By business type

Cookie Policy Generator for fintech

Written for KYC, open banking, automated decisions and the regulator that reads your terms.

Generate your cookie policy Read the cookie policy guide

Fintech cookie policies have to separate three categories that look alike and are not: fraud and device-fingerprinting signals collected for security, ordinary analytics, and advertising. The first is usually defensible without consent; the other two are not, and conflating them undermines all three.

Fintech privacy documentation sits under two regimes at once: data protection, and financial services regulation that imposes its own record-keeping, disclosure and fair-treatment duties. The two pull in opposite directions - anti-money-laundering law requires retention that data minimisation would otherwise forbid - and the policy has to explain both without appearing to contradict itself.

Automated decision-making is the clause that matters most. Credit decisions, fraud scoring, risk-based pricing and account restrictions frequently meet the Article 22 threshold, which entitles the individual to information about the logic, human intervention and a route to challenge.

Open banking adds a third layer. Where you access account data through an aggregator, the consent architecture is regulated separately, consent expires on a defined cycle, and the customer’s relationship with the aggregator has to be explained rather than hidden behind your own brand.

What a cookie policy for a fintech or financial services business has to cover

Device fingerprinting and fraud-prevention signals, and the basis relied on for them
Session and authentication cookies as genuinely strictly necessary
Analytics and advertising tags, separated from security tooling
Any tracker present inside an authenticated account area
How refusing consent affects onboarding, and what security signals still run

How a fintech or financial services business actually moves personal data

KYC and identity verification

Identity documents, selfies, liveness checks and sanctions screening, usually through a specialist vendor that becomes a significant sub-processor.

Credit and affordability data

Bureau searches, which leave a footprint on the individual’s file, and affordability models that constitute automated decisions.

Transaction monitoring

Continuous screening for fraud and money laundering, generating alerts and suspicious activity reports with their own confidentiality rules.

Open banking account access

Aggregated account and transaction data accessed with time-limited regulated consent.

Biometric authentication

Face or fingerprint matching for onboarding or login, which is special category data under GDPR when used to identify a person uniquely.

Regulatory reporting

Data disclosed to regulators and reporting bodies under legal obligation, which the policy should acknowledge.

Third parties the draft will ask you about

Onfido or Persona · ComplyAdvantage · Experian, Equifax or TransUnion · Plaid or TrueLayer · Stripe or Modulr · AWS · Featurespace or Sift

The rules that apply

Anti-money-laundering retention

Identity and transaction records must be retained for statutory periods - commonly five years after the relationship ends - which is a legal obligation basis, not a choice.

GDPR Article 22

Automated decisions with legal or similarly significant effects require disclosure of the logic, human intervention and a challenge route.

Open banking consent

Regulated consent flows with defined durations and re-authentication, plus a distinct relationship with the account information provider.

Financial promotions and fair treatment

Marketing is separately regulated, with rules on clarity, risk warnings and target-market appropriateness.

Operational resilience and outsourcing

Regulators expect due diligence and exit plans for critical third parties, which overlaps heavily with processor governance.

What the generated cookie policy contains

What the technologies actually are
Cookies, local storage, session storage, pixels, SDKs and server-side tags - the law covers storage and access on a device, not the word "cookie".
A per-cookie table
Name, provider, purpose, category and duration for each cookie, which is the format UK and EU regulators expect to see.
Category definitions
Strictly necessary, functional, analytics and advertising, with an honest explanation of why only the first runs without consent.
How consent was obtained and how to change it
The banner, the granular choices, and a permanent link to reopen preferences - the withdrawal route has to be as easy as the acceptance route.
Third-party cookies and onward use
Which providers set cookies through your site and what they do with the data once it is theirs.
Browser and device controls
Practical instructions, plus a note that blocking strictly necessary cookies will break parts of the service.

Fintech compliance essentials

Map every automated decision
And write the Article 22 disclosure, the human review route and the challenge process.
Document AML retention as a legal obligation
With the period and the statute, so erasure refusals are explicable.
Identify the Article 9 condition for biometrics
Before onboarding goes live.
Explain the open banking chain
Who the aggregator is, what they access, how long consent lasts and how it is revoked.
Word the AML section carefully
Enough transparency to be lawful, without breaching tipping-off restrictions.
Align outsourcing due diligence with processor governance
The regulator and the data protection authority want overlapping evidence.

Where this usually goes wrong

No Article 22 disclosure for credit or fraud decisions

Automated decisioning is the norm in fintech and the disclosure is routinely missing.

Deleting data an AML obligation requires you to keep

Erasure requests do not override statutory retention, and the policy should explain why.

Biometric onboarding treated as ordinary processing

Unique identification via biometrics is special category data and needs an Article 9 condition.

Open banking consent presented as your own

The aggregator relationship and the regulated consent duration have to be explained.

Suspicious activity handling described in the policy

Tipping-off rules constrain what you may tell a customer, which means the policy has to be carefully worded rather than fully transparent.

Marketing to customers acquired through regulated flows

Financial promotion rules apply on top of consent, and the two are frequently conflated.

Frequently asked questions

Can a customer ask me to delete their KYC records?

They can ask, and you will usually have to refuse. Anti-money-laundering law requires retention for a statutory period, which is a legal obligation basis that overrides erasure - but the refusal has to be explained.

Does automated credit scoring trigger Article 22?

Where the decision is solely automated and has legal or similarly significant effects, yes. That entitles the individual to meaningful information about the logic, human intervention and a route to contest the outcome.

Is facial recognition for onboarding special category data?

Where it uniquely identifies a person, yes - biometric data processed for identification requires an Article 9 condition, typically explicit consent in a consumer context.

How should I describe open banking access?

Name the account information service provider, explain what is accessed, state the consent duration and re-authentication cycle, and explain how access is revoked.

Do I need a cookie policy as well as a privacy policy?

In the UK and EU, yes in practice. PECR and the ePrivacy Directive regulate storing and reading information on a device separately from GDPR’s rules on processing, and the per-cookie disclosure is too detailed to bury in a privacy policy.

Do analytics cookies need consent?

In the UK and EU, yes - the ICO has said repeatedly that analytics is not "strictly necessary". Some EU regulators allow a narrow exemption for first-party, non-shared audience measurement, but the default answer is consent first.

Does a cookie policy need updating when I add a tool?

Yes, and this is the clause that goes stale fastest. Every new tag, pixel or embedded widget adds cookies your table does not list. Scanning your own site on a schedule is the only reliable way to keep it honest.

What about cookies set by embedded video and maps?

They count. An embedded YouTube player or Google Map sets third-party cookies as soon as it loads, so either it loads only after consent, or you use a privacy-preserving embed mode and say so.