AdButler has always embraced “Privacy by Design”, and because of this, we have a very small footprint on your users’ browsers. AdButler only has two features that involve cookies to carry out their respective functionalities. Both of these cookies do not store any personal data (including personal IDs) which means that you do not need to collect explicit consent from your users before using these AdButler features.
Although the GDPR was not meant to address non-personal data, there was a misalignment on the implementation of two new regulations: GDPR and ePrivacy Regulation. ePrivacy regulation was intended to replace the Data Protection Directive, which was repealed on May 25, 2018, but the ePrivacy Regulation has been delayed. In order to address the impending relatory gap that handles cookie privacy, a provision was added to the GDPR that says that references to the Data Protection Directive “shall be construed as references to this Regulation [the GDPR]”.
Because of this provision, and the fact that the Data Protection Directive addresses consent for cookies in general (not specifically those with personal data or IDs), there will be a period of time where GDPR transparency is required for cookies containing non-personal data.
Accordingly, you will need to disclose the following information to your EU users regarding these two cookies.
Please note that if you do not use AdButler Frequency Capping or AdButler Conversion Tracking, you do not need to disclose this information to your EU users.