What must an online store's cookie banner look like according to the Spanish data protection authority?

Q&A • Privacy

What must an online store's cookie banner look like according to the Spanish data protection authority?

The banner is not legal decoration: if consent is invalid, none of the cookies installed are valid either. The basis is article 22.2 of the LSSICE and the Spanish authority's cookie guidance.

Short answer

  1. No non-essential cookie may be installed before the user gives consent.
  2. The reject button must appear on the first layer, with the same prominence as accept.
  3. Continuing to browse or scrolling is not valid consent.
  4. Users must be able to accept some categories and reject others, without digging into submenus.
  5. Withdrawing consent must be as easy as giving it, through a permanent link on the site.

What the first layer must offer

  • An «Accept all» and a «Reject all» button with the same visual weight.
  • Access to per-category settings: analytics, personalisation, advertising.
  • Identification of the controller and a short explanation of what the cookies are used for.
  • A link to the cookie policy listing the cookies and their retention periods.

Essential and non-essential cookies

What requires consent in a store

CookiePurposeConsent?
Shopping cartKeep the added productsNo
User sessionKeep the user signed inNo
AnalyticsMeasure visits and behaviourYes
Advertising pixelsRemarketing and campaignsYes
Third-party videos and mapsEmbedded contentYes

Common mistakes

  • Loading analytics as the page opens and showing the banner afterwards.
  • Styling «Accept» in colour and «Configure» in grey, with no direct reject option.
  • Blocking access to the store for anyone who rejects non-essential cookies.
  • Copying a generic cookie policy that does not match what is actually installed.
  • Forgetting embedded videos and maps: they also install third-party cookies.

How 4shopy helps

  • The store runs on technical cookies: the cart and checkout do not rely on trackers.
  • Analytics and marketing tools are enabled by configuration, so you know exactly what is running.
  • The cookie and privacy policies are dedicated pages, linked from the footer.
  • Since third-party videos are not embedded by default, there are few cookies to declare.