aboutyou.ee
Policy changed — see what exactly · 2026-07-31 →
A German online retailer — the Russian-language version for Estonia. Usercentrics loads correctly and beats most trackers. One exception: the proprietary tracking API t2.aboutyou.com starts at the same time as the banner — before it actually appears.
Timeline of the leak
Declared versus actual
Transfer timings
Tracking lib.js, simultaneous with Usercentrics
Usercentrics loader — starts loading
Usercentrics fully loaded
rive.wasm CDN. USA
A/B testing events. USA
Detected trackers
- Optimizely (logx.optimizely.com)
- unpkg.com CDN (rive.wasm)
- t2.aboutyou.com (tracking API)
Indicators of GDPR non-compliance
- GDPR Art. 6(1), Art. 5(1)(a)t2.aboutyou.com (a tracking API) loads at the same time as Usercentrics, at +129 ms — before the banner has rendered and the user could see it. Optimizely (+3043 ms) activates after Usercentrics has loaded, but its consent mechanism is not evident from the HAR.
- GDPR Art. 13(1)(e), Art. 13(1)(f)Optimizely (USA) and the unpkg.com CDN are not mentioned in the privacy policy as data recipients. No data-transfer mechanism for Optimizely to the USA is stated.
Context
ru.aboutyou.ee is the Russian-language version of the Estonian ABOUT YOU store, a subsidiary of Otto Group (Hamburg). The audit was conducted on the Russian-language version of the site (ru.aboutyou.ee/vash-magazin) — a separate localization for Estonia’s Russian-speaking residents. HAR: 177 requests, 13 domains.
What is done correctly
ABOUT YOU has built an architecture substantially better than most retailers in the series. Usercentrics loads at +129 ms — among the very first requests. The GDPR configuration loads in Russian (/ru/GDPR/). Most trackers activate only after Usercentrics has loaded. Proprietary infrastructure (assets.aboutstatic.com, cdn.aboutstatic.com, tadarida-web.aboutyou.com) — no Google CDN, no Cloudflare for media content. Zero Set-Cookie responses.
t2.aboutyou.com — a borderline case
At +129 ms, both the Usercentrics loader and t2.aboutyou.com/tapi/basic-js/lib.js — ABOUT YOU’s own tracking API — fire simultaneously. Technically they start within the same millisecond, but the Usercentrics banner only rendered and became visible to the user roughly 1.5–2 seconds later. This means ABOUT YOU’s own tracker initialized before the user could physically see the banner and interact with it.
Optimizely and unpkg — undisclosed recipients
Optimizely (logx.optimizely.com, +3043 ms) is the A/B testing platform of the American company Optimizely Inc. It activates after Usercentrics has loaded, which is technically better — but Optimizely is not mentioned as a data recipient in ABOUT YOU’s Estonian privacy policy.
unpkg.com (+2898 ms) is a public npm-package CDN. It loads @rive-app/canvas@2.34.1/rive.wasm — an animation library. The IP address goes to Cloudflare (USA). Using a public CDN instead of self-hosting the library is a lapse against an otherwise fairly careful architecture.
Comparison with Zalando
Both sites use Usercentrics. Zalando loads GTM 1.5 seconds before the banner. ABOUT YOU loads Usercentrics among its very first requests and keeps most trackers behind the consent barrier. Architecturally, ABOUT YOU is closer to a correct implementation — with the caveat of t2.aboutyou.com and Optimizely.
Conclusion
ABOUT YOU demonstrates one of the best approaches to consent among the commercial sites in this series: Usercentrics starts immediately, most trackers sit behind the barrier, and infrastructure is proprietary. Two undisclosed recipients (Optimizely, unpkg.com) and the borderline case with t2.aboutyou.com are points to fix, not a systemic problem.
58ece84f05e319c5e61e99c20a2fdd64cb35cb77d957bdcc849d331d4ef0b328Where to file: Estonian Data Protection Inspectorate (AKI) — write to info@aki.ee
Important: AKI only handles submissions in Estonian. Translate the letter before sending.
To: Estonian Data Protection Inspectorate (AKI) From: [Your name], [contact email] 1. Subject of the complaint I am filing a complaint regarding the processing of my personal data by the website aboutyou.ee. 2. Circumstances I visited the website aboutyou.ee and found indications that the processing of my personal data does not comply with the GDPR. The technical analysis published on gdpru.eu on 6 June 2026 (open methodology, reproducible measurements) documents the following indications: 1) t2.aboutyou.com (a tracking API) loads at the same time as Usercentrics, at +129 ms — before the banner has rendered and the user could see it. Optimizely (+3043 ms) activates after Usercentrics has loaded, but its consent mechanism is not evident from the HAR. 2) Optimizely (USA) and the unpkg.com CDN are not mentioned in the privacy policy as data recipients. No data-transfer mechanism for Optimizely to the USA is stated. Full technical documentation is published at: https://gdpru.eu/en/audits/ee-aboutyou-ee/ 3. Provisions violated GDPR Art. 6(1), Art. 5(1)(a); GDPR Art. 13(1)(e), Art. 13(1)(f) 4. Request I request that you investigate the violations described and 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. [Date] [Signature / name]