Who Owns Your Customer List?
Your Instagram followers belong to Instagram. Ad audiences belong to Google and Meta, and they run on their rules. The only audience that is truly yours is the list you build yourself: the emails and phone numbers of customers who said yes. With one condition. That the yes was given properly.
What changed with Consent Mode v2
Since March 2024, Google has required anyone who advertises to or measures visitors in the European Economic Area to send it the user's answer to the consent banner. Two signals were added to the existing ones: ad_user_data, whether the user agrees to their data being sent to Google for advertising, and ad_personalization, whether they agree to personalised advertising.
If these are not sent, Google itself says that Analytics audiences linked to Google Ads will only include users outside the EEA. For a Greek business, that means remarketing lists that are almost empty, and measurement that loses pieces without you noticing.
Basic or advanced
Consent Mode can be set up in two ways. In basic mode, Google tags do not load until the visitor answers. If they decline, nothing is sent. In advanced mode, tags load with consent denied by default and, until consent is given, send only cookieless signals. Google uses them to estimate missing conversions, with a model specific to your account. Which one suits you is not only a technical decision. Discuss it with whoever helps you with personal data matters.
The list you build yourself
For promotional email and SMS, Greek Law 3471/2006 (Article 11) requires prior explicit consent. There is one exception: if you obtained a customer's email lawfully during a purchase, you may contact them about similar products or services, as long as every message clearly lets them say no more.
Proper consent matters for advertising too. Since March 2024, for a customer list to be used in Google Customer Match for audiences in the EEA, both consents must have been granted. A list collected without them is no use there either.
A hypothetical example
A hair salon keeps customers' phone numbers in a notebook and sends promotional SMS to everyone. Nobody knows who agreed, or when. The fix is not complicated. The online booking form gets a separate, unticked box: “I want to hear about offers”. Every message includes a way to unsubscribe, and every consent is recorded with a date and source. Within a year the salon has a list it can use with peace of mind. The example is illustrative, not a real business.
A half-hour check
1. Open your website in a private window. Does a consent banner appear before analytics and pixels load? Does it offer a way to decline?
2. Ask whoever set up your tracking whether ad_user_data and ad_personalization are being sent, and whether Consent Mode is basic or advanced.
3. On your website forms, is newsletter sign-up a separate box that is not pre-ticked?
4. Does every email and SMS you send include a simple way to unsubscribe?
5. Do you keep a record of when and where each person gave consent?
6. Is your whole list your own? Bought lists have no place here.
Where to start
A properly collected list is the most stable part of your marketing: it does not depend on algorithms or on cost per click. At Promoters we start with the basics, banner, Consent Mode and forms, before discussing newsletters or campaigns. If you would like to go through them together, book a free 60-minute online consultation. This article provides general information and is not legal advice.
Sources: Google Analytics Help, Verify and update consent settings · Google Ads Help, About consent mode · Google Ads Help, Customer Match consent (EEA) · Hellenic Data Protection Authority, leaflet on unsolicited communications (spam) · Photo: Lindsay Cash / Unsplash