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There are benefits to being a US based company that doesn't target EU users, even if it doesn't reject EU users, I guess.

I can't think of a way to actually use any kind of tracking cookies, even non-ad/sales/data-harvesting related that wouldn't be annoying in EU.

Of course, if you manage your own load balancing, could definitely combine a load-balancer pinning cookie (uuid) for "all" uses as a single "essential" cookie.




Load balancing would fall under "essential" cookies that don't require a permissions. No banner necessary.

See GitHub.

You can't use the data for other purposes though.

Tracking without cookies requires consent no matter how you implement it. Claiming it to be essential won't fly if, say your Marketing or sales team has access.


Why cannot load balancing be implemented without cookies?


using a cookie that is essential for non-essential purposes, is not allowed. So using a load-balancer cookie is fine, as long as it's only used for load balancing.

Once it's used for other (technically non-essential) needs as well, one needs to find another basis for processing or ask permission for that second purpose(consent basis).

Also, if the LB cookie can be non-identifying, while fullfilling the stated technical purpose, it must not allow identifying users. So for LB cookies, one must not use a unique ID per user, but an LB ID instead. Something like "node1", "node2" etc...




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