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> track sessions-of-use, for adjusting design, even before any commerce or specific-identity info is disclosed. And that value flows not just to the websites: it helps adjust content/UI for the users, as well.

Tracking (regardless of whether cookies or other methods are used - the dumb idea that GDPR only cares about cookies needs to die) for essential purposes such as maintaining state for shopping carts/user preferences/etc does not require disclosure nor consent.



That essentially every professionally-developed website I visit seems to have concluded differently makes me doubt your analysis - or, if your analysis is technically true, that that analysis is relevant to real websites' needs.




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