International privacy annex
EU/EEA: GDPR, cookie consent and transfer controls
Privacy annex for EU/EEA visitors covering GDPR notices, cookie consent, analytics, transfers and service-provider approval.
Status: Draft; GDPR and legal approval pending
This annex outlines data-processing requirements and relevant sources; it is not a final legal opinion. Legal, privacy and language reviews remain pending, and existing launch restrictions still apply.
Audience
business visitors in the Netherlands, Germany and other EU/EEA countries with matters involving Russian customs
Data that may be involved
- business contact details and company role
- document type, receipt date, deadline and country or route
- Strictly necessary storage does not depend on analytics consent. Local storage holds preferences and consent records. On production hosts, Google Analytics runs only after explicit consent.
- communication metadata when Telegram, email or Zoom is used
Launch safeguards
- no non-essential analytics or marketing tags before explicit consent
- clear accept and reject controls, with tested behaviour
- international transfers and service providers require approval before paid targeting
- Dutch and German pages remain subject to language and legal approval
Service-provider approval
GA4 is restricted to consent mode. LinkedIn Insight Tag, retargeting and customer-list uploads remain blocked pending a GDPR transfer assessment and evidence of valid consent.
Language-version status
An interim English annex only; Dutch and German versions are not yet approved for publication.
Implementation evidence required
Evidence includes HAR network records before and after consent on EU pages, plus screenshots of the consent controls and privacy-policy link.