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Consent Management (CMP)

CCM19

EU-Made Report an error

Panel rating · 6 judges · How to read the stars

Category median

Sovereignty: not determined

0–5 in half steps. 5 means the rubric's top anchor is met on the evidence.

by Papoo Software & Media GmbH · www.ccm19.de

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CCM19: AI-assisted analysis on whats-best.ai CCM19: AI-assisted analysis on whats-best.ai (dark)

Add ?theme=dark to the image address for dark backgrounds. The badge shows the category and the month of the latest evaluation, and EU-Made where that is the product’s provenance. It never shows a score.

CCM19 at a glance

Vendor
Papoo Software & Media GmbH
Headquarters
Not stated on the vendor’s pages as of 1 Nov 2026
Data hosting
Default not stated; pages mention Germany source, captured 29 Oct 2026
Free plan
Yes, per the vendor’s own page source, captured 29 Oct 2026
Starting price
“Starter EUR 7,90 Pro Monat / inkl. 19% USt” (vendor’s words) source, captured 29 Oct 2026
Panel verdict
The AI panel rates CCM19 3.5/5, the mean of 6 judges. CCM19 is a consent management platform from Papoo Software & Media GmbH, offered as a cloud service or a download version. how scores are made
As of
Vendor pages captured 29 Oct 2026 to 1 Nov 2026; evaluated by the panel 30 Oct 2026. all sources

CCM19 alternatives, European ones first →

Read this page as one judge. Each weighs the same scores by what they care about.

The In-House Lawyer

Weighted verdict

In-house counsel at a retailer with shops in Germany, France and Austria, who has read the court decisions on missing reject buttons and the regulators' banner guidance. Wants § 25 TDDDG and the GDPR mapped to concrete settings, equal-weight choices as the default, consent that can be withdrawn as easily as it was given, and records that would hold up if a competitor or a consumer group sued.

Same scores as the panel view — this lens weights them the way this judge cares.

Scored by The In-House Lawyer

Panel median The In-House Lawyer This judge’s scores over the panel median. Each label opens its reasoning below.
Scores per criterion, in stars out of 5
Criterion Panel median The In-House Lawyer
Banner & choice architecture 3.5 of 5 3 of 5
Prior blocking & script control 3 of 5 3 of 5
Scanning & cookie classification 3.5 of 5 3.5 of 5
Consent records & proof 3 of 5 3 of 5
Frameworks, signals & platforms 3.5 of 5 3.5 of 5
European sovereignty 4 of 5 4 of 5
Pricing transparency 3 of 5 3 of 5

Banner & choice architecture

How this is scored

What the visitor is asked and how: a reject option on the first layer with the same prominence as accept, consent by category and by vendor, withdrawal and changed choices as easy as the first consent (a persistent button or link), banner texts and layouts the site owner controls, languages, rules per country or regulation (GDPR, Swiss FADP, US state laws), accessibility of the banner itself, and consent-rate analytics or A/B tests that stay within the rules.

0 — Not a consent banner; the product shows a notice that cannot record a choice, or is a different kind of product.

3 — A banner with accept and a settings layer; whether reject sits on the first layer, how consent is withdrawn and how far the design can be changed are basic or not described.

5 — Accept, reject and settings on the first layer, consent by category, a way for visitors to change or withdraw their choice later, customisable texts, colours and layout, the banner in several languages, and a basic consent-rate statistic.

8 — Choice architecture documented in depth: reject and accept of equal weight stated as a default, consent per vendor or service as well as per category, geolocation rules that show a different banner per country or regulation, the banner stated as accessible (WCAG level named), dozens of languages with automatic detection, and consent-rate analytics or A/B testing with the limits on what may be tested explained.

10 — The choice is designed to stand up to a supervisory authority: templates mapped to named regulator guidance (for example the German DSK, CNIL or EDPB cookie banner report), dark patterns the product prevents listed, every banner version kept with its texts so the choice shown can be reconstructed, and consent-rate figures reported without nudging defaults.

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The In-House Lawyer

The captured pages show reject, information and accept on the first layer — each button individually switchable — consent by cookie group, a documented withdrawal icon, theme and CSS control, WCAG/EN 301 549/BITV accessibility claims with a contrast warning in the theme builder, and consent analytics with A/B tests. I found no stated equal-weight default for the buttons, no consent per vendor, no banner versions kept for reconstruction, and the limits on A/B testing and automatic language detection are not described; the claimed conformity with TDDDG, DSGVO and the 2020 Federal Court of Justice ruling is not mapped to named regulator guidance. 1 2 5 7

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Prior blocking & script control

How this is scored

What happens before the visitor decides: automatic blocking of scripts, pixels, cookies and embedded content until consent is given, content blockers with placeholders for videos, maps and social embeds, integration with tag managers (Google Tag Manager, Matomo Tag Manager) and server-side tagging, consent passed to forms and plugins, and a documented way for the site owner to check that nothing loads too early.

0 — No blocking of any kind; the product only shows a banner and leaves every script running.

3 — Blocking by hand: the site owner changes script tags or tag-manager triggers using the consent state; automatic blocking, embeds and testing are basic or not described.

5 — Automatic blocking of known scripts and cookies before consent, placeholders for embedded videos and maps, a Google Tag Manager template or integration, and the blocking method documented in the help centre.

8 — Blocking described in depth: an auto-blocking mode and a manual mode with their limits explained, content blockers for named services that the vendor maintains, consent passed to forms, CAPTCHAs and plugins through a JavaScript API or events, server-side tagging supported, and instructions to test in the browser or a tag-manager preview that nothing loads before consent.

10 — Prior blocking the site owner can verify: an automated check or monitor that reports scripts and cookies set before consent on the live site, alerts when a new tracker bypasses the banner, blocking covering local storage, fingerprinting and pixels as well as cookies, and the method published so an auditor can follow it.

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The In-House Lawyer

Automatic blocking of more than 210,000 known cookies, automatic deletion of foreign first-party cookies, iframe blocking for YouTube and Google Maps, and a Google Tag Manager template with instructions are documented, and the tool can act as tag manager itself, injecting scripts only after consent. We found no public information on manual blocking modes with their limits, consent passed to forms or CAPTCHAs, server-side tagging, or a documented browser or tag-manager test showing that nothing loads before consent. 1 2 5

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Scanning & cookie classification

How this is scored

How the product knows what the site sets: a scanner that crawls the site for cookies, local storage, pixels and third-party requests, scheduled rescans, a maintained database that classifies cookies and services by purpose, provider and lifetime, alerts on new or changed trackers, and a cookie declaration or policy section that updates itself from the scan.

0 — No scanning and no cookie list; every service is entered and described by the site owner from scratch.

3 — A one-off scan or a list of services the site owner fills in, with some predefined templates; scheduled scans, classification and the declaration are basic or not described.

5 — A scanner that finds cookies and third-party services on the site, regular rescans, automatic classification into categories from a vendor database, and a cookie declaration generated from the result and kept on the site.

8 — Scanning described in depth: scheduled scans with a stated depth or page count, scanning behind logins or in different regions, local storage and pixels as well as cookies, a large maintained database of services with purposes, providers and lifetimes, email alerts on new or changed trackers, and the declaration updated automatically in several languages.

10 — The cookie list stays true without manual work: continuous monitoring of the live site with a change history, unknown trackers flagged for review rather than silently classified, the classification sources and update process published, and scan reports exportable for an audit.

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The In-House Lawyer

An onboarding scan lists and classifies found cookies and scripts, a permanent crawler rechecks the page — including local storage — with scheduled crawls from every eight days down to daily by tariff, backed by a maintained database of over 1,000 providers and a dynamic, self-updating cookie table translated into more and more languages. Email alerts on new or changed trackers, a stated scan depth, scanning behind logins, and unknown trackers flagged for review rather than classified are not described in the captured pages. 1 2 3 5

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Frameworks, signals & platforms

How this is scored

Where the consent goes and where the product runs: the IAB Transparency and Consent Framework (TCF, current version) with a registered CMP ID, Google Consent Mode v2 and Google's CMP certification, Microsoft UET consent mode and other ad-platform signals, the Global Privacy Platform and Global Privacy Control for US laws, plugins and apps for WordPress, Shopify, TYPO3 and other systems, iOS and Android SDKs, connected TV, multi-domain and agency accounts, and an API.

0 — No consent signal is passed on; other tools cannot read the visitor's choice.

3 — Consent readable through a cookie or a JavaScript variable, perhaps one CMS plugin; TCF, Consent Mode, app SDKs and multi-site management are basic or not described.

5 — Google Consent Mode v2 supported with the vendor named as a Google-certified CMP, IAB TCF supported, plugins or integrations for several named CMS and shop systems, a JavaScript API, and several domains manageable from one account.

8 — Signals and platforms described in depth: a registered IAB Europe CMP ID and the current TCF version, Google Consent Mode v2 in basic and advanced mode, Microsoft UET consent mode and other named ad signals, GPP and GPC for US states, iOS and Android SDKs documented, agency or partner accounts managing many client sites, and a REST API for configuration.

10 — One consent across every channel: web, apps and connected TV under one configuration, consent shared across domains and logged-in devices, every signal (TCF, Consent Mode, GPP, ad platforms) documented with its mapping to the banner choices, and configuration exportable or managed as code.

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The In-House Lawyer

The pages state an IAB TCF v2.4 certification and Google CMP certification, Google Consent Mode v2 in basic and advanced mode with the required signals named and a documented guide, WordPress and Shopware support among nearly all CMS and shop systems, a data query and hosting API, and multi-client agency use with white-label. Microsoft UET, GPP and GPC for US states, and iOS or Android SDKs are not described, and only the certification claim is shown, not an IAB registration number. 1 3 4 5

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European sovereignty

How this is scored

Who the contracting entity and the parent company are, where the banner script is served from, where consent logs and scan results are stored, and who the subprocessors are (hosting, CDN, geolocation, scanner infrastructure, app SDK telemetry, email and support). Independently sourced by the sovereignty pipeline; a CMP runs on every page of the customer's site and sees every visitor, so the whole chain counts, not only the database. For a plugin that runs on the customer's own server, the vendor's licence, update and scanner services are the chain.

0 — Non-EU vendor and contracting entity, hosting unstated, subprocessors unnamed, and no data processing agreement offered.

3 — A privacy policy and a data processing agreement exist, but hosting location is unstated or non-EU and the subprocessors are not listed.

5 — EU hosting available and an EU contracting entity or EU representative, but parts of the chain (CDN for the banner script, geolocation, scanner, analytics, support) run through non-EU providers without a stated safeguard.

8 — EU hosting on named infrastructure, EU contracting entity, banner script and consent logs served and stored in the EU, subprocessors listed with their locations, a data processing agreement published, and security certifications (ISO 27001, SOC 2) stated.

10 — Sovereign end to end and evidenced: European ownership, entity, hosting, CDN and every subprocessor, or a self-hosted option that keeps the banner and the logs on the customer's own server; data export and deletion documented, and certifications published with their scope rather than implied.

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The In-House Lawyer

The contracting entity is Papoo Software & Media GmbH in Bonn (HRB 22721), processing is stated to stay within the EU on named German hosts (OVH in Frankfurt, Hetzner in Gunzenhausen) with no US providers, a downloadable DPA with a named data protection officer, subprocessor changes only with notice and an objection right, and return or deletion with proof on request. A self-hosted open-source download version keeps the banner and all data on the customer's own server with no external transfer; however, ISO 27001 appears in the DPA only as an example of accepted audit evidence, and we found no statement that the vendor holds a certification or publishes its scope. 1 2 5 6 8

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Pricing transparency

How this is scored

Whether a buyer can compute the real annual cost from public pages alone: price per domain or site licence, the page-view, session or consent limits of each tier and what happens above them, the free tier's limits, which features (TCF, app SDKs, A/B testing, multi-domain, white label) cost extra, agency or reseller terms, minimum term, and setup.

0 — No public prices at all; every customer is a sales call.

3 — A starting price or a free tier exists, but how cost scales with domains, traffic or features is unclear.

5 — Tiers are public with their price per domain or licence and their main inclusions, but at least one commonly needed piece (traffic overage, extra domains, TCF, app SDKs, agency use) is unpriced or "on request".

8 — Every tier priced publicly with its scaling rule (per domain, per page view or session band, per site licence), overage and extra domains priced, add-ons listed with prices, minimum term and VAT treatment stated.

10 — Complete price computability: annual cost derivable for a given number of domains, traffic and apps, with every add-on, setup, support, overage and agency fee and the cancellation and data-return terms published.

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The In-House Lawyer

Free, Starter at EUR 7,90 and Business at € 19,90 per month including 19% VAT are published with per-tier domain and impression limits (for example 5 domains and 100.000 impressions in Business), a 14-day trial without credit card that closes automatically, and terms of one month or a year cancellable at term end. What happens above the impression limits, and the prices of the TCF module, no-label licences, the installation service, the agency tariff billed per domain per month, and the enterprise tier from 100 domains, are not published on the captured pages. 1 2 5

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European sovereignty — proven facts

0 of 6 dimensions proven

Built only from facts shown on the vendor's own pages. A dimension we could not prove is left open, not scored as zero.

Hosting location Not determined ⚠ unverified — uncited Report an error
Hosting options Not determined ⚠ unverified — uncited Report an error
Open source Not determined — uncited Report an error
Data processing agreement Not determined ⚠ unverified — uncited Report an error
Transfer impact assessment Not determined ⚠ unverified — uncited Report an error

Questions about CCM19

Is CCM19 European?

Yes. whats-best.ai classifies CCM19 as EU-Made.

Where does CCM19 store data?

The default storage location for customer data is not stated on the vendor’s pages as of 1 Nov 2026. The vendor’s pages mention Germany as hosting location, per the vendor’s page captured 29 Oct 2026.

Does CCM19 have a free plan?

Yes. CCM19 has a free plan, per the vendor’s page captured 29 Oct 2026.

What are the best alternatives to CCM19?

As of 3 Nov 2026, the panel rates Usercentrics CMP (3.5/5), Didomi (3.5/5) and Cookie Information (3.5/5) highest among the other 19 Consent Management (CMP) products evaluated. Ratings that look equal are rounded to half stars; the order uses the unrounded rating, then the name. The highest-rated European alternative is Usercentrics CMP (EU-Made). Ratings are the AI panel’s opinion, formed from public evidence: how scores are made. The full list, with European products first: CCM19 alternatives.

Where this could be wrong

What we left out

A claim that does not survive our checks costs us the claim, not the page. This is what was taken off this one.

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Sources (11)

The pages every claim on this page was read from — each one checked, dated, and kept verifiable.

  1. 1 Vendor homepage www.ccm19.de Checked 29 Oct 2026 Details →
  2. 2 Features page www.ccm19.de Checked 29 Oct 2026 Details →
  3. 3 Features page (cookie scanner) www.ccm19.de Checked 29 Oct 2026 Details →
  4. 4 Features page (Google Consent Mode v2) www.ccm19.de Checked 29 Oct 2026 Details →
  5. 5 Pricing page www.ccm19.de Checked 29 Oct 2026 Details →
  6. 6 Legal notice www.ccm19.de Checked 29 Oct 2026 Details →
  7. 7 Privacy policy www.ccm19.de Checked 29 Oct 2026 Details →
  8. 8 Data processing agreement (dpa) www.ccm19.de Checked 29 Oct 2026 Details →
  9. 9 Security / trust page — found from the homepage www.ccm19.de Checked 1 Nov 2026 Details →
  10. 10 Self-hosting / on-premises installation docs — found from the homepage www.ccm19.de Checked 1 Nov 2026 Details →
  11. 11 Code repository (open-source licence) — found from the homepage github.com Checked 1 Nov 2026 Details →