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Storing a cookie with a counter still requires consent afaik. If I am right, then this technique is not sufficiently different and also requires consent.


Why would that require consent?


Consent is always required; even if you just give people a random UUID, with no associated session/etc., that always requires consent.

There is a separate question, of whether consent is implied. If the identifying information is required to provide the user with a service they requested (e.g. a cookie for their online shopping cart), then consent is implied; no need to ask.


Giving a random UUID and giving someone a counter is significantly different. This is not identifying and thus does not require consent.


I don’t think this would require consent. It is not, as described in the post, uniquely identifying. It is not even pseudononymous. Thus, it is not personal data and does not require consent.




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