Today I want to delve into the topic of 'Consent-Mode V2' specifically for you as an online shop operator, addressing all the questions relevant to you to get started with the topic within the next few minutes.
There are two variants of the Consent Mode: the Basic and the Advanced variant. I will explain the differences, the respective benefits, and which variant is most suitable for your case.
Lastly, we will clarify whether the Consent Mode is legally compliant and provide resources for you or your legal advisor to delve deeper into it.
One common question clarified upfront: Can we completely dispense with annoying "cookie banners" by using "Consent Mode"? Short answer: "No." This will be clarified at the end of the article in connection with GDPR, and I will explain what you actually need to implement.
Let's start with the question of what the Consent Mode is and what it means for us.
I compare the situations with and without Consent Mode, taking into account the GDPR since 2018. Before consent to the cookie banner, no tracking scripts may be loaded or data flows take place. After consent, tracking via Google Analytics tags, Google Ads tags, and similar scripts is permitted. The Consent Mode mainly affects Google services such as Google Ads and Google Analytics, but GDPR rules apply universally.
The Consent Mode is divided into two variants: Basic and Advanced.
From March, the Basic variant will be mandatory, the exact effects of which are not yet fully clear. It is possible that without the implementation of the Consent Mode, certain functions such as retargeting may no longer work, while conversion tracking may still be possible.
The main difference between the situations with and without Consent Mode is that without the user's consent, no tags may be triggered or data transmitted. With consent, data can be collected and transmitted, as before. However, the Consent Mode adds an additional signal sent to Google to confirm the legality of data collection. This signal is an innovation that Google likely introduces due to GDPR requirements to ensure that data is processed only with lawful consent.
In summary, the Consent Mode fundamentally does not change data collection, but merely adds an additional signal confirming the legality of data collection. As a user of Shoplytics, this is already implemented for you, but it is important to understand how this process works and what it means, especially regarding retargeting and conversion tracking.
The Advanced Consent Mode offers significant benefits, but these are not equally accessible to everyone. Particularly larger companies (with high visitor numbers and high click-through rates in Google Ads) can benefit, but its use requires certain prerequisites. In comparison to the previously discussed Basic Consent Mode, where tags may only be triggered with the user's consent, the Advanced Mode allows tags to be triggered even without explicit consent, albeit under strict conditions.
In the Advanced Mode, a reduced data set is already sent before the user's consent. This means that certain information can be transmitted to Google (Google Ads and GA4) as long as it is heavily restricted. An additional "Deny" signal is sent to Google, indicating that the visitor has not yet actively consented to data collection, and therefore only a reduced portion of the data may be collected. This is particularly important as it explicitly signals that the user has not yet granted consent. Google then adjusts the functionality of its tracking scripts to accommodate the restrictions, aiming for GDPR-compliant data processing.
Some key differences in the function of this "Advanced" mode (with "Deny" signal):
If the user then gives consent during the visit, the situation changes: all tags may be executed, cookies may be written, and all data may be collected and transmitted cohesively to Google.
We will address the question of GDPR compliance in the final part of the article. Just a quick preview: Google argues that this mode meets the requirements, but there is a question of whether this is actually the case or if Google is acting out of self-interest. Nevertheless, the Advanced Mode offers potential benefits for shop owners, especially through the ability to collect more data. Signals are also collected from all visitors who either rejected the cookie banner or have not yet accepted it. And more data is always good in our world full of data-hungry Google algorithms.
The question arises: What value do these data actually have? The data is anonymized to such an extent that no direct conclusions can be drawn about user behavior. Furthermore, this data does not appear in any report that could be used for direct analysis. What is the purpose of this anonymized data collection? And above all: What advantage does it offer for you as a shop owner?
This model allows reduced data to be sent before the explicit consent of the user. No cookies are used, and no user profile is created, thus preserving user privacy. An important aspect is that as an operator, you do not have direct access to this data; they remain invisible to you and instead flow into Google's artificial intelligence. This means you do not receive detailed reports on the behavior of users who have not given their consent.
The collected data, although anonymous and without user attribution, include important metrics such as the number of purchases or cart actions. This information is processed alongside the more detailed data of users who have given their consent. This combination results in a more comprehensive picture created by Google through data modeling. This modeling links anonymous data with detailed user data and allows for more precise conclusions about the behavior and preferences of visitors.
Let's assume that 100 purchases were recorded by users who clicked your cookie banner "accept." In this case, the signal "granted" was sent to Google. These are the purchases made with the complete consent of the visitors. The purchases have a complete user and behavioral profile.
Google knows everything about these purchases: e.g., where the visitor came from to your shop before making a purchase. Thus, the source of the purchase of these 100 purchases can be clearly identified. So, Google knows exactly what proportion of purchases came through your Google Ads ads. Let's assume that 50% of the total purchases came through your Google Ads ad.
In addition to these 100 purchases, there are another 100 purchases that were recorded by visitors without consent. Google knows nothing about these 100 purchases. Only that they occurred. Google was not allowed to collect data on the visitor source here (the "Deny" signal was sent due to lack of user consent). Google only knows: In addition to the 100 purchases for which we have a complete profile (including the visitor source), there are 100 "anonymous" purchases about which we know nothing.
And here's where the modeling comes in.
In the background, Google's artificial intelligence calculates the following:
From the 100 purchases for which everything is known, we know that 50% of them came through Google Ads.
Thus, it can be assumed that this ratio also applies to the "anonymous" purchases.
And suddenly it is clear that your Google Ads campaign not only brought 50 purchases but also another 50 purchases can be attributed to the Google Ads account.
The Google Ads algorithm and also your Google Ads manager suddenly have a much clearer picture of the actual performance of your campaign.
The algorithm can much better recognize that the work it is doing ("finding ready-to-buy visitors and directing them to your shop") was twice as good as previously thought. With the additional data available, the algorithm can much more quickly identify which new visitors it should show your ads to, in order to bring even more ready-to-buy visitors to your shop.
That's the competitive advantage you'll have by using the "Advanced" Consent Mode with activated conversion modeling in Google Ads. Your Google Ads algorithm will be much better trained with more extensive data, and your Google Ads manager will recognize the "actual" ROAS of the ads. As a result, you can make much better decisions about the allocation of your budgets. Meanwhile, the competition continues to struggle with one eye closed and one arm tied behind its back.
A significant advantage of this modeling is the improvement of data quality in Google Ads and Google Analytics 4 (GA4). In the case of Google Ads, the modeled data can help understand and improve campaign efficiency by providing a more realistic picture of the conversion rate. For GA4, this means that additional conversions derived from anonymized data are included in the reports through so-called Behavioral Modeling. These data significantly expand understanding of user behavior and enable more precise evaluation and optimization of marketing strategies.
It is important to emphasize that as a user, you have the choice whether to consider modeled data in your analyses. Google Analytics offers the option to include or exclude modeled data, giving you flexibility in data interpretation and analysis.
The same advantage that applies to Google Ads in the example above can also be applied to Google Analytics.
Through background data modeling, the additionally captured purchases (without consent) can be distributed proportionally across all visitor sources. Here, too, you receive a much more comprehensive and clearer picture of the true role of Facebook Ads, Google Organic, and all the other visitor sources for your business.
However, modeling in Google Analytics goes far beyond conversion modeling (e.g., of purchases as described above).
The entire visitor behavior (number of visits, number of page views, scroll behavior, click behavior, time on page, entrances, exits, bounce rates, etc.) is adjusted through "Behavioral Modeling." This also improves data availability. It creates a much more detailed picture of the weaknesses in your shop.
In summary, the Advanced Consent Mode aims to gain valuable insights into user behavior despite the restrictions imposed by privacy regulations. For Google, it offers the opportunity to improve its services and optimize personalized advertising. For you as a shop owner, it provides the chance to make better decisions based on an enhanced understanding of data and to make your online marketing strategies more effective.
Whether the use of the "Advanced" Mode makes sense for you and your shop depends on two factors:
To effectively use the Advanced Consent Mode, certain minimum requirements must be met. These requirements are important because machine learning and artificial intelligence require a sufficient amount of data to provide meaningful results.
For Google Ads, you need to reach at least 700 clicks per day over seven consecutive days within the last 28 days. This equates to approximately 25,000 clicks per month. This requirement ensures that enough data is available for modeling. It is not sufficient to temporarily increase the budget to reach the required number of clicks, as a permanent maintenance of this amount of data is necessary. Modeling in Google Ads is only activated when these minimum requirements are met, so it is important to take this threshold seriously.
For Google Analytics 4 (GA4), there are two specific requirements. First, you must reach at least 1,000 users per day who have accepted the Consent Mode (granted signal), and this on at least 7 out of 28 days. In addition, at least 1,000 standard events per day over 7 days with the rejection signal (deny signal) are required. These criteria ensure that Google Analytics receives a comprehensive picture of user activity, both from users who have given their consent and those who have denied it.
In summary, for effective use of the Advanced Consent Mode in GA4, you need approximately 30,000 users per month who have given their consent. Assuming that only 50% of users agree, you would need a total of about 60,000 users per month on your website. For Google Ads, about 25,000 clicks per month are required to activate data modeling.
Only when these requirements are met does it make sense to further explore the Advanced Consent Mode and the associated privacy considerations. These requirements ensure that enough data is available for Google's machine learning and artificial intelligence to perform effective modeling and analysis.
As a final consideration regarding "meaningfulness," there is the potential negative impact of data collection without consent (in the "Advanced" Consent Mode) on the trust of visitors to your shop in your brand.
Sure: Few shop visitors will be technically capable of understanding the situation and may not even recognize that data is already flowing to Google without the visitor giving their "OK."
Nevertheless, it may be that some visitors, influenced by the current topic of "data protection" and "GDPR," develop a negative and distrustful attitude towards your shop and brand if they realize that data is being collected without the visitor's consent. GDPR compliance of the Consent Mode "Advanced" aside. Even if it turns out that everything is in the green zone: Data collection (even if anonymized and GDPR-compliant) without the user's consent may not be appreciated by them.
The legal situation surrounding the Advanced Consent Mode requires special attention, especially due to existing privacy concerns. Although I am not a legal expert, I would like to share my acquired knowledge without guaranteeing its absolute correctness.
Regarding the Basic Consent Mode, there are no privacy concerns as long as data collection occurs solely with user consent. This clear situation poses no risks regarding privacy violations.
The situation is different with the Advanced Consent Mode, which raises questions about GDPR compliance, especially when users have not yet given their consent. In this mode, data is collected in reduced form, even without explicit consent, by sending a "deny" signal. This signals that no cookies may be set and only anonymous data is collected. No personally identifiable information such as IP addresses is collected, and Google takes measures to anonymize data before any processing outside the EU.
However, the mere loading of an analytics or ads script on the user's device could be interpreted as a technical change since the script was not previously present. Even the temporary caching of information could be seen as a modification to the user's device, raising questions about compatibility with the GDPR.
Currently, there is no definitive legal assessment or official statement on this aspect of the Consent Mode. The legal situation thus remains unclear and subject to interpretation.
Therefore, the use of the Advanced Consent Mode requires an individual risk assessment. Despite the attractive technological possibilities and (according to Google) compliance with privacy policies, the potential legal uncertainty should not be ignored. A well-considered business decision is required, possibly involving legal advice, to ensure compliance with current privacy requirements.
My Personal Opinion: If the section on "Purpose" and "Meaning" in this article has explained to you convincingly that you gain competitive advantages from the situation, I personally believe that the economic benefits of the Advanced Consent Mode outweigh the theoretical privacy risks. As long as you use the Consent Mode "Advanced" as described in this article, you are (in my opinion) at an advantage if you also use it.
Examining various scenarios - without the Consent Mode as well as the Basic and Advanced Consent Modes - has shown that without the Consent Mode, nothing changes in the existing practice: without consent, triggering tags and data transmission are not allowed. It is important to realize that regardless of the chosen Consent Mode, a consent banner is still required, as the regulations do not apply exclusively to Google but also affect other elements in the shop.
In the Basic Consent Mode, the situation remains largely unchanged compared to the standard procedure without the Consent Mode. Tags may not be triggered without consent, and no data may flow. The crucial difference is that after giving consent, an additional information signal is sent to Google, confirming permission for data processing. No new data is added, nor is the amount of data reduced.
The Advanced Consent Mode, on the other hand, leads to a fundamental change in approach: Tags must be executed, even without consent, if a "deny" signal is transmitted. This results in reduced data flow and signals to Google that no cookies may be set and no user profiles may be created. The collected data is solely used for training Google algorithms, without detailed reports being provided to the shop owner. Only with the user's consent are tags allowed to be set as usual, with the additional signal still necessary to confirm Google's full use of data.
The consequences of not sending this signal remain uncertain, such as whether this will result in no data being displayed, conversion tracking being prohibited, or only retargeting being restricted.
This presentation aims to provide a clear understanding of the functions and differences between the traditional procedure without the Consent Mode, the Basic Consent Mode, and the Advanced Consent Mode. Understanding these concepts is crucial for making an informed decision about their use and ensuring that your own procedures are privacy-compliant.
Ideally, your Consent Management Tool already supports Consent Mode V2, and all you need to do is activate the "Consent Mode" option in your Consent Management Tool. You can find a list of all Consent Management Tools that directly support Consent Mode V2 and can be used by activating the corresponding option here directly in Google's list.
We have prepared a separate article with step-by-step instructions for this purpose. Simply click here for the practical guide.