Under GDPR Article 6(1)(f), we’re permitted to process data for the legitimate interest of fraud prevention and campaign efficiency. Since we are not using this data for personalization, retargeting, or profiling — but only for exclusion — we believe this does not require consent under EU law. Can you confirm why exclusion-only user lists are still treated as personalized advertising in Google Ads?
On Monday, November 17, 2025 at 3:43:55 PM UTC+4 Google Ads API Forum Advisor wrote: > Hi, > > Thank you for reaching out to the Google Ads API support team. > > Please find your answers for your questions below: > > >> For uploadClickConversions with GCLID/WBRAID/GBRAID, what is the > expected behavior if the consent object is: > > If consent is missing for EEA users, then the consent value is determined > as not consented. Data from unconsented EEA users won't be processed and > cannot be used for ad personalization using Customer Match. See FAQs > <https://support.google.com/google-ads/answer/14310715> and updates to > consent mode <https://support.google.com/tagmanager/answer/13695607> for > more details. > > - > > Will these conversions still appear in reports (e.g. all_conversions)? > > No, the conversion will not be reported in UI if you don't specify the > consent. If consents are missing, then the consent value is determined as > not consented. Data from unconsented EEA users will not be processed and > cannot be used for ad personalization. > > - > > Will they still be eligible to populate a conversion-based user list? > > No, user lists are not eligible to populate. You can refer to the usage > flow > <https://developers.google.com/google-ads/api/docs/remarketing/audience-segments/customer-match/get-started#usage-flow> > > document which suggest to populate the consent field of > customer_match_user_list_metadata > <https://developers.google.com/google-ads/api/reference/rpc/v22/OfflineUserDataJob#customer_match_user_list_metadata> > in > your OfflineUserDataJob > <https://developers.google.com/google-ads/api/reference/rpc/v22/OfflineUserDataJob> > > request. > > >>Is a conversion-based user list that is used *only for exclusion* (invalid > traffic) still treated as “personalized advertising” and therefore requires > ad_personalization = GRANTED? > > Yes, you need to pass the consent > <https://developers.google.com/google-ads/api/reference/rpc/v22/Consent> > even when the user lists the user for exclusion. Only to remove user list > requests, consent is not needed. > > >> Is the following pattern correct/allowed: > > Yes, the pattern you have provided is correct i.e setting the > ad_user_data + ad_personalization = GRANTED for both the conversions and > user lists. > > >> When I *omit the consent object completely*, does Google infer consent > state automatically from Consent Mode / other signals and silently treat > some uploads as non-eligible (for reporting or user lists)? Or are such > uploads supposed to behave the same as if consent were not restricted? > > Yes, when you omit the consent > <https://developers.google.com/google-ads/api/reference/rpc/v22/Consent> > object then those uploads are not eligible and not reported in the user > list. > > As your list size list is small, I would suggest to pass the consent > parameter and refer to the help > <https://support.google.com/google-ads/answer/7474166> center. > > > Thanks, > > [image: Google Logo] Google Ads API Team > Feedback > How was our support today? > > [image: rating1] > <https://docs.google.com/forms/d/e/1FAIpQLSeRhIg5VeThVmbcD0c5DTWTDjmpJuSktN8vFelEL7_KV_Orbg/viewform?usp=pp_url&entry.141427034=1&entry.295079254=500Ht00001vTczSIAS> > > [image: rating2] > <https://docs.google.com/forms/d/e/1FAIpQLSeRhIg5VeThVmbcD0c5DTWTDjmpJuSktN8vFelEL7_KV_Orbg/viewform?usp=pp_url&entry.141427034=2&entry.295079254=500Ht00001vTczSIAS> > > [image: rating3] > <https://docs.google.com/forms/d/e/1FAIpQLSeRhIg5VeThVmbcD0c5DTWTDjmpJuSktN8vFelEL7_KV_Orbg/viewform?usp=pp_url&entry.141427034=3&entry.295079254=500Ht00001vTczSIAS> > > [image: rating4] > <https://docs.google.com/forms/d/e/1FAIpQLSeRhIg5VeThVmbcD0c5DTWTDjmpJuSktN8vFelEL7_KV_Orbg/viewform?usp=pp_url&entry.141427034=4&entry.295079254=500Ht00001vTczSIAS> > > [image: rating5] > <https://docs.google.com/forms/d/e/1FAIpQLSeRhIg5VeThVmbcD0c5DTWTDjmpJuSktN8vFelEL7_KV_Orbg/viewform?usp=pp_url&entry.141427034=5&entry.295079254=500Ht00001vTczSIAS> > [2025-11-17 11:43:17Z GMT] This message is in relation to case > "ref:!00D1U01174p.!500Ht01vTczS:ref" (ADR-00339498) > > > -- -- =~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~ Also find us on our blog: https://googleadsdeveloper.blogspot.com/ =~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~=~ You received this message because you are subscribed to the Google Groups "AdWords API and Google Ads API Forum" group. 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