Start with the data flows
Whether your website needs a cookie banner depends on its technologies and the applicable law. Having no tracking cookies does not automatically make every processing activity lawful. Forms, server logs and external content can also involve personal data.
Record the services contacted, the data they receive and the information stored in the browser. A product name alone does not determine the answer.
Distinguish Switzerland and the EU
The FDPIC guidance on cookies and similar technologies explains Swiss information, objection and consent requirements. Non-essential cookies do not automatically require opt-in consent in every Swiss situation.
For the EU, Article 5(3) of the ePrivacy Directive is also relevant. Non-essential storage or access generally requires prior consent. Exceptions include strictly necessary operations. The rules applying to a particular offering need individual assessment.
This article discusses technical choices. It does not replace a legal review of your offering.
Technical choices that simplify the review
- Serve fonts locally when an external font service is unnecessary.
- Link to a map instead of embedding one where a link is sufficient.
- Load videos only after their integration and any required consent have been assessed.
- Avoid advertising profiles when the offering does not need them.
- Check what a cookieless analytics provider actually processes.
A tag manager is a tool for loading services. Its configuration and the tags actually loaded determine the data flows. A “cookieless” label does not replace that review.
The current approach on eluma.ch
The website project serves fonts locally and configures Plausible for analytics. The URL determines the language. Language routing does not set a NEXT_LOCALE cookie.
This describes the technical configuration. It is not a blanket promise of legal compliance. Details about forms, service providers and contact options appear in the privacy policy.
A practical review
- Open the website in a fresh browser profile.
- Inspect network requests, cookies and other browser storage, including after using forms or embeds.
- Record the purpose, recipient and retention for each service.
- Assess information, objection and consent requirements for the actual offering.
- Review again when services or embeds change.
Fewer external services can simplify the review. They do not establish a particular improvement in speed, rankings or enquiries.
You can request a project discussion to review your website’s data flows.