6.2.5 Use of Tracking Pixels in Emails

The Italian Data Protection Authority's (Garante per la Privacy) ruling of 17 April 2026 establishes the rules for using tracking pixels in email communications, with the aim of protecting recipients' privacy.

What are tracking pixels?

Tracking pixels are small, invisible elements embedded in emails that make it possible to detect whether a message has been opened and, in some cases, how many times it has been opened and when. This information can be used, for example, to analyse the results of email marketing campaigns and understand which communications generate the most interest.

What rules must be followed?

To use tracking pixels correctly, it is necessary to:

Inform the recipient: clearly explain that emails may contain tracking tools and specify the purposes for which they are used.
Obtain consent when required: individual tracking of email opens, for example in promotional campaigns, generally requires obtaining the recipient's prior consent.
Allow consent to be withdrawn: users must be able to change their preferences and withdraw their consent easily.
Protect personal data: collect only the information that is necessary and implement measures to reduce the risk of identifying the recipient.

Certain exceptions are provided for, such as aggregated and adequately anonymised statistics, specific security requirements, and certain strictly necessary technical functions. Whether these exceptions apply must be assessed on a case-by-case basis.

What is the objective of the regulation?

The objective is to enable companies to use email analytics tools while respecting privacy, ensuring that recipients have transparency and control over their personal data.

Note: Responsibility for the proper management of consent, privacy notices, and system configuration must be verified by the party using the software, with support from their privacy officer or consultant where necessary.

What does the software user need to do?

Anyone using the software to send emails must verify that tracking features are configured in compliance with the applicable legislation. In particular, before enabling email open tracking, it is necessary to verify that the recipient has been properly informed and that consent has been obtained where required. Simply possessing the recipient's email address does not automatically authorise the monitoring of their activities.

vtenext Lead, Organisation and Contact Records

In vtenext records, there is a field called "Newsletter Tracking Consent". This field is set to No by default. This means that when a new Lead, Organisation or Contact record is created, this field will not be enabled. The CRM user is responsible for updating this field based on the consent provided verbally or in writing by their existing or prospective customer.

Display of the Newsletter Tracking Consent field in the Lead module

In the statistics for a Newsletter, when the Tracking Consent field is set to No, aggregated data can be viewed for Emails Opened and Links Clicked.

As shown in the screenshot below, a row labelled "Anonymous" appears in the "Recipient Name" column. The "Number of Opens" and "Number of Clicks" columns display values (e.g. 2 or 4) that may relate to a single contact or to multiple contacts, as the data is aggregated.

Statistics screen showing anonymous opens and clicks

Unsubscriptions and Tracking

Finally, a new value called Tracking has been added to the Unsubscriptions section of the statistics. This screen displays the number of clicks on the unsubscribe link associated with pixel tracking.

Pixel tracking unsubscription statistics screen

Finally, clicking the unsubscribe link in the Newsletter opens the standard unsubscribe page, which now includes an additional link for disabling tracking, allowing users to manage this preference separately from the other features.