Fictional product, illustrative draft. Not legal advice.
Shutterline Cookie Notice¶
Draft for counsel review. Law as of 20 October 2026. This is not legal advice.
This notice explains what Shutterline stores on or reads from your device (cookies, local storage, and similar technologies), why, and how to control it. It works alongside our [Privacy Notice].
1. Categories we use¶
| Category | Purpose | Needs your consent? | Duration | Shared with a third party? |
|---|---|---|---|---|
| Strictly necessary | Keep you logged in, remember your session, load-balance our servers, store your cookie-consent choice | No: strictly necessary for the service you asked for | Session or [X days] | No |
| Analytics (aggregated, on-platform only) | Understand how Shutterline is used, in aggregate | Yes | [X months] | No |
| Contextual advertising support | Show an advertisement next to content, not based on your personal profile | [To confirm with client: if this reads any identifier from your device, it needs consent; if it is purely based on the page content with no device read, it may not. Drafted here as needing consent out of caution.] | [X months] | [Name of ad-serving vendor, if any] |
| Personalised advertising | Select which advertisement to show you based on what you have viewed and liked on Shutterline | Yes | [X months] | [Name of any ad-tech vendor, if any: see open point below] |
[Open point, see open-points.md item 6: this notice is drafted on the assumption that personalised advertising uses only on-platform signals (what you view and like on Shutterline) and does not involve a third-party ad-tech SDK, cross-device matching, or data bought from outside Shutterline. If personalisation in fact uses a third-party tool, that tool's name, the data it accesses, its retention period, and whether it shares data outside Shutterline all need to be added to this table before publication, and the consent banner's first layer needs to name that third party individually rather than referring to "partners" generally.]
2. EU and UK users: how our consent banner works¶
Before we store or read anything on your device for a purpose that is not strictly necessary, we ask for your consent. Our banner:
- names each purpose separately, with its own on/off control that starts off;
- gives you a reject option on the same screen as accept, equally prominent;
- lets you keep using Shutterline without accepting anything beyond what is strictly necessary;
- names [any named third party] individually if we use one, not just "partners" in general;
- tells you whether data is processed outside the EEA (see our [Privacy Notice], Section 6); and
- lets you change your mind at any time from [Settings → Privacy → Cookie settings], just as easily as you gave consent in the first place.
We do not label a cookie "essential" or "strictly necessary" unless it meets that standard, and we keep a current list able to justify each label on request.
Germany¶
At the point we ask for consent, we also name: whether we build and enrich an individual profile of you using data from other sites, whether any data is processed outside the EEA, and how many parties your data is disclosed to, if any. Where one button grants both this storage consent and a related data-processing consent under the GDPR, we tell you this clearly at the same point, rather than only on a deeper screen.
3. United States: how opt-out works¶
For a US user, we honour an opt-out of "sale" or "sharing" of personal information for cross-context behavioural advertising, to the extent our personalised-advertising category above falls within that definition. You can opt out by [link to opt-out mechanism], or, where you use a recognised opt-out preference signal in your browser, we honour that signal automatically.
[Open point: whether the personalised-advertising category as actually built counts as a "sale" or "share" of personal information under the CCPA's own definitions turns on the mechanics confirmed in the open point above (item 6) and on the CCPA threshold question (item 4); this section is drafted to offer an opt-out regardless of that determination, as the more conservative approach, but the exact regulatory label (sale, share, or neither) should be confirmed with counsel.]
4. Changing your choice later¶
You can change your cookie choices at any time from Settings → Privacy → Cookie settings, or the link in the footer of every page. Changing your choice takes effect immediately and takes the same number of steps as giving consent in the first place.