTIS makes it technically possible for the Customer to anonymise or pseudonimyse any data parameter.

(c) Duration of information storage

Storage of data in the Essential Mode is limited to a maximum of 13 months by default.

Storage duration can be set individually by the Customer to address data minimisation in the most adequate way and to store data for as long as it is necessary for the implementation of the granular function of the telemedia service.

(d) Readability of information

JENTIS technology allows to control the first party context of data. This means that all third-party components are removed from server side and replaced in such a way that neither direct terminal equipment access nor direct transmission of user data, such as the IP address and user IDs, is carried out to third-party servers as part of an immediate server request from the user's browser. Capturing the data on the client side as a sole processor, the website operator (Customer) collects and processes the data on the server side as the sole controller of data.

Additional Resources

For legal assessment and example configuration, please have a look at:

For any questions feel free to reach out to your direct contact at JENTIS or to our Compliance & Legal Team via email at privacy@jentis.com.