That's correct, if you don't collect or use that data in the first place, you don't have to ask. Keeping email addresses and placing cookies for account creatio

That's correct, if you don't collect or use that data in the first place, you don't have to ask. Keeping email addresses and placing cookies for account creation doesn't by itself require a notice, just due care in handling. It's when you want to use it for advertising or other "off label" purposes that these messages become mandatory.