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Technical audit · 13.04.2026

epa.ee

Estonian Patent Office
EE

A state body protecting citizens' and businesses' intellectual property. Trackers on the site work reliably — Matomo, Cloudflare, browser-update.org. Meanwhile the site has no cookie policy at all: in its place, a single line linking to another agency.

Request timeline

+230 ms · before consent
Matomo (statistika.rik.ee) — analytics on an Estonian domain (a plus), but loads before consent. In parallel, Cloudflare Insights and browser-update.org initiate requests on every page.
Policy / banner
There is no cookie policy — only a line linking to the Ministry of Justice's website. There is no way to find out what epa.ee itself collects.
Per session
unpkg.com — 4 requests on the contacts page (status 200, USA). cdnjs.cloudflare.com — 8 requests (Bootstrap, mapping libraries, USA).

Declared versus actual

+ Matomo — statistika.rik.ee, before consent — not declared
+ Cloudflare Insights, browser-update.org — the same signature seen at aki.ee — not declared
+ unpkg.com, cdnjs.cloudflare.com — CDNs in the USA — not declared

Transfer timings

+230 ms statistika.rik.ee (Matomo)

Analytics on the Estonian RIK domain, but before consent

No exact timing

on every page static.cloudflareinsights.comBlocked by the browser, but the request was initiated. IP address to Cloudflare (USA)
on every page browser-update.orgA third-party American service. The request went out
per session cdnjs.cloudflare.com8 requests, Bootstrap and libraries. Data to the USA

Detected trackers

Indicators of GDPR non-compliance

Context

Patendiamet is Estonia’s Patent Office. A state body: it registers patents, trademarks, and industrial designs, and is legally responsible for protecting citizens’ and businesses’ intellectual property. HAR: 145 requests per session, 6 pages.

Familiar traces

On every page load, the following fire: Matomo (statistika.rik.ee, +230 ms) — analytics on an Estonian domain, itself a plus, but loading before consent remains an indicator of non-compliance; Cloudflare Insights and browser-update.org — an attempt on every page, blocked by the browser in response, but the request had already been initiated and the user’s IP address reached servers in the USA; unpkg.com (4 requests on the contacts page) and cdnjs.cloudflare.com (8 requests) — CDNs in the USA. All of this before any interaction with the site.

Not the first time

Two services — Cloudflare Insights and browser-update.org — were previously recorded on AKI’s site, Estonia’s Data Protection Inspectorate. The same domains, the same timings, the same signature. This isn’t a coincidence, but a pattern: likely a single CMS, a single contractor, or a single template replicated across Estonian government sites with no GDPR compliance check.

No policy at all

epa.ee has no cookie or tracker policy. In its place is a single line linking to the Ministry of Justice’s website. Users cannot find out what data this site collects, who the processor is, on what basis, or where it is transmitted. Meanwhile, the trackers work reliably. For comparison: koda.ee at least had a policy — it just hadn’t been updated in 8 years, which is itself an indicator of non-compliance. epa.ee has no site-specific policy whatsoever — a different level altogether.

Conclusion

A body that is legally responsible for protecting intellectual property and registering rights runs trackers on its own site with no consent, and publishes no information about what is transmitted where. The absence of a policy doesn’t make the processing more transparent — it makes it invisible. The same template, with the same trackers, is spreading across government sites, and as long as no one checks them for compliance, it will keep spreading.

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/epa-ee-2026-04-13.har
SHA-256: a3a01fbb95eb6b33d799f3e35fd5dd7ba67d94a54545f945b3a797e165b03f40
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) — epa.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 epa.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) Matomo (+230 ms), Cloudflare Insights, browser-update.org, unpkg.com, and cdnjs.cloudflare.com fire before any consent — some are blocked by the browser, but the requests have already been initiated.

2) The site has no cookie or tracker policy. In its place is a single line linking to the Ministry of Justice's website. Users cannot find out what data is collected, who the processor is, or on what basis.

3) The actual recipients (Matomo, Cloudflare Insights, browser-update.org, unpkg, cdnjs) are undeclared — there's nowhere to declare them, as no policy exists.

4) Data transfer to the USA (Cloudflare, browser-update.org, unpkg) with no legal mechanism stated.


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-epa-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 — epa.ee

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

2. Circumstances
I visited the website epa.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 13 April 2026 (open methodology, reproducible measurements) documents the following indications:

1) Matomo (+230 ms), Cloudflare Insights, browser-update.org, unpkg.com, and cdnjs.cloudflare.com fire before any consent — some are blocked by the browser, but the requests have already been initiated.

2) The site has no cookie or tracker policy. In its place is a single line linking to the Ministry of Justice's website. Users cannot find out what data is collected, who the processor is, or on what basis.

3) The actual recipients (Matomo, Cloudflare Insights, browser-update.org, unpkg, cdnjs) are undeclared — there's nowhere to declare them, as no policy exists.

4) Data transfer to the USA (Cloudflare, browser-update.org, unpkg) with no legal mechanism stated.

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

3. GDPR provisions I ask you to examine
GDPR Art. 6(1), Art. 5(1)(a); GDPR Art. 12, Art. 13; GDPR Art. 13(1)(e); GDPR Art. 13(1)(f), Chapter V

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]