Privacy policy clauses for Cookiebot
Cookiebot is a cookie consent management platform that helps websites comply with privacy regulations by identifying, categorizing, and managing cookies and similar tracking technologies. It enables websites to obtain user consent before deploying non-essential cookies and provides transparency about data collection practices.
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When does Cookiebot trigger privacy obligations?
Installing Cookiebot triggers privacy obligations the moment its script runs on your site, because Cookiebot itself sets a consent-management cookie (CookieConsent) to track user choices. This cookie is placed *before* you collect consent for other cookies—which is legally permissible under GDPR Article 7(4) and ePrivacy Directive Article 5(3) because consent-management cookies are exempt from pre-consent requirements. However, this exemption is narrow: Cookiebot's cookie exists solely to *record* consent decisions, not to track or profile users.
Once Cookiebot is live, GDPR applies if you process any personal data of EU residents (no traffic threshold). CCPA applies if you process personal data of California residents and meet one of three thresholds: $25M+ revenue, data on 100k+ consumers/households, or data sales generating 50%+ revenue. The ePrivacy Directive (or national implementations like PECR in the UK) applies to electronic marketing and cookie storage.
Your first concrete step: audit which cookies and trackers your site currently fires *before* consent is given. Cookiebot will block non-essential cookies after deployment, but only if configured correctly. Map each cookie/script to a category (Analytics, Marketing, Preferences, Strictly Necessary) and document why it belongs there. Without this audit, your Cookiebot configuration will be incomplete or incorrect, leaving you non-compliant.
Common compliance pitfalls
Misconfiguring consent categories and leaving tracking cookies unblocked
Cookiebot relies entirely on your classification of third-party scripts and cookies into its categories. A common mistake is marking Google Analytics or Facebook Pixel as 'Strictly Necessary' to avoid friction, or simply ignoring cookies that fire before users see the banner. The consequence: you're collecting tracking data without affirmative consent, violating GDPR Article 6(1)(a) (lawfulness of processing) and ePrivacy Directive Article 5(3). DPAs in France, Austria, and Germany have issued fines specifically for misconfigured consent tools.
