Sample Cookies Policy Template

Last updated on 23 October 2021 by Sara Pegarella (Law school graduate, B.A. in English/Writing. In-house writer)

Sample Cookies Policy Template

Cookies are small text files that websites place on the computers and mobile devices of people who visit those websites.

A Cookies Policy is the policy used to inform users about the use of cookies by a website or an app.

These files are then read by the website each time you return to the site. These text files allow a website to remember your device and how you interacted with the website, which is useful for a number of different purposes.

For example, cookies can be used to remember username and password information so that you don't have to re-enter all of your login information every time you visit a site you frequently log in to.

Other functions of cookies are to provide custom advertising to users based on searches and personal interests, as well as site performance cookies that enhance website use by remembering things such as custom video streaming or volume settings you have selected while using the website in the past.

If you use cookies, you should consider having a Cookies Policy. In fact, you may be legally required to have one.

This article will discuss Cookies Policy requirements, best practices, and provide you with a template to create your own policy.


What's a Cookies Policy

A Cookies Policy is a policy that provides users with detailed information about the types of cookies a website uses, how these cookies are used, and how users can control cookies placement through limiting or forbidding a website to place cookies on his/her electronic device.

A Privacy Policy will often include a section within it that covers Cookies. However, in the EU, having a fully separate Cookies Policy is required.

In this case, any information about cookies can also be placed in the Privacy Policy but then referenced in the separate Cookies Policy.

Download our free Cookies Policy template here.

Requirements in the EU

Flag of EU

Any EU business that uses cookies must comply with the EU Cookies Law, which requires a Cookie Policy to be in place. Visitors to your website must be alerted that cookies are in use, what kind of cookies are in use, and given the option to opt out of having these cookies placed on their devices.

A Cookie Policy is where this information can be thoroughly detailed and explained to your visitors.

While pop-up boxes and banner notifications alert users that cookies are being used and can allow for an option to opt out within that box or banner, this kind of policy is where further information can be detailed and accessible to your visitors at any time.

The EU's GDPR requires that you get consent to use most cookies, and having a cookie notification is the perfect way to do this.

Requirements in the U.S.

US Flag

U.S.-based companies that do business targeted to EU nations must comply with EU cookies laws. However, most U.S.-based, U.S.-targeted businesses do not need to comply.

In the U.S., the Federal Trade Commission (FTC) enforces privacy and data security laws and regulations, but cookies are not explicitly separated from general privacy laws as they are in the EU.

It is common with U.S.-based businesses to see just one general Privacy Policy that contains a section within it that deals with the use of cookies.

This differs from EU-based businesses/websites that have both a Privacy Policy and a separate Cookies Policy.

Note below how the EU-based BBC website has a link to its Privacy Policy page and its separate Cookies Policy page in the footer of its website:

BBC website footer with Privacy Policy and Cookies Policy links highlighted

While both policies of the BBC are closely connected and within the same general informational section of the website, they are kept clearly separate:

BBC Policies: Privacy and Cookie separated

To really see the difference between EU and U.S. requirements, consider Amazon.

Amazon's U.S. website has a link to a Privacy Notice page in its footer, while Amazon's UK website has a link to a Privacy Notice as well as a separate Cookies Notice link.

This is the U.S. version of Amazon:

Amazon US website footer with Privacy Notice highlighted

This is the UK version of Amazon:

Amazon UK website footer with Privacy and Cookies notices links highlighted

The U.S.-based Amazon website has the information about cookies located within its Privacy Notice. For U.S. laws, that's good enough:

Amazon Privacy Notice Table of contents with Cookies section highlighted

What to Include in Your Cookies Policy

All Cookies Policies will include the same basic information:

  • That cookies are in use on your website
  • What cookies are
  • What kind of cookies are in use (by you and/or third parties)
  • How and why you (and/or third parties) are using the cookies
  • How a user can opt out of having cookies placed on a device

Let's look at some examples of Cookies Policy clauses that address the above information.

You Use Cookies, and What Cookies Are

Most Cookies Policies start by letting users know that cookies are in use, and telling them what cookies are. Simple, easy-to-understand language should be used here so that everyone is able to understand what the policy is saying.

Below is an example of the introduction from The Guardian's Cookies Policy. Note how it starts with a short, simple definition of what cookies are:

The Guardian Cookie Policy: What is a Cookie clause highlighted

NTT Data includes a similar clause, but adds in some informational links for users to visit if they wish to learn more:

NTT Data Cookie Policy: What are Cookies clause

What Types of Cookies are Being Used

This section will let users know what cookies you may place, and what the function of each is, in general. This is helpful to users as it allows them to pick and choose which cookies to allow or disallow depending on what they feel comfortable with after being informed.

Here's how the Guardian informs users about each different type of cookie that is used, and how they may be used:

The Guardian Cookie Policy: What types of cookies do we use clause

Pearson uses a dropdown menu format within its Cookie Policy, where users can click on each of the cookie types for more detailed information:

Pearson Cookie Policy: Types of Cookies Used menu

How Cookies are Used

After users know what cookies you use, let them know how you use them. While this may often be combined with the previous clause, some companies opt to separate it.

In other words, the previous clause would note the types of cookies that may be used, and include a general definition of what that cookie is, and then the business would include another clause that describes specifically how the business uses or may use cookies.

Amazon's Cookies Notice lets users know some of the purposes for using cookies on the website, which is generally helpful and informative:

Amazon Cookie Notice: How we use cookies clause excerpt

How Users Can Opt Out of Cookies Use

When it comes to disabling or turning off cookies, you must provide information on how to do this to your users, whether the information is specific to your website, or general.

NTT Data informs users that they can set preferences regarding cookies by clicking a link on the bottom of every page of the website. Instructions are also given for how to manually delete cookies at any time:

NTT Data Cookie Policy: How to refuse or withdraw consent for cookies clause

Pearson includes a separate webpage with information about "How to Manage Cookies." Here, users can check to see what cookies are enabled on their computers and adjust them as desired:

Pearson How to manage cookies intro

Immediate Media might make it the easiest for its users to opt out or change cookie settings by providing a link within the Cookies Policy to directly where the cookie preferences can be changed:

Immediate Media Cookie Policy: Change Cookie preferences link highlighted

How to Notify Users About Your Cookies Use and Policy

The EU Cookie Directive requires that users be informed that cookies are being used and that there's a Cookie Policy in existence that they can access.

Websites based in the EU have taken a number of different approaches to notify users of cookies and their Cookie Policies.

While you should always include a link to your policy in your website footer, you'll need to do more than just that.

Here are a few of the most convenient and effective methods for providing this notice.


Top banner pop-ups

These pop-up banners are hard for a user to miss.

They pop up the first time a user visits a website, and are right in the main line of sight. These banners are a great way to quickly inform a user that cookies are in use on your website, provide a link to your Cookie Policy, and request consent to place cookies by including something such as a clickable "Continue" link, or language that lets a user know that by continuing to use the website, consent will be assumed.

Here's an example of a notice that could be used as a top pop-up banner notice, from Costa Coffee:

Costa Coffee Cookie Banner

General pop-up messages

Providing a pop-up box anywhere on your website will give adequate notice to users that cookies are in use on your website, so long as the pop-up box is conspicuous and clearly states what the purpose of the message is.

While the Financial Times now uses a top banner pop-up, it used to use a pop-up box, seen below. This is an example of an adequately conspicuous and clearly stated pop-up box message that provides a link to the Cookies Policy where users can find out more about cookies and also links for managing cookies settings or disabling them altogether.

Pop-up message from FT on FT Cookie Policy

Here's another example from the BBC's Good Food website:

BBC Good Food Cookie Consent Notice

When creating and implementing your Cookie Policy to comply with the EU Directive, remember the following points to stay compliant:

  • Make sure that the Cookie Policy is separate from your other policies and/or legal agreements.
  • Make sure that the Cookie Policy is detailed and clear enough and lets users know what cookies are, how and why you use them, and how a user can opt out of or manage cookies.
  • Don't forget to include information about any third-party cookie usage through your website.
  • Make sure the first time users visit your website, they're briefly informed by way of some sort of notification that your website uses cookies, how they can opt out of or manage cookies, and always provide a link to your full Cookie Policy.

Cookies Policy FAQ's

Here is a list of frequently asked questions that you may find useful.

A Cookies Policy is only required by businesses in the EU, or businesses located elsewhere that have a target audience in the EU.

For other businesses, simply addressing cookies in your Privacy Policy will be sufficient.


Download Cookies Policy Template

Use the Cookies Policy Generator to create this legal agreement.

If you're looking for the template, download the Cookies Policy Template as a PDF file or download the Cookies Policy Template as DOCX. It's free.

You can also download this Cookies Policy Template as a Google Document.

This free Generic Cookies Policy Template is available for download and includes these sections:

  • Introduction
  • What are cookies
  • How we use cookies
  • Third-party cookies
  • What are your choices regarding cookies
  • Where can you find more information about cookies

Screenshot of the Generic Cookies Policy Template

Sara Pegarella

Sara Pegarella

Law school graduate, B.A. in English/Writing. In-house writer

This article is not a substitute for professional legal advice. This article does not create an attorney-client relationship, nor is it a solicitation to offer legal advice.