Stats4U - Free Counters

In short

You can download your counter's figures as CSV or JSON at any time, free of charge and without asking. The links are on the counter's statistics page.

There is nothing to switch out of: no account, no term, no notice period, no charge. Stopping means taking the code off your own site.

Chapter II of the Regulation — connected products — does not apply here. Stats4U is not an item and belongs to none. The reasoning is under 3., and it is set out at length there, because an assertion without reasoning is worth nothing.

Chapter VI — switching between data processing services — has no microenterprise exemption. Whether it covers a free visitor counter is doubtful; the operator does not rely on that doubt but states under 6. what is there and what is missing.

This page is information, not legal advice. It states the operator's own assessment and has not been reviewed by any authority or lawyer.

1. Why this page exists

The Data Act does not require a page like this. There are two reasons for it anyway.

The first is practical. The most common question about a service you embed for ten years is not about a regulation but "can I get at my figures, and can I get out again". This page answers that in one place, with the links you need for it.

The second is the honest answer to the Regulation itself. Where it does not apply, that is the information — with reasons. A claimed conformity that nobody has examined would be the worse answer.

It is information and not legal advice. Anyone who needs a legal assessment of their own case should get it from someone who answers for it.

2. What the Data Act is about

The Regulation consists of several chapters with quite different subjects. It does not "apply" as a whole to everybody — it has to be gone through one chapter at a time. In order:

• Chapter II (Art. 3–7) — access to the data generated by the use of a connected product and a related service.
• Chapter III (Art. 8–12) — how data are to be made available if an obligation to do so exists.
• Chapter IV (Art. 13) — unfair contractual terms about data access and data use, unilaterally imposed.
• Chapter V (Art. 14–22) — data for public sector bodies on the basis of exceptional need.
• Chapter VI (Art. 23–31) — switching between data processing services.
• Chapters VII and VIII — international access, interoperability.

For Stats4U exactly one of these comes seriously into question, namely Chapter VI. The others are dealt with under 3. to 5., so that it can be followed why they drop out.

3. Chapter II: connected products — not applicable

Chapter II hangs on two terms, and Art. 2 defines both of them narrowly.

A connected product is, under Art. 2(5), an *item* that obtains, generates or collects data concerning its use or environment and that is able to communicate them, and whose primary function is not the storing, processing or transmission of data on behalf of third parties. Stats4U is not an item. There is no hardware that goes to a user, no device and nothing you can pick up.

A related service is, under Art. 2(6), a digital service connected with such a product in such a way that its absence would prevent the product from performing one of its functions, or that subsequently adds to the product's functions. There is no product here for anything to be connected to. A visitor counter on a website is not an accessory to an item.

Both terms therefore lack the thing they attach to, and Chapter II runs empty. That is the operative reason.

In addition, and only for completeness: Art. 7(1) exempts micro and small enterprises from the obligations of Chapter II. Stats4U is a sole trader with no employees and would fall within it. That exemption is not relied on here — an exemption you invoke presupposes that the rule bites. It does not.

The pre-contractual information duties of Art. 3(2) and (3) likewise hang on the connected product and fall away with it.

4. Chapters III and IV

Chapter III (Art. 8–12) governs how data are to be made available where an obligation to do so follows from Chapter II or from other Union law — fair, reasonable and non-discriminatory terms, reasonable compensation, dispute settlement. No such obligation exists here (see 3.), so there is nothing for Chapter III to shape.

Chapter IV (Art. 13) makes unilaterally imposed contractual terms about access to and use of data non-binding where they are unfair. The terms of service contain no clause restricting a user's access to their own figures, forbidding their use of those figures, or granting the operator rights in them. Export is open to every counter holder, free of charge and without condition.

Chapter IV has applied since 12 September 2025 to newly concluded contracts; for contracts concluded before that date for an indefinite period or with a long term it applies from 12 September 2027.

5. Chapter V: data for public sector bodies

Chapter V obliges data holders to make data available to public sector bodies where there is exceptional need. For micro and small enterprises the scope is narrower: they owe data only where those data are needed to respond to a public emergency and the body cannot obtain them by other means in time.

No such request has been made so far. If one came, it would fail on the facts before it failed on the law: what is held here is aggregated access figures for individual websites, not location, health or traffic data.

Orders by authorities outside the Data Act — in criminal proceedings, for instance — are unaffected. How those are handled is set out in section 6 of the privacy policy.

6. Chapter VI: switching between data processing services

This is the part that comes seriously into question, and that is why it stands here at length.

The microenterprise exemption does not help here. Art. 7(1) exempts micro and small enterprises from Chapter II — not from Chapter VI. Chapter VI contains no such exemption. Anyone writing otherwise has not read Art. 7(1) to the end.

Whether a free visitor counter is a "data processing service" is doubtful. Art. 2(8) means a digital service that enables ubiquitous, on-demand network access to a shared pool of configurable, scalable and elastic computing resources that can be provisioned and released with minimal management effort. What is meant by that is IaaS, PaaS and SaaS. Here nobody provisions or releases computing resources; there is a fixed service with a fixed function and nothing to configure or scale. A broad reading that catches every web application can nonetheless be argued.

The operator does not rely on that doubt. Rather than assert an inapplicability that nobody has examined, here is what is actually in place and what is not:

• Art. 23 — removing obstacles. There are none. No account, no registration, no term, no minimum duration, no charge, no lock. Stopping means taking the code off your own site; no declaration to the operator is needed.
• Art. 25 — contractual terms. The article requires particular clauses in the contract: a notice period of at most two months, a transition period, a right of export, deadlines. Those clauses are not in the terms of service. The reason is that there is nothing to terminate and access to the data does not depend on a contract continuing. If Chapter VI applies, that is a gap in form. It stands here rather than not standing here.
• Art. 26 — information duties. What can be exported and in what format is under 7. Where the data are: on a server in Łódź, Poland. They do not leave the European Union.
• Art. 29 — switching charges. From 12 January 2027 none may be levied. None ever have been, because the service as a whole is free of charge.
• Art. 30 — technical aspects. Export is in a structured, commonly used and machine-readable format (CSV and JSON), and additionally through an open interface. Details under 7. and 8.
• Art. 31 — specific regime. Neither a custom-built single commission nor a time-limited test version. Neither applies here, so neither helps.

What switching means in practice: export the figures, swap the code, delete the counter. Stats4U cannot make a count continue at the next provider from the level reached — that would require the other service to accept a starting value, and whether it does is its decision.

7. What you can download

On every counter's statistics page there are two links, CSV and JSON. They cover the period currently selected on the page — not a fixed one, so that the file shows what the page shows.

CSV contains the daily values: date, hits, visitors, automated access.

JSON contains the same daily values and, in addition, the totals and the breakdowns by country, city, region, browser, operating system, device, recognised program and most visited subpage.

Both are free of charge, subject to no condition and need no sign-in. For a counter marked private or protected by a password the management token is needed — the same check as for the page itself.

What is not in it, because it does not exist: there is no row per visit. What is stored are daily figures per feature; visitors are told apart by a salted daily hash whose salt is deleted after a few days. An export cannot contain what was never collected. The details are in the privacy policy.

8. The interface

The same data are available machine-readably at /live/<number>/stats.json. The endpoint answers with a cross-origin permission so that a script on your own site can read your own figures.

A limit of sixty requests per hour and address applies, and the answer may be cached for five minutes. The reason is not scarcity but the machine: counter numbers can be enumerated, and a counter should not cost one database query per visitor.

Private and password-protected counters never reach it. These are the same figures that are public on the statistics page anyway.

9. Stopping and deleting

Stopping works without us: remove the code from your own site. Nothing is counted after that. There is no notice period, no declaration and no confirmation.

Deleting works with us, and completely. At the very bottom of the owner area on the statistics page there is a collapsed section; whoever has the management token there and types the counter number deletes the counter and everything belonging to it — some twenty tables, in one go. What stays behind is the number in an archive, so that it is not handed out a second time.

The export links stand before the delete button, not beside it. That is deliberate: a shadow copy after deletion would be the opposite of a deletion, so there is none. Anyone who wants to keep their figures fetches them first.

A deletion cannot be undone. There is no backup from which a deleted counter could be brought back.

10. If the management link is gone

There are no accounts here. Losing the management link would also mean losing access to export and deletion — which is why there is a way back that needs no email address: recover a counter.

The proof is that you can edit the page the counter sits on: write a short string there, we fetch the page and look. The counter has to be on the same page, and that address has to be one the counter actually counted.

Every recovery changes the token. A second access makes the first link invalid, and that is noticeable.

11. What is not offered

So that the information is correct in both directions:

• No import. There is no way to feed in a count reached at another service, or its history, here.
• No takeover by another provider. There is no common format for visitor counters that anybody adheres to. The export is CSV and JSON — both common, both readable, but that is a data format, not a switching format.
• No write interface. The interface reads. Figures cannot be set or altered from outside.
• No backup for you. What the operator backs up, he backs up for operations and not as a service to users. Anyone who wants to keep their figures exports them.

12. Relationship to the GDPR

The Data Act leaves the GDPR untouched (Art. 1(5)). The two stand side by side, and each means something different.

The right to data portability under Art. 20 GDPR concerns personal data based on consent or contract. For counter data it largely runs empty: they are aggregated, contain no IP addresses and cannot be assigned to an individual person. The export under 7. exists regardless — it does not depend on a right, it is simply there.

The data subject rights — access, rectification, erasure, objection — are set out in section 9 of the privacy policy, together with what limits us in meeting them.

13. Dates

The Data Act entered into force on 11 January 2024 and applies in stages:

• since 12 September 2025: the Regulation in principle, including Chapter VI (switching) and Chapter IV for newly concluded contracts,
• since 12 September 2026: Art. 3(1) — access to data by design — for connected products and related services placed on the market after that date,
• from 12 January 2027: no more switching charges (Art. 29),
• from 12 September 2027: Chapter IV also for contracts concluded before 12 September 2025 for an indefinite period or with a long term.

These dates were looked up, not remembered. The Regulation is the subject of ongoing amendment work at Union level; anyone relying on a deadline should check the Official Journal of the European Union.

14. Supervision

Art. 37 requires Member States to designate competent authorities. For Poland an act on fair access to data and their use is in the legislative process; under it the President of the Office of Electronic Communications (Prezes Urzędu Komunikacji Elektronicznej, UKE) is to be competent.

Whether that act is already in force at the time you read this has not been conclusively checked by the operator. It is put that way because naming an authority that does not yet exist would be worse than the note that competence is not yet settled.

For the matter itself, write to stats4u@lukaswojcik.com. A different authority is responsible for data protection complaints; it is named in section 10 of the privacy policy.

15. Further documents

These apply and explain in addition:

• the privacy policy — what is collected, how long it stays and what rights you have,
• the page on the AI Act — where a language model is involved and where it is not,
• the terms of service and the data processing agreement,
• the imprint.

What the counter costs a third-party page is measured and stands under weight. What the service is doing right now stands under status.

Version

Version 1.0, as of 1 September 2026. This page is information about the actual state of things and not legal advice; it states the operator's own assessment and has not been reviewed by any authority or lawyer.