I’ll take it as a yes? You still need notice and consent even when using email-based identifiers.
The age of email-based identifiers is nigh. But are these cookie replacements actually as transparent about consent as promised? Digiday’s Kate Kaye says maybe not.
“Because many identity technologies, including Unified ID 2.0, use email addresses and other information gathered when people interact directly with a brand or publisher to build encrypted IDs, the companies that make and use them suggest they are created with people’s knowledge and consent”.
“Although these companies are modernizing their means of tracking people online, they have yet to update their methods of notifying them when these systems capture individuals’ email addresses to transform them into identifiers that can be passed throughout the ad tech ecosystem.”
“So basically, the age-old problem continues its aged oldness: Consumers have no idea how their data is being used. For instance, some publishers aren’t specifically notifying people that their personal info will be used to power an identifier that will be shunted into an ad marketplace.”