ekel.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.

Timeline of the leak

+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.

+5296 ms

GA4 collect — data goes to Google, USA.

Indicators of GDPR non-compliance

GDPR Art. 7

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

GDPR Art. 6(1), Art. 5(1)(a)

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.

GDPR Art. 13

There is no dedicated privacy policy for site visitors.

Additionally

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.

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

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.

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.

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 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. Provisions violated
GDPR Art. 7; GDPR Art. 6(1), Art. 5(1)(a); GDPR Art. 13; Additionally

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]