Skip to Main Content
D&D Portfolio Ideas Portal
Status New
Workspace PROG - Consumer
Created by Edie Kuo
Created on Oct 6, 2025

EMEA Consent Manager Enhancement

Background

Deckers EMEA is strengthening its Consent Management approach to ensure marketing practices are effective, compliant, and scalable under GDPR/PECR.

  • Historically, first-party consumer data has been used for retargeting and lookalike audiences (LALs) on Meta/Google without explicit consent wording.

  • Current cookie banners (via Osano) do not differentiate between on-site personalization and off-site advertising.

  • Cordial → Meta sync is one-way add-only: new subscribers are added, but unsubscribers or converted customers remain in audiences unless refreshed.

Legal guidance:

  • Lookalike audiences → no risk, as we use opted-in customer data to find new users with similar traits. Already allowed today.

    • Limitation: seed audiences only add new users, no auto-removal (operational inefficiency).

  • Retargeting → higher risk, requires explicit consent wording in cookie banner before activation. (Currently paused until compliant.)

Note on Lookalikes: LALs do not retarget known customers; instead, they expand reach by modeling new audiences. This is legally safe but requires clean seed lists for effectiveness.

Business analysis:

The use of first-party data (1PD) lists in paid media (e.g., Customer Match) primarily improves efficiency by lowering CPCs and increasing conversion rates.

  • These efficiency gains allow marketing teams to reinvest savings into additional traffic acquisition.

  • Jellyfish (our media agency) advises a more conservative expectation of +3% to +8% uplift based on real campaign performance.

  • Applied to HOKA EMEA Paid Search (Mar 2024 – Jan 2025):

→ Incremental revenue potential = $1.3M – $3.4M.

Inaccessible revenue opportunity until compliant 1PD activation (retargeting & improved Lookalike hygiene) is enabled.

Problem Statement

  • Deckers EMEA cannot currently activate first-party data for retargeting in paid media without breaching GDPR/PECR.

  • Revenue opportunity blocked: $1.3M–$3.4M uplift (per brand) is not yet accessible.

  • Operational inefficiency: manual suppression/audience hygiene needed due to one-way sync.

  • Reputational risk: unclear consent flows reduce transparency and consumer trust.


Opportunity / Data Case

Google benchmarks show Customer Match yields:

  1. 3.6% reduction in CPCs → more clicks at same spend.

  2. +20% conversions per dollar.

  3. +5.3% overall conversion uplift.

While Google benchmarks suggest a +24% uplift, Jellyfish (our media agency) advises a more conservative expectation of +3% to +8% uplift based on real campaign performance.

Applied to HOKA EMEA Paid Search (Mar 24–Jan 25):

  • $1.3M – $3.4M incremental revenue potential.

  • UGG estimates the same.


Objectives

  1. Make consent explicit → Update Osano banner with off-site targeting wording.

  2. Automate consent flow → Feed Osano → Cordial → Meta/Google in near real time.

  3. Preference granularity → Split digital-wallet service vs. marketing pushes.

  4. Audience hygiene → Share refreshed audiences to update records in segments, mitigating the current one-way add-only sync until two-way sync is supported (instead of manual suppression).

  5. Unlock compliant growth → Enable Lookalike now, prepare retargeting at scale once consent signals are flowing.

Scope

In scope

  • Cookie banner update (legal-approved off-site wording).

  • Osano SDK/API event listener integration.

  • Cordial schema update to store consent flags (w/ timestamp + version).

  • Universal opt-out protocol across ESP + ad platforms.

  • SOP for hygiene & suppression.

Deliverables

  • Updated cookie banner language.

  • Consent schema & opt-out protocol.

  • SDK/event listener integration docs.

  • Audience hygiene SOP.

  • Business case + legal approval pack.

Business Benefits

  • Compliance & risk reduction: Reduce GDPR/PECR exposure.

  • Consumer trust: Transparent opt-ins build credibility.

  • Marketing efficiency: Automate audience sync, cut manual errors.

  • Revenue growth: $1.3M – $3.4M incremental revenue per brand potential by enabling compliant retargeting.

  • Future readiness: Framework for scalable 1P audience activation.

Region EMEA
  • Attach files