TrustComponent

Privacy-compliant CAPTCHA

How TrustCaptcha handles personal data, and which privacy laws matter for a CAPTCHA.

Privacy as a core design principle

TrustCaptcha was built on privacy by design: it uses data for verification only, sets no cookies and builds no profiles.

TrustCaptcha was built on one principle: security should not cost your visitors their privacy. A privacy-compliant CAPTCHA has to stop bots without watching people. Older CAPTCHA approaches rely on behavioral monitoring or cross-site signals, while TrustCaptcha uses the data it receives for verification only. It sets no cookies, keeps data to a minimum and creates no persistent identifiers, and processing takes place in EU data centers. That makes it a good fit for companies that work under strict privacy rules in several regions.

Designed for privacy-first deployments

TrustCaptcha operates as a security control, not a data collection layer.

  • ✓ No cookies set on user devices
  • ✓ Security-only purpose limitation
  • ✓ Clear documentation for reviews

CAPTCHA privacy laws around the world

GDPR

Under the GDPR, CAPTCHA-related data (e.g., IP address, device/browser signals, and interaction patterns) can be personal data. If your company is established in the EU or if you serve users there, you typically need a legal basis for the processing and a clear explanation in your privacy notice.

What TrustCaptcha does about it is summed up on our product page for the GDPR-compliant CAPTCHA.

Data sovereignty

Data sovereignty is about who controls verification data and where it is processed. TrustCaptcha processes it in EU data centers.

CCPA / CPRA (California)

TrustCaptcha does not sell or share personal data and builds no profiles, which are the practices California's privacy law looks at most closely.

LGPD (Brazil)

TrustCaptcha collects only what verification needs, uses no persistent identifiers and does not reuse the data for other purposes.

CPPA (Canada)

Minimal processing and clear documentation help meet the law's expectation that processing is proportional and limited to its purpose.

DPDPA (India)

Verification used only for security, with as little data as possible, fits the data minimization principles of India's DPDP Act.

PDPA (Singapore)

TrustCaptcha does no profiling and no persistent tracking, so the data stays within its security purpose.

PIPL (China)

Because TrustCaptcha does no tracking, it fits the data minimization and purpose limitation principles in the PIPL.

APPI (Japan)

Processing is limited to one stated purpose, security, which matches the APPI's focus on a clearly specified purpose of use.

Australian Privacy Act

TrustCaptcha collects no more than verification needs, in line with the Act's principles on collecting and handling personal information.

Which CAPTCHA laws apply to me?

It depends on where you operate and who you serve

International organizations often fall under multiple privacy regimes at once, especially when serving users across borders.

The privacy laws that apply to your CAPTCHA implementation depend on where your company is established, where your end users are located, and the regulatory expectations of your industry.

TrustCaptcha keeps data use small, does no tracking and keeps the CAPTCHA focused on security instead of user analysis. That makes overlapping obligations easier to meet.

Privacy law compliance flowchart for CAPTCHA

Data protection resources

Documentation that simplifies reviews

For legal, security, product and procurement teams.

Data Processing Agreement (DPA)

Every customer gets a DPA that sets out TrustCaptcha's role as your processor.

Request DPA

Need help with a vendor/security questionnaire?

Contact us and we'll help you answer the questions about TrustCaptcha.

Contact Us

Frequently Asked Questions

Questions about CAPTCHA privacy

Short answers to what legal and security teams ask most often. For anything else, contact us.

What is CAPTCHA privacy compliance?
CAPTCHA privacy compliance means stopping automated abuse while minimizing data collection, avoiding unnecessary tracking, and keeping processing strictly limited to security. In practice, it focuses on data minimization, purpose limitation, and transparency around what happens during a challenge. TrustCaptcha follows this approach by operating without cookies or profiling and keeping verification focused on bot protection.
Does using a CAPTCHA require user consent?
Whether consent is required depends on how the CAPTCHA works and what data it uses. If it relies on non-essential tracking, profiling, or advertising-related processing, consent requirements are more likely. If it’s implemented as a security-only control with minimal, transient signals, consent is less likely to be required. TrustCaptcha is designed for that second case. This is not legal advice: check your own setup with your data protection officer.
How can CAPTCHAs support compliance?
CAPTCHAs support compliance by reducing privacy risk through minimal data use, avoiding cross-site tracking, limiting retention, and preventing secondary uses like analytics or marketing. Clear documentation and predictable processing make legal reviews easier. TrustCaptcha follows privacy by design and keeps the CAPTCHA step limited to security.
What data do CAPTCHAs process?
CAPTCHAs typically process limited technical and interaction signals to distinguish humans from bots, such as request metadata, network indicators, and challenge outcomes. Privacy risk increases when signals are stored long-term, shared across contexts, or used to create persistent identifiers. TrustCaptcha keeps signals transient, avoids persistent identifiers, keeps verification data only for a short retention period and builds no profiles from it.
What should legal, security, and procurement teams evaluate in a CAPTCHA vendor?
Evaluate what data is collected, whether tracking or fingerprinting is used, retention periods, cross-border transfers, subprocessors, and the availability of DPAs and privacy documentation. Security teams should also assess reliability, abuse resilience, logging practices, and incident response readiness. TrustCaptcha keeps these reviews short by using little data and providing a DPA and privacy documentation.