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Technical audit · 06.06.2026

ekel.ee

Estonian Union of Construction Consultancy and Design Firms
EE

A union of construction firms — 20 requests, 4 domains. Google Analytics UA loads at +85 ms and sends a pageview — even though UA has been officially discontinued since July 2024. No banner, no policy.

Request timeline

+85 ms · on load
Google Analytics UA (analytics.js) — a discontinued service, retired in July 2024. Data to Google, USA.
+112 ms · on load
UA pageview collect — visit data goes out. With no consent.
+174 ms · on load
GA4 (G-2S9JR4QFXD) — loads in parallel. Both GA properties run simultaneously.
Consent banner
Completely absent.
+5296 ms
GA4 collect — data goes to Google, USA.

Declared versus actual

+ Google Analytics UA — not declared
+ Google Analytics GA4 (G-2S9JR4QFXD) — not declared

Transfer timings

+85 ms www.google-analytics.com

UA analytics.js — service discontinued July 2024

+112 ms www.google-analytics.com

UA pageview collect

+174 ms www.googletagmanager.com

GA4 G-2S9JR4QFXD

+5296 ms region1.google-analytics.com

GA4 collect

Detected trackers

Indicators of GDPR non-compliance

Context

MTÜ EKEL is the Estonian Union of Construction Consultancy and Design Firms. An informational site: sector news, a member list, a training calendar. HAR: 20 requests, 4 domains — one of the smallest in this series. No marketing, no advertising infrastructure of any kind.

UA after retirement

Google Analytics Universal Analytics officially stopped processing data on July 1, 2024. ekel.ee still loads analytics.js and sends a UA pageview collect at +112 ms. Google accepts these requests — technically, the service responds with status 200. But data is no longer being recorded to the UA property: Google stopped processing it almost two years ago.

This means the site sends visitor data to Google with no consent — for analytics that no longer works. GA4 (G-2S9JR4QFXD) runs in parallel, correctly transmitting data — but likewise with no consent.

A parallel with e-kaubanduseliit.ee

The same picture as at the Estonian E-Commerce Association: an industry organization, an informational site, GTM/GA with no banner, no policy for visitors. Both unions run their sites as internal corporate pages — not as public services processing visitor data.

Conclusion

20 requests — the most minimalist site in this series after europark.ee. But minimalism doesn’t mean compliance: UA loads even though the service has been retired, GA4 runs with no consent, there’s no banner, no policy. Two lines of code would fix this — add a CMP, and remove the dead UA script.

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: ee/ekel-ee-2026-06-06.har
SHA-256: b5a4d67b6af804020f2ca6dacde7df94d5a50d4b7c26d237cbe45c1adf20446d
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) — ekel.ee

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 ekel.ee.

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) There is no consent banner whatsoever. Zero consent requests across the entire session.

2) Google Analytics UA (+85 ms) and a pageview collect (+112 ms) go to Google immediately on load. A GA4 collect fires at +5296 ms. Both with no consent of any kind.

3) There is no dedicated privacy policy for site visitors.

4) Google Analytics UA (Universal Analytics) officially stopped operating in July 2024. ekel.ee still loads analytics.js and sends a UA pageview — data going to a discontinued service that Google officially retired almost two years ago.


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/ee-ekel-ee/

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: Estonian Data Protection Inspectorate (AKI) — write to info@aki.ee

Important: AKI only handles submissions in Estonian. Translate the letter before sending.

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 — ekel.ee

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

2. Circumstances
I visited the website ekel.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) There is no consent banner whatsoever. Zero consent requests across the entire session.

2) Google Analytics UA (+85 ms) and a pageview collect (+112 ms) go to Google immediately on load. A GA4 collect fires at +5296 ms. Both with no consent of any kind.

3) There is no dedicated privacy policy for site visitors.

4) Google Analytics UA (Universal Analytics) officially stopped operating in July 2024. ekel.ee still loads analytics.js and sends a UA pageview — data going to a discontinued service that Google officially retired almost two years ago.

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

3. GDPR provisions I ask you to examine
GDPR Art. 7; GDPR Art. 6(1), Art. 5(1)(a); GDPR Art. 13; Additionally

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]