Cookie banners predate the GDPR: they were initially for the (much older) ePrivacy Directive, though many sites now have combination consent gathering flows for

Cookie banners predate the GDPR: they were initially for the (much older) ePrivacy Directive, though many sites now have combination consent gathering flows for ePrivacy+GFPR. For your specific question, I think the Planet49 ruling gets pretty close. "It does not matter whether the cookies constitute personal data or not - Article 5(3) of the e-Privacy Directive (i.e. the cookie consent rule) applies to any information installed or accessed from an individual's device." [1] (still not a lawyer) [1] https://www.twobirds.com/en/news/articles/2019/global/planet49-cjeu-rules-on-cookie-consent https://www.twobirds.com/en/news/articles/2019/global/planet...