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Technical audit · 26.05.2026

willhaben.at

Austria's Largest Classifieds Marketplace
AT

Austria's largest marketplace — 168 requests, 9 external domains. A CMP is present, so is a policy. But the advertising machine fires before consent: Permutive, Xandr, and Microsoft Advertising are already active 2–3 seconds after load. Among them, an undeclared pa-cd.com.

Request timeline

+1887 ms · CMP starts loading
sdk.privacy-center.org begins loading CMP components. The banner has not yet been shown.
+2114 ms · first tracker
njnccxc.pa-cd.com receives the first POST with idclient. An undeclared service, no consent.
+2601 ms · audience analytics
api.permutive.com returns audience segments. Permutive builds a visitor profile before any user choice.
+2900 ms · Microsoft advertising
adsdk.microsoft.com loads the advertising SDK. Followed by adsdk.bing.net and adsdkprod.azureedge.net.
+3128 ms · Xandr
ib.adnxs-simple.com and ams3-ib.adnxs-simple.com (Xandr/AppNexus) — ad placement requests. 9 requests to Xandr per session in total.
Session total
Of 168 requests, 33 go to external advertising and analytics services. Not one waited for consent.

Declared versus actual

✓ Permutive — mentioned indirectly in the analytics section — declared
✓ Microsoft Advertising — mentioned as an advertising partner — declared
+ pa-cd.com — POST with a client identifier, absent from the policy — not declared

Transfer timings

+2114 ms njnccxc.pa-cd.com

POST with idclient=mpmyuubwyz89p1vb. 5 requests per session. Not mentioned in the privacy policy.

+2601 ms api.permutive.com

Audience segmentation before consent. 4 requests per session.

+2900 ms adsdk.microsoft.com / adsdk.bing.net

Microsoft's advertising SDK. 7 requests per session.

+3128 ms ib.adnxs-simple.com / ams3-ib.adnxs-simple.com

Xandr (AppNexus) — an ad auction. 9 requests per session.

Detected trackers

Indicators of GDPR non-compliance

Context

willhaben.at is Austria’s largest classifieds platform (real estate, cars, jobs, marketplace), part of Styria Media Group. HAR: 168 requests, 9 external domains.

A CMP is present, but the advertising doesn’t wait

The Privacy Center CMP is integrated and starts loading at 1887 ms. But the advertising infrastructure doesn’t wait for it to finish: pa-cd.com fires a POST request at +2114 ms, Permutive segments the audience at +2601 ms, Microsoft Advertising loads its SDK at +2900 ms, and Xandr enters the auction at +3128 ms. At this point, the consent banner has not yet been shown even once.

pa-cd.com — undeclared

Among the external services, njnccxc.pa-cd.com stands out — a randomized subdomain sending POST requests with a persistent client identifier (idclient=mpmyuubwyz89p1vb) five times per session. The request body is marked <REDACTED>. This service is not mentioned anywhere in the privacy policy, under this name or any other.

The policy is detailed, but reality doesn’t match

The privacy policy (March 2026) describes legal bases, retention periods, and user and partner rights in detail. Yet there is a gap between what is declared and what happens before consent. A commercial marketplace with an advertising-driven model and a detailed policy, where the advertising trackers outrun the site’s own consent-management tool.

Evidence

How to verify: download the file and compute its checksum — sha256sum file.har (Linux, macOS) or certutil -hashfile file.har SHA256 (Windows); it must match the one shown. The conclusions apply to the scope of this measurement — see the limitations of the method.

Original (audit)
HAR file: willhaben.at.har
SHA-256: e3d318e3c283f11ab5c36105d2820b16ee143848cac7744253bd116760ca6d0f
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.
Want a response from the company about this audit? → Open the tool

Fill in once — it will be inserted into every letter below:

All fields are required to print the document — this is a formal requirement of the letter itself (the particulars of an official submission), not data collection: nothing is sent or saved anywhere, it all stays in your browser and disappears when you close the page. See the methodology for details.

Step 1. Data access request (GDPR Art. 15)

Send this letter directly to the company first — before contacting the regulator it has the right to respond (GDPR Art. 12(3) — 30 days).

Subject: Data access request (GDPR Art. 15) — willhaben.at

To: [insert the company's address — DPO / support / legal department]
From: [Your name], [contact email]

I request access to my personal data processed in connection with the website willhaben.at.

1. Categories of data and purposes of processing (Art. 15(1)(a)-(c))
Based on an independent technical analysis of the site, I request confirmation and detailed disclosure of the following categories of processing:

1) Advertising trackers — Permutive, Xandr, Microsoft Advertising, and pa-cd.com — load before the CMP finishes initializing and before any user action. There is no consent, yet data goes out.

2) pa-cd.com sends POST requests with a client identifier (idclient=mpmyuubwyz89p1vb) 5 times per session. This service is not mentioned in the privacy policy.


2. Recipients, retention periods, and transfers outside the EEA (Art. 15(1)(c)-(d), 46)
I also request the full list of third-party recipients, the applicable retention period for each category, and the legal basis for any transfer of data outside the EEA. The full technical audit with evidence (saved network log, SHA-256 checksum) is published at: https://gdpru.eu/en/audits/at-willhaben-at/

3. Automated processing and profiling (Art. 15(1)(h))
Please state whether I am subject to automated decision-making or profiling, and if so, disclose the logic involved.

Sincerely,

[Your name]
[contact email]
[Country]


[Date]
IMPORTANT: before filing a complaint with the regulator, first contact the company directly and give it 30 days to respond. Without this step the regulator may reject the complaint. Details and a template letter to the company are in the Methodology.
Ready-to-send complaint letter

Where to file: Datenschutzbehörde (DSB) — file a complaint online →

The regulator reviews complaints in its national language. There is an officially translated template from the European Data Protection Board (EDPB) — you can use it instead of or alongside this letter: Official EDPB complaint form (PDF, your language)

Subject: Complaint regarding personal data processing — willhaben.at

1. Subject of the complaint
I am filing a complaint regarding the processing of my personal data by the website willhaben.at.

2. Circumstances
I visited the website willhaben.at and found indications that the processing of my personal data does not comply with the GDPR. The technical analysis published on gdpru.eu on 26 May 2026 (open methodology, reproducible measurements) documents the following indications:

1) Advertising trackers — Permutive, Xandr, Microsoft Advertising, and pa-cd.com — load before the CMP finishes initializing and before any user action. There is no consent, yet data goes out.

2) pa-cd.com sends POST requests with a client identifier (idclient=mpmyuubwyz89p1vb) 5 times per session. This service is not mentioned in the privacy policy.

Full technical documentation is published at: https://gdpru.eu/en/audits/at-willhaben-at/

3. GDPR provisions I ask you to examine
GDPR Art. 6(1)(a), TKG § 165; GDPR Art. 13

4. Request
I request that you examine the circumstances described and, if non-compliance is confirmed, apply the measures provided for in Article 58(2) GDPR.

5. Attachments
The full evidence base — the HAR file, its SHA-256 checksum and the quotation from the site's privacy policy documenting the stated contradiction — is published and verifiable at the link in point 2 above.

Sincerely,

[Your name]
[contact email]
[Country]


[Date]