Can I use only a privacy statement instead of a cookie policy

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Mathieu

Mathieu

IT Law Specialist

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On some sites you see a cookie warning which points to a privacy statement only, and the cookie policy is absent. Some users have asked if Complianz GDPR could be adjusted to do this same thing. I have discussed this with our legal partner, Mathieu Paapst. Read it in this article.

Cookie policy: describe what your are asking consent for?

The cookie warning should always link to the information about the cookies which are about to get placed on a user’s system, as you’re asking the user for consent to specifically place and read these cookies. The E-Privacy draft speaks of a “clear and prominent notice”.

Reading this, it allows for the cookie information to get added to a privacy policy as well, as long as it’s “clear and prominent”. The question which arises then is what you are asking permission for: the privacy statement also discusses other things.

Our conclusion is that it’s not recommended to point your cookie warning to a privacy statement.

CCPA and US privacy laws

If you are specifically focussed at US visitors, it might be necessary to add a privacy policy link separately. Cookie banners and privacy policies specifically aimed at US visitors is something which will be added in the next update.

Adjusting the Cookie Policy URL

So is it possible to change the URL which is included in the cookie banner? Yes. You need a small piece of code which you can add in your theme’s functions.php:

add_filter('cmplz_cookie_settings', 'cmplz_my_cookie_policy_url', 10, 1);
function cmplz_my_cookie_policy_url($settings){
  $settings['readmore_url'] = 'https://complianz.io/cookie-policy/';
  return $settings;
}

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