It is still work in progress, but there are some modifications now. So, this demo is still a draft.
The cookie banner itself is unchanged, but:
- Links for privacy & cookie policies are placed in the footer.
- Opt-Out has some information included.
This information could help you if you are searching for a solution for integrated policies and a cookie banner. This is integrated with the service from Iubenda, but some aspects could be helpful using equal solutions.
Privacy & cookie policies
Both policies are separated links and open an overlay window. The information regarding Matomo & Do Not Track is integrated in each policy. As the Do Not Track (DNT) functionality affects only the setting of cookies for the Matomo tool they are grouped together under the topic “Analytics” in each policy for now.
Why separated policies?
How to add services in Iubenda and declare a purpose for them:
Integrating policies in the footer
This is the applied method:
Code Snippet:
This is the slightly shortened & modified code snippet:
// footer
var topP = document.createElement("p");
//topP.style.textAlign = "center";
topP.innerHTML = '<hr><div class="custom-nav"><a href="https://www.iubenda.com/privacy-policy/YYYYYY" class="iubenda-nostyle no-brand iubenda-embed" title="Privacy Policy ">Privacy Policy</a> | <a href="https://www.iubenda.com/privacy-policy/YYYYYY/cookie-policy" class="iubenda-nostyle no-brand iubenda-embed" title="Cookie Policy ">Cookie Policy</a></div>';
var cont = document.getElementById("wrapper");
if (cont !== null) {
// Add to blog index and tag pages
cont.appendChild(topP);
} else {
// Add to individual blog post page
cont = document.getElementById("post-body");
cont.insertAdjacentHTML("afterend", topP.outerHTML);
}
Matomo
Iubenda offers a standard text for Matomo. This one is included. But the opt-out for Matomo has to be described additionally with a link to the opt-out page. It is possible to integrate a custom service in Iubenda.
This is the additional text field for opt-out of tracking by Matomo:
Matomo Web Analytics: How to: Opt-out
The User may opt-out of the tracking done via Matomo Analytics by following the link below and then clicking the opt-out option on the presented page. Please note that the opt-out works by applying a cookie to the User’s browser which in turn signals to Matomo not to register the particular User. This means that the User needs to opt out again, when visiting this site in another browser or another device.
Opt out of Matomo Analytics on this page
Matomo integration:
Do Not Track
Do Not Track is added as additional service into the policies.
This is the additional text field for Do Not Track:
Matomo uses cookies, or small text files saved on your computer, but it also respects your browser’s Do Not Track (DNT) setting.
If you don’t use DNT Opt out of Matomo Analytics on this page
The issue with the added DNT service into the policy is that this one differs from the integrated standard clause regarding DNT.
This one can be found under “Additional information about Data collection and processing” → ‘How “Do Not Track” requests are handled’.
The standard information regarding DNT in every Iubenda policy:
How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
As it seems this standard clause can be replaced by request. I will update this information at a later point.
Data transfer outside the EU
There is another information embedded in the privacy policy. This one is the standard clause for GDPR compliance.
Here is the simplified version that you see first:
Data transfer outside the EU
Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield
Personal Data: various types of Data
The privacy policy offers more details in the section “Detailed information on the processing of Personal Data”.
At this point there is input needed by the team of write.as. Is it possible to give a statement regarding this? As it seems this is mandatory – at least for me from an European country.
The section “Legal bases for transfer” provides the most relevant sets of legal bases:
There is an older article that gives some background information to the connection between Privacy Shield and the GDPR. Next to this Safe Harbour is mentioned as the predecessor of Privacy Shield. It is worth reading this one as this article offers a differentiated view:
Opt-out
This page is still a draft also. There is still redundant information and some pieces to reflect.
My thought would be to give enough information at hand but focused enough for a short overview.
And yes, I think it is necessary to use a separate opt-out page integrated in my own blog. This one has to be translated for German readers also. It would feel not consistent to guide German readers to an opt-out page with English content. So I need some feedback what is missing or is eventually misleading.