> How Adally handles accessibility preferences, cookies and data under GDPR, ePrivacy and the European Accessibility Act. Legal basis, transfers and DPIA notes.
>
> Canonical: https://www.flowconsent.com/en/services/cms/adally

CMS

# Adally

Unclassified · [Official website](https://adally.com)

Accessibility platform that adds a customisable widget to a website, lets visitors adjust contrast, font size, navigation and animations, and helps merchants document their WCAG conformance under the European Accessibility Act.

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At a glance

- Category

  [CMS](https://www.flowconsent.com/en/services/cms)

- Consent

  Unclassified

- Prior consent

  Required

- Documented cookies

  3

- Third-party domains

  3

- Servers

  United States (primary)

Overview

## What does Adally do?

## **What Adally is**

Adally is an accessibility platform that loads a customisable widget on a website. Visitors can adjust contrast, font size, animations, link highlighting, reading masks, text to speech and keyboard navigation. The platform also performs automated WCAG scans and generates accessibility statements that merchants need to comply with the European Accessibility Act and national equivalents.

## **Data and cookies**

Adally stores accessibility preferences (e.g. contrast on, large fonts, reading guide) in a first party cookie so they persist between visits. It logs anonymised usage counters (button clicks, profile selections) for product analytics. The compliance dashboard stores account data for the merchant.

## **GDPR and ePrivacy implications**

Loading the widget itself is generally lawful under Article 6(1)(f) GDPR (legitimate interest in providing an accessible service, reinforced by the European Accessibility Act). The preference cookie can rely on the user request exemption under Article 5(3) ePrivacy because it is set only after the user opens the widget. Aggregated usage signals can use legitimate interest provided they remain anonymous.

## **Consent and sensitive data**

Using accessibility features can indirectly reveal a disability, which is a special category under Article 9 GDPR. Avoid linking accessibility preferences to identified user profiles, do not export them to advertising platforms and do not use them for segmentation. If you absolutely need to keep accessibility data with identified users, rely on explicit consent.

## **Data transfers**

Adally is operated from the United States. Transfers rely on Standard Contractual Clauses and the EU US Data Privacy Framework via the Adally DPA. Document the transfer impact assessment and prefer an EU CDN endpoint if Adally offers one.

## **Practical compliance steps**

Sign the DPA, configure the widget to load without third party advertising, only set the preference cookie after the user activates the widget, document the legitimate interest balancing test, expose the choice of profile in your accessibility statement, and avoid combining accessibility usage with marketing or behavioural analytics.

Compliance

## Adally and the GDPR

Adally is classified as “Unclassified”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.

- Legal basis

  Article 6(1)(f) GDPR (legitimate interest in providing an accessible website to all users). Cookies storing accessibility preferences fall under Article 5(3) of the ePrivacy Directive: necessary preference cookies set after a user opens the widget can rely on the user request exemption, persistent profiling cookies require consent.

- Risk level

  medium

- Applicable regulations

  GDPR, ePrivacy Directive, European Accessibility Act 2025, WCAG 2.1 AA, German TTDSG, French CNIL guidelines, Spanish LOPDGDD

### Impact assessment (DPIA)

A DPIA is not normally needed for the accessibility widget itself. It becomes useful when usage data reveals special category information such as disability, especially if combined with logged in customer profiles or behavioural analytics.

### Sample text for your banner

> We use Adally (Adally Inc., United States) to offer accessibility features such as contrast, font size and reading aids. Your preferences are stored in a strictly necessary cookie set after you open the widget. The accessibility widget itself loads without tracking advertising data.

Cookies and trackers

## What Adally sets and contacts

- Tracking method

  JavaScript accessibility widget loaded on the page, first party preference cookies, optional aggregated usage analytics

- Server location

  United States (primary)

- Data transferred outside the EU

  Adally is operated from the United States. Preference selections, IP addresses and page metadata are transmitted to the US backend. Transfers rely on Standard Contractual Clauses and the EU US Data Privacy Framework.

### Cookies set (3)

| Name            | Type | Duration | Purpose                                                                                              |
| --------------- | ---- | -------- | ---------------------------------------------------------------------------------------------------- |
| adally\_prefs   | http | 1 year   | Stores the accessibility preferences chosen by the visitor (contrast, font size, reading aids).      |
| adally\_profile | http | 1 year   | Stores the accessibility profile (e.g. cognitive, motor, vision) selected from the widget shortcuts. |
| adally\_session | http | Session  | Session identifier used by the widget while it is open.                                              |

### Third-party domains contacted (3)

- `adally.com`
- `cdn.adally.com`
- `widget.adally.com`

Questions

## Frequently asked questions about Adally

Can't find your question? Write to us, we answer fast.

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### Which cookies does Adally set?

Adally sets first party cookies for accessibility preferences (adally\_prefs), the selected profile (adally\_profile) and a session cookie (adally\_session). No advertising cookie is set.

### Is user consent required?

The widget itself can usually load under legitimate interest. The preference cookies can rely on the user request exemption because they are set only after the user opens the widget. If any optional behavioural analytics module is enabled, it must be gated by consent.

### What is the legal basis?

Article 6(1)(f) GDPR (legitimate interest, reinforced by the European Accessibility Act). If accessibility preferences are linked to identified user profiles, Article 9 may apply and explicit consent is needed.

### Does Adally transfer data outside the EU?

Yes, the platform is operated from the United States. Transfers rely on Standard Contractual Clauses and the EU US Data Privacy Framework. Document the transfer impact assessment in your DPA records.

### Do I need a DPIA?

Normally no. A DPIA is recommended when accessibility usage is linked to identified profiles, when it is exported into a CRM or when it is combined with behavioural analytics that could reveal disability.

### How do I implement Adally compliantly?

Sign the DPA, load the widget without third party advertising calls, set preference cookies only after the user interacts with the widget, mention Adally in your privacy notice and accessibility statement, avoid linking preferences to identified users.

### What are the alternatives?

Other accessibility platforms include accessiBe, UserWay, EqualWeb, AudioEye, Recite Me, Inclusive Reader and Silktide. Some EU based vendors such as Recite Me offer EU hosting and reduced transfer complexity.

### How do I update the cookie policy?

List Adally as a processor under the accessibility category, describe the strictly necessary preference cookies, link to its privacy policy, and refresh the entry whenever you enable an optional analytics module or change the integration.

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