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.
Timeline of the leak
Declared versus actual
Transfer timings
Analytics on the Estonian RIK domain, but before consent
No exact timing
Detected trackers
- Matomo (statistika.rik.ee)
- Cloudflare Insights
- browser-update.org
- Cloudflare CDN (cdnjs)
- unpkg
Indicators of GDPR non-compliance
- GDPR Art. 6(1), Art. 5(1)(a)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.
- GDPR Art. 12, Art. 13The 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.
- GDPR Art. 13(1)(e)The actual recipients (Matomo, Cloudflare Insights, browser-update.org, unpkg, cdnjs) are undeclared — there's nowhere to declare them, as no policy exists.
- GDPR Art. 13(1)(f), Chapter VData transfer to the USA (Cloudflare, browser-update.org, unpkg) with no legal mechanism stated.
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 a violation; 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 a violation. 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.
a3a01fbb95eb6b33d799f3e35fd5dd7ba67d94a54545f945b3a797e165b03f40Where 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 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. Provisions violated 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 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]