Bottom Line
Cross-border independent sites targeting overseas users still need to display ICP on the domestic corporate site and provide a privacy policy, Cookie consent, and payment/refund disclosures on-site — this is the "minimum set" for trust and advertising compliance.
Minimum Compliance Stack
| Module | Audience | Key Points |
|---|---|---|
| ICP Filing Number | Domestic visitors, Baidu, some ad reviews | Footer links to MIIT (clickable) |
| Privacy Policy | EU/US users, GDPR, ad platforms | Explain what data is collected, purpose, contact info |
| Cookie Banner | EU/UK traffic | Don't load non-essential analytics before consent (Consent Mode) |
| Terms of Service / Refunds | Payment gateways, consumer trust | Shipping, refunds, dispute handling |
| Contact Information | All channels | Email, WeCom/WeChat, physical address |
GULINGLE website example: footer ICP 粤ICP备2024164256号-2, privacy/terms at /privacy, /terms.
Cookie & GA4 / Ads Relationship
- Without Consent Mode configured, EU users rejecting cookies → no GA4 data, lower Ads conversions
- Correct approach: reject non-essential by default → load GTM after user consent
- Coordinate with step 6 of GA4 0-conversion article
Dual-Site Architecture Recommendation
Domestic site (ICP filed) → brand trust, Baidu, WeChat
↓
Overseas independent site (Shopify/Woo) → Google/Meta ads, cross-border payments
Both sites can share a privacy policy template, but must specify the data controller and governing jurisdiction.
FAQ
Q: Can I run Google Ads without ICP filing? A: Generally yes for overseas campaigns, but domestic showcase sites should be ICP-filed, and Baidu's sitemap quota is tied to the registered entity.
Q: Can I copy a privacy policy template? A: You can start from a template, but you must adapt it to the data you actually collect (forms, analytics, payments) to avoid boilerplate.
Q: Does the domestic site need a Cookie banner too? A: It's mandatory if your main traffic is from the EU/UK; domestic-only sites can simplify, but for any overseas-facing site we recommend enabling it across the board.
Q: Which pages does Stripe require? A: Usually privacy, refund, contact, and service description pages must be publicly accessible.
Q: Does GULINGLE's website build include compliance pages? A: Yes. Standard delivery includes privacy/terms templates, ICP display placement, and Cookie strategy consulting.



