Euroconsumers response to the Digital Omnibus call for evidence: Cookie fatigue

The rules on cookies and other tracking technologies are fragmented between the ePrivacy Directive and the GDPR, leading to inconsistent enforcement, high compliance costs and widespread “cookie consent fatigue”, which some exploit through manipulative design that leads to involuntary consent. Believing consumer trust and business innovation go hand in hand, Euroconsumers proposes integrating cookie rules into the GDPR framework through a dual-pillar approach: making legitimate interest the default legal basis for personalisation, with strict limits, transparency and an easy opt-out; and creating a conditional exemption for privacy-enhancing analytics under strict data minimisation rules. Together, these would strengthen privacy, reduce consent fatigue and give businesses legal certainty to use non-invasive data.

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