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The scanner-first Termly alternative

Termly writes your US-style policies and runs your banner. CookieSentry proves what fires before consent under EU ePrivacy and writes the national-law documents to match.

Termly is a US company (founded in 2017, based in Spokane, Washington) that built a popular all-in-one SaaS for small and mid-sized businesses: a suite of policy generators, a consent management platform with a cookie banner, and an automated cookie scanner, all from one subscription. It is a certified Google CMP Partner and supports IAB TCF 2.3 and Google Consent Mode v2, which makes it a genuinely capable consent tool for an SMB that wants legal documents and a banner in one place. The design center, though, is US-first: the model leans on CCPA-style notice-and-opt-out thinking and a generic global-privacy baseline. CookieSentry is built for the other side of the Atlantic. It does one job well for EU sites: it loads your live URL like a real visitor and records every cookie and tracker that fires before consent, names the source, and then generates GDPR documents mapped to the national rules that actually apply (Germany's section 25 TDDDG, plus Poland, Denmark, Sweden and pan-EU ePrivacy). CookieSentry is not a consent banner and not a CMP. The banner is Termly's job; proving the banner actually holds back trackers, and documenting it for an EU regulator, is ours.

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€150M

CNIL fine on Shein (Sept 2025) for cookies placed before consent and ineffective refusal

CNIL, 1 September 2025

€325M

Same-day CNIL fine on Google for invalid cookie consent at account creation

CNIL, 1 September 2025

Opt-in

ePrivacy Art. 5(3) requires prior consent before non-essential cookies, unlike CCPA opt-out

ePrivacy Directive 2002/58/EC, Art. 5(3)

27

EU member states transpose ePrivacy differently, so one generic policy rarely fits all

ePrivacy Directive, national transposition

Independent proof of pre-consent firing, not a self-report

Termly's scanner inventories cookies so it can build a banner around them. CookieSentry runs an adversarial pre-consent test: it visits your live URL as a fresh visitor, takes no consent action, and records every cookie and tracker that fires anyway, naming the source. That is exactly the failure the CNIL fined Shein €150M for in September 2025: cookies placed before consent. A separate audit layer that proves your banner actually holds back trackers is evidence a regulator and your own counsel can read, independent of the tool that set the banner up.

EU national-law documents, not a US-first generic baseline

Termly's generators are excellent at CCPA, US state laws and a generic GDPR baseline. CookieSentry generates GDPR documents mapped to the specific national overlays that apply to your traffic: Germany's section 25 TDDDG, Poland, Denmark, Sweden and pan-EU ePrivacy. Because the 27 member states transposed ePrivacy differently, a single global template often leaves national gaps. CookieSentry targets those gaps deliberately.

A free public scan and shareable evidence, no signup

Anyone can run CookieSentry's free public scan on any URL with no account. The result is an indexable report plus a downloadable PDF you can hand to a privacy team, an agency or outside counsel as standing evidence, with a public compliance badge for the sites that pass. That evidence trail is something a documents-and-banner suite is not built to produce.

A US-first generator meets EU prior-consent law

Termly grew up solving a US problem well: give a small business the documents and notices it needs to look compliant without spending thousands on lawyers. That heritage shows in the model. CCPA and most US state laws follow a notice-and-opt-out logic: tell people what you collect, give them a way to opt out of sale or sharing. The EU works the other way. ePrivacy Article 5(3) requires prior, opt-in consent before any non-essential cookie or tracker touches the user's device. Notice after the fact is not enough; the tracker must not fire until the user agrees.

That gap is not academic. On 1 September 2025 the CNIL fined Shein €150M and Google €325M on the same day, both for cookie failures rooted in consent that came too late or was not valid. A US-style generator can produce a beautiful cookie policy and a working banner, and you can still be non-compliant if scripts fire before the user clicks accept. The document describes the intended state; it does not prove the actual state.

CookieSentry exists to close that distance. It does not write a policy and assume the banner works. It measures what your live page actually does before consent, then generates documents that reflect the national rule that applies, so the paperwork and the behaviour line up.

A policy is not proof of what fires

Termly bundles three things: generated documents, a cookie scanner, and a banner. The scanner's job inside that bundle is to feed the banner, categorising cookies so the consent UI knows what to gate. That is useful, but it is the same vendor checking its own work, and it inventories cookies rather than proving the order of events. The compliance question an EU regulator asks is narrower and harder: at the moment a fresh visitor lands and does nothing, what already fired?

CookieSentry answers only that question, and answers it independently. It loads the URL with no consent given and captures every cookie and tracker that appears anyway, names the third party behind each one, and writes it into a report and a PDF. If your Termly banner is configured correctly, the report confirms it and you have evidence. If a tag manager or an embedded script is leaking before consent, the report catches it before a DPA does. Keeping the auditor separate from the banner vendor is the point.

Keep your banner, add the evidence and the right documents

Switching to CookieSentry does not mean ripping out your consent setup. CookieSentry has no banner to install and never will, so there is no consent script to swap. If you run Termly's banner, keep it; if you run your own, keep that. CookieSentry sits alongside as the layer that proves what fires before consent and generates and maintains your GDPR documents against the national overlays that apply to your EU traffic.

Where teams do consolidate is the audit half. If you adopted Termly partly for its cookie scanner and policy output, CookieSentry can take over that role with EU-specific depth: a real pre-consent test instead of an inventory, and documents tuned to section 25 TDDDG, Poland, Denmark, Sweden and pan-EU ePrivacy rather than a global template. Pricing is flat and predictable and does not scale by the number of subpages, so the cost of running the audit layer does not climb as your site grows.

Consent is not validly constituted if the storage of information, or access to information already stored in a website user's terminal equipment, is permitted by way of a pre-checked checkbox which that user must deselect to refuse his or her consent.

— Court of Justice of the EU, Planet49 (C-673/17), 2019

CookieSentry vs Termly

CapabilityCookieSentryTermly
Automatic pre-consent cookie scanningTermly scans and categorises cookies to build its banner; CookieSentry runs an independent pre-consent firing test.
Free public scan (no signup)Termly offers free generators and a free tier; CookieSentry's full scan runs with no account.
GDPR document generationBoth generate documents; Termly is US-first and broad, CookieSentry is EU national-law focused.
Exportable audit evidence (PDF)CookieSentry produces a shareable report plus a downloadable PDF as standing evidence.
National-law overlays (TDDDG, PL, DK, SE)Termly covers GDPR/ePrivacy generically and CCPA; CookieSentry maps to specific national rules.
Consent banner / CMPTermly is a certified Google CMP Partner with a full banner; CookieSentry has no banner.
IAB TCF supportTermly supports IAB TCF 2.3 and Google Consent Mode v2; CookieSentry is not a CMP.
Flat pricing (not per-subpage)CookieSentry pricing does not scale by subpage count.Tiered SaaS subscription

The compliance reality

Opt-in, not opt-out

ePrivacy Article 5(3) requires prior consent before non-essential cookies are stored or read. US CCPA logic is notice-plus-opt-out. A generator built around the US model can miss the EU requirement that nothing fires until the user agrees.

Shein, €150M, for firing first

On 1 September 2025 the CNIL fined Shein €150M for placing cookies before consent and for an ineffective refusal mechanism. The lesson is precise: a banner that exists is not the same as a banner that holds trackers back, which is what CookieSentry measures.

Pre-ticked boxes settled in 2019

In Planet49 (C-673/17) the CJEU ruled that consent collected via a pre-ticked box is not valid consent. EU consent must be active and prior. Documents and banners must reflect that standard, and an audit should verify the page actually does.

When Termly is the better pick

Termly is a strong choice if you are a small or mid-sized business, especially one with a US or global footprint, that wants documents and a consent banner from a single affordable subscription. Its banner is a real consent management platform: it is a certified Google CMP Partner and supports IAB TCF 2.3 and Google Consent Mode v2, which CookieSentry does not offer at all. If your priority is getting a working, Google-compatible consent banner live quickly and generating a stack of standard policies (privacy policy, terms, cookie policy, disclaimers) without paying legal fees, Termly does that well and is hard to beat on convenience. CookieSentry does not replace that banner and does not try to. Use Termly (or any CMP you trust) for the consent UI; the question this page answers is whether Termly's US-first generator and self-reported scan are enough to prove EU prior-consent compliance, and to produce documents that survive a German or French regulator, on their own.

Pricing

Termly is a tiered SaaS subscription pitched at SMBs, bundling documents, a banner and a scanner. CookieSentry prices the audit and documents layer flat and predictably: the cost does not climb with the number of subpages you scan, so a large site is not penalised for being thorough. The two are not substitutes on price because they are not the same product; CookieSentry sits next to whatever CMP you already pay for, including Termly's.

Switching from Termly

You do not swap your consent banner for CookieSentry, because CookieSentry has no banner. Keep Termly's CMP, or your own, running as the consent UI. Add CookieSentry as the independent layer that proves what fires before consent on your live pages and generates GDPR documents mapped to the national rules for your EU traffic (section 25 TDDDG, Poland, Denmark, Sweden, pan-EU ePrivacy). If you used Termly mainly for its cookie scanner and policy output, CookieSentry can replace that half with EU-specific depth while your banner stays exactly where it is.

Frequently asked questions

Does CookieSentry replace Termly's cookie banner?

No. CookieSentry is not a consent banner or a CMP and never displays one. Keep Termly's banner, which is a certified Google CMP Partner solution with IAB TCF 2.3 support, or keep your own. CookieSentry adds the audit and documents layer alongside it.

If Termly already scans my cookies, why add CookieSentry?

Termly scans to categorise cookies for its banner: the same vendor checking its own setup. CookieSentry runs an independent pre-consent test, loading your live URL as a fresh visitor and recording every tracker that fires before any consent, which is the specific failure regulators like the CNIL fine for.

How is CookieSentry better for EU compliance specifically?

Termly is US-first and strong on CCPA and a generic GDPR baseline. CookieSentry maps documents and checks to the national overlays that actually apply to EU traffic, including Germany's section 25 TDDDG, Poland, Denmark, Sweden and pan-EU ePrivacy, where one global template often leaves gaps.

Can I show the results to a regulator or my lawyer?

Yes. CookieSentry produces a shareable, indexable report and a downloadable PDF you can hand to a privacy team, an agency or outside counsel as standing evidence of what fired before consent, plus a public compliance badge for sites that pass.

Compare CookieSentry with other tools

Weighing more than one option? See how CookieSentry stacks up against the other consent tools on the market.

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See what fires on your site before you switch

Run a free CookieSentry scan on your live pages, catch early-firing cookies, and export evidence your privacy team or agency can act on — no signup required.

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Comparison last reviewed 2026-06-14. Termly is a trademark of its respective owner; competitor details are described in good faith and may change over time.

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