On 14 April 2026, France’s data protection authority (CNIL) issued a recommendation on the use of tracking pixels in emails. Here is what it means for you, and how the 360 system helps you comply before 14 July 2026.
What a tracking pixel is
A tracking pixel is a tiny, invisible image embedded in an email. When the recipient opens the message and images load, a request is sent, revealing that the email was opened and returning certain technical information. The same principle applies to link-click tracking.
What the recommendation says
For most marketing purposes — measuring open rates to optimise campaigns, personalisation, profiling — using these pixels now requires the recipient’s prior consent, exactly as for cookies. This framework applies to both B2C and B2B.
Two narrow exemptions remain: mechanisms linked to security, and individual deliverability measurement used solely to identify and remove inactive contacts, for emails requested by the recipient. As soon as the data is used to segment or personalise, consent is required.
Who is responsible?
This is a key point: the data controller is the organisation that decides to send — that is, you. Your emailing platform is your technical processor. Compliance therefore cannot be fully delegated to the tool: the duty to inform and to collect consent is yours.
The deadline: 14 July 2026
For existing databases, the CNIL grants three months from 14 April to clearly inform recipients and allow them to object. After that date, checks may be carried out under Article 82 of the French Data Protection Act.
How the 360 system supports you
We have enhanced the 360 system with four settings: one-click deactivation of open tracking, one-click deactivation of click tracking, email unsubscribe, and a global preference centre where your recipients manage all their choices from a single page. We also provide a ready-to-customise email template, available directly from your campaign manager, that you can send to your consumers to inform them and open their right to object.
You can therefore choose your approach: switch off tracking, or inform your database and deploy the objection mechanism before the deadline.
This article concerns customers on the 360 range.
