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> It does seem to lead to some strange loopholes though, like requiring an account for access.

That's false.

Requiring an account or even payment for access does not replace or imply consent of any kind, and all rules still apply even if the user is still logged in or paying.

In fact, it's probably more complicated for logged-in users since you have to comply to requirements of data-scrubbing, removing/anonymising logins/emails/passwords from your database upon request, etc.



How could you anonymize an email address for an account? You are going to need it to reset passwords


You have to do it upon request.

Meaning: more code that you have to write and time you have to spend.




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