[tingletech]

Then they probably need that "we use cookies" banner, and will fall under the Data Protection Act.

"The Data Protection Act does not define fair processing. But it does say that, unless a relevant exemption applies, personal data will be processed fairly only if certain information is given to the individual or individuals concerned. It is clear that the law gives organisations some discretion in how they provide fair processing information – ranging from actively communicating it to making it readily available."

https://ico.org.uk/for-organisations/guide-to-data-protectio...