Even with tracking you merely need a privacy policy in a place users can find. It's considered implied consent to continue using a site if the site makes a reasonable effort to make you aware that such a policy exists.
However, what counts as reasonable hasn't been explicitly defined. The UK government considers it fine to use a header that automatically disappears after awhile (i.e. no need to click "ok"). But other governments may view it differently so I can understand some large organisations being cautious.