Though the e-Privacy Directive was initially implemented in Bulgarian law through the Bulgarian Electronic Communications Act, the amendments to that directive, requiring express consent for the storage of or access to cookies, have not been implemented yet. As a result, local Bulgarian legislation allows the use of cookies provided that the user has been informed of the use of cookies and he/she has been given the opportunity to refuse the storage of or access to such cookies.


Nevertheless, since GDPR in Recital 30 specifically includes the term ‘cookie identifiers’ within the definition of what constitutes personal data and because EU law has priority over national law, in order to be GDPR compliant many Bulgarian businesses decided to request users, in relation to cookies, for their explicit consent that meets GDPR standard.


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