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Privacy

Brazil's LGPD (Lei Geral de Proteção de Dados, Law No. 13,709/2018) never mentions cookies, but it applies to any cookie, pixel or script that collects personal data from site visitors. As the ANPD (Brazil's data protection authority) reads it, cookies needed for the site to work can rely on legitimate interest, while advertising and cross-site tracking require consent. The guides below show what the banner needs to do, what pixels collect and what the privacy policy should say.

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Brazil's LGPD for websites: cookies, consent and third-party scripts

What Brazil's LGPD and the ANPD guide require of a site with cookies, analytics and pixels: legal bases, banner, cookie policy and a checklist.

Complete guide · 16 min read

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Frequently asked questions

Does every site need a cookie banner?
Only when the site uses cookies or scripts that are not necessary for it to work and that depend on consent, such as advertising and cross-site tracking. Strictly necessary cookies can rely on legitimate interest, according to the ANPD cookie guide.
Does the reject button need to be as visible as the accept button?
Yes. As the ANPD guide reads it, consent has to be free, and the person needs to be able to refuse as easily as they accept. Non-necessary cookies stay off until they choose.
Does an ad pixel count as collecting personal data?
In general, yes. Pixels such as Meta's and Google's send the vendor browser identifiers and browsing data that the LGPD treats as personal data when they make it possible to identify someone, even indirectly.
Does the privacy policy replace the banner?
No. The policy explains how the site processes data as a whole. The banner is where the person makes a choice about the cookies that depend on consent. Both are needed when the site uses that kind of cookie.

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