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European Union cookie law. Yes another topic!


Michel_72

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EU customers historically tend to pay more than those of us in the US to companies like Adobe, Microsoft, etc. -- this is a large reason why. There's simply a higher cost of doing business with EU customers. If you wouldn't mind paying more as an IPS customer in the EU, we likely wouldn't mind entertaining the notion of retaining ongoing EU counsel, researching and maintaining the software for seemingly ever-changing EU regulations. Otherwise, as a US company we can't guess and offer our own interpretations of EU law for our customers -- it would be irresponsible to do so. From a sheer business standpoint, eating the costs of retaining ongoing EU counsel to maintain ongoing EU compliance across the suite would not be a fruitful venture for whatever slight gain in marketshare. 

​I would not mind paying more.

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​I would not mind paying more.


Based on customer feedback, all customers residing in the EU will now pay $250 per license and $75 per renewal. There will then be a yes/no popup for cookies. 

See? We listen!! 

:lol:

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EU customers historically tend to pay more than those of us in the US to companies like Adobe, Microsoft, etc. -- this is a large reason why. There's simply a higher cost of doing business with EU customers. If you wouldn't mind paying more as an IPS customer in the EU, we likely wouldn't mind entertaining the notion of retaining ongoing EU counsel, researching and maintaining the software for seemingly ever-changing EU regulations. Otherwise, as a US company we can't guess and offer our own interpretations of EU law for our customers -- it would be irresponsible to do so. From a sheer business standpoint, eating the costs of retaining ongoing EU counsel to maintain ongoing EU compliance across the suite would not be a fruitful venture for whatever slight gain in marketshare. 

​one reason why laws confuse the crap out of me... so who really has to follow this cookie law thing? everyone? or people who get EU clients? EU hosters only?

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If you wouldn't mind paying more as an IPS customer in the EU, we likely wouldn't mind entertaining the notion of retaining ongoing EU counsel, researching and maintaining the software for seemingly ever-changing EU regulations.

That’s one way to do it, but there is another way to see:
If I can’t use IPS for those legal reasons, I pay you $0. If I could use IPS software without problems in the EU, I would be willing to spend hundreds of dollars over years to come. So it doesn’t really matter if I as EU customer pay an extra fee or not – the money for IPS is in the question if I can use the software at all. 

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That’s one way to do it, but there is another way to see:
If I can’t use IPS for those legal reasons, I pay you $0. If I could use IPS software without problems in the EU, I would be willing to spend hundreds of dollars over years to come. So it doesn’t really matter if I as EU customer pay an extra fee or not – the money for IPS is in the question if I can use the software at all. 

I'm not aware of a significant loss of sales due to the fact we don't bear the site owner's burden of responsibility for ensuring compliance with laws of all varying jurisdictions. Whether we'd gain enough EU marketshare to justify the immense ongoing expenditure of retaining counsel in the EU for ongoing consulting with compliance and the extra development effort, is impossible to substantiate. At this juncture, we maintain that it's the responsibility of the site owner to comply with local laws. If you have feedback regarding features that aren't specific to compliance, but could make your life easier, please feel free to let us know. 

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​Based on customer feedback, all customers residing in the EU will now pay $250 per license and $75 per renewal. There will then be a yes/no popup for cookies. 

See? We listen!! 

:lol:

​Seriously? Is this your official statement? Sorry, but that response is just ignorant and very disrespectful to me and to anyone over in the EU who actually cares about the law and customers with the need for compliance. If this would be such a meaningless topic it would not have come up numerous times by now. Folks in this thread took the time to try to explain and figure something out the software company is supposed to do (imho...) and instead of taking this seriously we get a snappy sarcastic one-sentence "cookie popup" response? Thanks...

Get off your (american?) high horse and please reconsider your position on this. If from a business standpoint the EU market or the segment that wants to provide law-abiding services isn't found to be of any concern to you that's fine with me. Comments like this on the other hand, that show no concern whatsoever about needs of a group of people known as clients, are not. Deal with this in a professional manner. Thanks.

 

 

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​Seriously? Is this your official statement? Sorry, but that response is just ignorant and very disrespectful to me and to anyone over in the EU who actually cares about the law and customers with the need for compliance. If this would be such a meaningless topic it would not have come up numerous times by now. Folks in this thread took the time to try to explain and figure something out the software company is supposed to do (imho...) and instead of taking this seriously we get a snappy sarcastic one-sentence "cookie popup" response? Thanks...

Get off your (american?) high horse and please reconsider your position on this. If from a business standpoint the EU market or the segment that wants to provide law-abiding services isn't found to be of any concern to you that's fine with me. Comments like this on the other hand, that show no concern whatsoever about needs of a group of people known as clients, are not. Deal with this in a professional manner. Thanks.

 

 

​There are a number of proper replies to this issue throughout this topic. In fact one right above your reply.

It is of course your choice to take the one, humorous, lighthearted post out of context in this entire topic and get all worked up over it.

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We need to say which cookies we set and for what they are used.

I did not make IPS Software, so i don't know this, which means it needs to be done by IPS. 

If i get a fine because my site is not complaining with it, i will need to search another solution that complains(if i still have money after the fine). 

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​Seriously? Is this your official statement? Sorry, but that response is just ignorant and very disrespectful to me and to anyone over in the EU who actually cares about the law and customers with the need for compliance. If this would be such a meaningless topic it would not have come up numerous times by now. Folks in this thread took the time to try to explain and figure something out the software company is supposed to do (imho...) and instead of taking this seriously we get a snappy sarcastic one-sentence "cookie popup" response? Thanks...

Get off your (american?) high horse and please reconsider your position on this. If from a business standpoint the EU market or the segment that wants to provide law-abiding services isn't found to be of any concern to you that's fine with me. Comments like this on the other hand, that show no concern whatsoever about needs of a group of people known as clients, are not. Deal with this in a professional manner. Thanks.

 

 

It was merely an attempt at some light hearted humo(u)r - no disrespect was intended. :)

The fact that this topic started in 2013, the law has already changed several times since inception and you folks, even amongst yourselves still can't completely agree on how or even if you need to comply is telling in itself, is it not? China has pretty strict regulations. Even the US has varying regulations in different jurisdictions. We develop software... we're not global attorneys that keep track of and interpret laws across the world while incorporating all of those accommodations into the software -- hoping, for liability purposes, that we get it right for everyone. 

IPS software is fully customizable -- you are absolutely free to customize it to suit your interpretation of the laws of your jurisdiction. Perhaps someone will create a marketplace add-on based on one of the many interpretations. Some think a mere disclaimer at the bottom "this site uses cookies" is sufficient. Others argue that implied consent is required. Some argue implied consent is only required for tracking cookies. Others argue not only do you need to obtain implied consent, you need to detail what every cookie does. In reality, what YOU are doing with your site and WHERE you are doing it determines what you need to do to comply, if anything. If, for example, you're adding analytics to your site, the requirements may be different than a stock IPS software installation. Whatever the case, interpretation of such end-user laws is unfortunately outside the responsibility of a software manufacturer -- I'm not aware of related software companies that provide for this, even those based within the EU. 

We're very happy to entertain feedback regarding things like "I need XYZ feature to properly collect tax via Commerce." -- but we're not opening this particular pandoras box, sorry.

I apologize that making light of the concern was perceived as offensive. I hope this statement better clarifies our position on EU regulation. If you have any further concerns - we're always here to listen. You may find me personally on my clydesdale wearing a red, white and blue lapel pin. (Final attempt at humor, I promise. :))

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We need to say which cookies we set and for what they are used.

I did not make IPS Software, so i don't know this, which means it needs to be done by IPS. 

If i get a fine because my site is not complaining with it, i will need to search another solution that complains(if i still have money after the fine). 

​As far as I know, none of the major paid or unpaid forum/suite development companies do what you are asking for in that post. vBulletin, phpBB, Xenforo, and MyBB all have mod communities just like IPS and I know that vBulletin and phpBB, at least have a mod that takes care of the cookie issue. My point to this is your saying IPS NEEDS to do this. They don't need to do ANYTHING other than what they put in their terms and conditions of service and other official documentation. Per my previous post it was understood that what was needed was a feature that will let the site admin input text, that text will popup on the site and give an agree/disagree option and that be it. Now if this is what you are asking for IPS may be more willing to add it. If what you are saying is that you want them to do a site owners job and put the text in there themselves then, absolutely not. If what you are saying is that cookies need to be separated into different subgroups or whatever, again that isn't IPS's responsibility. You know what you were getting when you purchased the software. There is a full demo available for said software.

If IPS chooses to make these cookie subgroup things that would be pure awesomeness for the people that need it (for whatever reason). If they choose to put in the field where the site admin can put in the EU cookie law text, that would be awesome as well. As I stated above, IPS has a very good modification community. I am sure if a feature is needed there will be someone to create it, whether free or paid.

 

Dark Shogun

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We're very happy to entertain feedback regarding things like "I need XYZ feature to properly collect tax via Commerce." …

​Here you go ;-)

To sell subscriptions/ads (i.e. electronic services) or files (i.e. electronic goods) through Commerce from the EU we need (since January 2015):

  • a user choice for “business customer” or “consumer”  (radio button or indirectly through filling out the business name field)
  • if it’s a business, a VAT ID field needs to appear, which business from other EU countries could fill in
  • if filled in, that VAT ID should to be checked through one of the available APIs in real-time. 
  • if correct, the tax will be reduced to 0, unless the sale is from the same country as the store owner.
    (For consumers and missing/failed VAT IDs the default VAT-per-specific-country and -product rates apply)
  • for successful VAT ID checks, the invoice then needs to automatically show the VAT IDs of the buyer and seller and a text string (“reverse_charge_note") where the store owner can explain why no tax was applied. (IPS doesn’t need legal counsel for the content of that field. It can be blank by default.)

This is one of the functionalities which decides, if I can even open new IPS sites in the future. And it applies to all EU businesses who want to run any serious business with IPS software using the built in purchase options. 

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​Here you go ;-)

To sell subscriptions/ads (i.e. electronic services) or files (i.e. electronic goods) through Commerce from the EU we need (since January 2015):

  • a user choice for “business customer” or “consumer”  (radio button or indirectly through filling out the business name field)
  • if it’s a business, a VAT ID field needs to appear, which business from other EU countries could fill in
  • if filled in, that VAT ID should to be checked through one of the available APIs in real-time.
  • if correct, the tax will be reduced to 0, unless the sale is from the same country as the store owner.
    (For consumers and missing/failed VAT IDs the default VAT-per-specific-country and -product rates apply)
  • for successful VAT ID checks, the invoice then needs to automatically show the VAT IDs of the buyer and seller and a text string (“reverse_charge_note") where the store owner can explain why no tax was applied. (IPS doesn’t need legal counsel for the content of that field. It can be blank by default.)

This is one of the functionalities which decides, if I can even open new IPS sites in the future. And it applies to all EU businesses who want to run any serious business with IPS software using the built in purchase options.

​I did ask for a few of this very low key a few times in the past, I would love this to be available, and I would actually pay for it too.

Let me add one additional point regarding VAT: B2B in the same country is still due VAT. And VAT for all others now is rated at the VAT of the country the purchaser resides in, or where a product is delivered to (shipping address).

I would also love to have multiple currencies in the store, and not so much selectable based upon a conversion rate, although I also want that, but essentially multiple prices based on the currency used :). I want to be able to use different pricing models for different countries and currencies essentially, and I really need to, considering the difference in not only pricing models, but costing models as well.

The way I currently deal with this is with some hacks and manually altering/changing stuff. We work with suppliers in the US and Europe currently, not that we sell a lot, but we also sell adverts and subscriptions, so these are sold from Europe, while other stuff is sold from the US.

Administration/bookkeeping for all this stuff is absolutely horrendous, especially for a volunteer run site, so if there could be an add-on to deal with all the above, which are essentially all add-ons required for Nexus, and an add-on for the cookie bits, I would actually pay good money for them as it would save a hell of a lot of time for us/me. I would even pay for it myself. If really need be, I will develop this myself, but I do know that that will take a lot of time. Although I have been quite the decent developer up until about 15 years ago, I am a newb when it comes to php, and have only been developing a little in my spare time ever since - so I'd prefer someone else to develop this for me :).

Kind regards, Wim

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​Here you go ;-)

To sell subscriptions/ads (i.e. electronic services) or files (i.e. electronic goods) through Commerce from the EU we need (since January 2015):

  • a user choice for “business customer” or “consumer”  (radio button or indirectly through filling out the business name field)
  • if it’s a business, a VAT ID field needs to appear, which business from other EU countries could fill in
  • if filled in, that VAT ID should to be checked through one of the available APIs in real-time. 
  • if correct, the tax will be reduced to 0, unless the sale is from the same country as the store owner.
    (For consumers and missing/failed VAT IDs the default VAT-per-specific-country and -product rates apply)
  • for successful VAT ID checks, the invoice then needs to automatically show the VAT IDs of the buyer and seller and a text string (“reverse_charge_note") where the store owner can explain why no tax was applied. (IPS doesn’t need legal counsel for the content of that field. It can be blank by default.)

This is one of the functionalities which decides, if I can even open new IPS sites in the future. And it applies to all EU businesses who want to run any serious business with IPS software using the built in purchase options. 

​We are in fact reviewing all of this for Commerce. 

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It was merely an attempt at some light hearted humo(u)r - no disrespect was intended. :)

The fact that this topic started in 2013, the law has already changed several times since inception and you folks, even amongst yourselves still can't completely agree on how or even if you need to comply is telling in itself, is it not? China has pretty strict regulations. Even the US has varying regulations in different jurisdictions. We develop software... we're not global attorneys that keep track of and interpret laws across the world while incorporating all of those accommodations into the software -- hoping, for liability purposes, that we get it right for everyone. 

IPS software is fully customizable -- you are absolutely free to customize it to suit your interpretation of the laws of your jurisdiction. Perhaps someone will create a marketplace add-on based on one of the many interpretations. Some think a mere disclaimer at the bottom "this site uses cookies" is sufficient. Others argue that implied consent is required. Some argue implied consent is only required for tracking cookies. Others argue not only do you need to obtain implied consent, you need to detail what every cookie does. In reality, what YOU are doing with your site and WHERE you are doing it determines what you need to do to comply, if anything. If, for example, you're adding analytics to your site, the requirements may be different than a stock IPS software installation. Whatever the case, interpretation of such end-user laws is unfortunately outside the responsibility of a software manufacturer -- I'm not aware of related software companies that provide for this, even those based within the EU. 

We're very happy to entertain feedback regarding things like "I need XYZ feature to properly collect tax via Commerce." -- but we're not opening this particular pandoras box, sorry.

I apologize that making light of the concern was perceived as offensive. I hope this statement better clarifies our position on EU regulation. If you have any further concerns - we're always here to listen. You may find me personally on my clydesdale wearing a red, white and blue lapel pin. (Final attempt at humor, I promise. :))

​Thanks for that response, as you probably could tell, i was really pissed off. Sorry for that. You're right, the state of the law is constantly shifting, that's why it is such a delicate topic for me. Since I a as a solution provider for my customers am to be held liable I need strong partners that take that away from me. The well known Shop-software XT Commerce for example strongly advertises their compliance with the law which gives them a strong USP against their competitors. They do make the different regulations their priority and offer tons of settings for tons of countries, regularly updating the mechanics to comply with current laws. And that's actually something I expect from a professional software company. IPS isn't just a "framework" where I am indeed responsible on how to make use of the tools, your software suite is a comprehensive system with lots of areas where different laws in different countries do matter. That starts with a simply "premium feature" user-group that can be purchased for 2 bucks and ends with the selling of downloadable files and items in the shop. None of those functions are currently usebale anywhere in the EU. User wimg listed a whole bunch of things that are missing (and aren't simply mod-able like a cookie popup) but there are lots of other things.

A few examples in relation to eCommerce:

  • Ability for the seller to decide country-based what VAT to be used (local or foreign) for b2c
    • If you sell lets say from Germany to customers in Spain you can choose wether to use the German or Spanish VAT
    • This rule is in effect as long as your turnover stays below a certain amount (for Spain its 35.000 Euro)
    • If you are over this limit you automatically are subject to turnover tax in that country
    • Your decision on what Tax to use is binding for 2 years
    • So if you reach the 35k mark on October the 2nd all your shop Items that are being sold to Spain have to switch from 19% VAT (Germany) to 20% VAT (Spain)
  • Execption for certain items in your shop for the above rule
    • There are products or services that have special taxes in the foreign country
    • So if you for example have decided to sell such an item with the German VAT 19% to Spain the spanish VAT has to be added due to EU law
  • Since January the 1st of 2015 there's a new rule in effect concerning "electronically delivered services" (eBooks, Downloads, Streaming ...)
    • If you're selling those services to a consumer customer you have to pay turnover tax in the country of the customer
    • Contrary to "real" items, you cannot choose what tax to use
  • Small Business Owners (Business with below 17.500 Euro turnover)
    • Those business owners do NOT have to apply VAT to sold items
    • BUT: They DO have to add VAT when selling thus "electonically delivered services" to foreign countries
    • Therefore are simple "tax yes/no" option in any webshop software isn't enough...

I could now go on and on but as I said, figuring this out is something I expect from the software developer ;-) As you probably can tell, those things are not something one single web solution provider can handle on his own. That's why I am indeed am willing to pay more.

​We are in fact reviewing all of this for Commerce. 

​Cool!

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Hi DREffects2,

Thanks for your exhaustive post, that is really great.

One additional thing, however. Some of these rules are still different per country in the EU as well. I have been told by my accountant that officially I have to charge the VAT-rate of the country delivered to, whether it is physical goods or downloaded items. And as far as I understood, the exemptions you mention are (were) only for non-VAT registered companies. The moment you are VAT-registered those rules do not apply any longer.

All of this was really caused by the fact that the different tax offices in the different countries saw all this VAT going to the country were the sales office was, so to speak, and they thought they were missing out. :)

Ah well.

My accountant also advised me that this year shouldn't be a real problem yet, they will likely only start clamping down on this new law from next year, mostly because they realize that the changes on admin (bookkeeping) and software side are rather complex and radical. If this is indeed the case (no guarantees unfortunately), it means we have some time still to implement stuff, and hopefully not have to do all this by hand anymore.

We recently started selling physical items again from different locations worldwide, to get funding for the running costs of our (volunteer run) site, and it used to be a nightmare trying to sell in different currencies and still conform to the bookkeeping requirements. For now we have chosen to sell in just a single currency, but that gets expensive rather quickly, and for the advertising we sell on an ad hoc basis that just is impossible. Clients insist on paying in their own currency. For this specific option we only use 3 currencies now, but that may change in the future. You don't want to know how complex my spreadsheets are currently .... :). It would be great if that could be handled all through Nexus/Commerce for sure.

I will also gladly pay more for this, and I even wouldn't mind constructively beta-testing for this, and giving input for what is required, and what we would like.

I think that in the end this would be a true USP for Invision in the EU. AFAIK, no one else is doing this either, when it comes to Community software.

BTW, I don't know if it does, because I can't test it, but it would be rather nice if Nexus/Commerce also captures any costs involved with transactions. It doesn't in 3.4.7, though Donation tracker f.e. does, and it would make quite a difference from an admin POV for sure.

Final point is the current (in 3.4.7) way Nexus/Commerce deals with Invoices and Transactions. The way I see it, Invoices are Orders, and Transactions are Invoices (should be anyway) - this makes things extremely confusing for bookkeeping purposes. Maybe there is a solution for this already, I haven't looked yet. Transactions are just the payments between client and supplier over here, often via an intermediary, especially when doing business electronically (so could include the transfer of monies from the client to a bank account, f.e., and the confirmation that that indeed has received).

Kind regards, Wim

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Hey Wimg,

of course the VAT stuff only applies to VAT registered companies - I kind of presumed that ;-) (Hey IPB Team, thats yet another missing feature! There are non VAT companies out there...).

Please remember that if your company is not VAT registered there are still deliverey and buy limits within the EU member states.

Please see http://www.hk24.de/recht_und_steuern/steuerrecht/umsatzsteuer_mehrwertsteuer/umsatzsteuer_mehrwertsteuer_international/367108/Lieferschwellen.html for more information (in german though, but the limits are kind of universal^^)

As soon as you start doing business within the EU member states you'll loose the right to choose as you need an european VAT id for invoming invoices from foreign countries.

If we start with invoices/transactions we open another delicate topic concerning EU billing laws. Currently the so called 'invoices' can actually result in hefty fines because they lack the proper required features. But that's another topic alltogether.

 

 

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It's worth mentioning that nobody has ever been prosecuted or fined for not following this law, which has changed so many times most people just don't bother.

Even ICO, the organisation that "enforces" the law doesn't require you to explicitly accept cookies on their own website; they simply have a box that basically says that they use cookies and if you use their site then they presume storing cookies is okay.

This page explains it best, IMO: http://silktide.com/the-stupid-cookie-law-is-dead-at-last/

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Hey Wimg,

of course the VAT stuff only applies to VAT registered companies - I kind of presumed that ;-) (Hey IPB Team, thats yet another missing feature! There are non VAT companies out there...).

Please remember that if your company is not VAT registered there are still deliverey and buy limits within the EU member states.

Please see http://www.hk24.de/recht_und_steuern/steuerrecht/umsatzsteuer_mehrwertsteuer/umsatzsteuer_mehrwertsteuer_international/367108/Lieferschwellen.html for more information (in german though, but the limits are kind of universal^^)

As soon as you start doing business within the EU member states you'll loose the right to choose as you need an european VAT id for invoming invoices from foreign countries.

If we start with invoices/transactions we open another delicate topic concerning EU billing laws. Currently the so called 'invoices' can actually result in hefty fines because they lack the proper required features. But that's another topic alltogether.

 

 

​:D

You could have a non-VAT company buying and selling to another EU-country. Not great for the company itself, which will always have to pay VAT, and I am sure the companies one sells to would not be happy either - they would always have to pay VAT too buying from a non-VAT company, as the non-VAT company still has to charge VAT and pay the local Tax office the VAT due :), and they can;t get a refund anymore. Gets really expensive rather quickly for those involved :).

Kind regards, Wim

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It's worth mentioning that nobody has ever been prosecuted or fined for not following this law, which has changed so many times most people just don't bother.

Even ICO, the organisation that "enforces" the law doesn't require you to explicitly accept cookies on their own website; they simply have a box that basically says that they use cookies and if you use their site then they presume storing cookies is okay.

This page explains it best, IMO: http://silktide.com/the-stupid-cookie-law-is-dead-at-last/

​No, it isn't dead at all - that is the state in 2013, and even that isn't correct.

Currently, certainly over here, it depends on what you do with these cookies. If it is purely for making it easier for visitors to navigate, or for website functionality, all you need to do is ask whether your visitor accepts cookies or not.

The moment it is about using personal information in some way or another, it still becomes a very tricky business. You can only use it without too many problems if it is anonymized info, and you have to be able to prove it.

If you do use it in other ways, further steps have to be taken to protect the identity and personal info of visitors.

Some changes to the law were made with effect from March this year, over here in the Netherlands, and the above is a summary of the effects on this law.

Kind regards, Wim

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well I only noticed a lot of site show some box "we use cookies, deal with it or leave" if you hit the site (anywhere, not just the start page).

I understand the legal situation is not clear. But why not add that feature to better be safe than sorry? There have been cases where sites received a "dissuasion" (don't know if it's the correct english word for "Abmahnung"). That time something will be required will come and websites will miss that moment.

And to be honest: nothing requested here sounds overly time consuming? It's not like one requested: "do a cookie-less version of the suite" or something.

 

If I bought a car in the US it would be clear to me that I have to make sure it complies to european laws. But only this topic make me think. I though IPS was some company on england :tongue: - honestly what country is "Invision Power Services, Inc., PO Box 2365, Forest, VA 24551"? If you sell cars directly to europe: there better be a handbrake in it...

US. Ah I see. Now you need to add a warning into the client center so when I download the suite I get a warning to not use it unmodified in the EU? Sounds like the same amount of work? ;)

 

Currently this topic leaves me with a weird feeling that I don't know if it is legal to use IP.Board in its default setup in the EU. I don't like that state of insecurity. When it comes to legal issues I would argue trying is better than ignoring. Even if it's only to argument with a judge (I think that's what a lot of german websites do at the moment).

 

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@ossipetz -- we don't want to assume responsibility for what you may or may not do with your site. It's really as simple as that. To you, it may naturally seem like something is better than nothing. From a business standpoint, I'd rather not try and instead ensure you're not led on with a false sense of security that you're in compliance and then be held liable when it turns out you're not. Remember, the law (which has changed ... 5 times now?) purportedly has different requirements for different uses for your site. Out of the box, the software may likely fall under the "functionally necessary" category and some argue you don't need to do anything at all. The second you install a plugin or even enable ads, the requirements could change and you're no longer in compliance. 

I'm not aware of a single software manufacturer/developer that builds in EU cookie compliance. Wordpress, XF, vB, Drupal, etc. all leave it to the third party community. From a development and liability standpoint, that's the smart and appropriate thing to do. 

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