RU EN
www.
Technical audit · 13.04.2026

evea.ee

Estonian Association of SMEs
EE

Estonia's SME association. 197 requests, 2 domains. Google Analytics is wired into the code and initiates requests on every page load — but status 0, no data actually goes out. The privacy policy doesn't mention Google.

Request timeline

+1324 ms · on load
www.googletagmanager.com/gtag/js?id=G-BL74ZJ1E86 — status 0. The request is initiated, but no data is transmitted.
+10161 ms, +23154 ms, +30868 ms
Repeat requests to GTM — all status 0. Four requests total per session, all blocked.
Consent banner
The beautiful-and-responsive-cookie-consent plugin is installed and loads. Zero Set-Cookie responses per session.

Declared versus actual

✓ Website developer, IT support, marketing service provider — a general formulation — declared
✓ Maksekeskus AS — the payment processor — declared
✓ Transfer outside the EU only where a legal basis exists — declared
+ Google Analytics (G-BL74ZJ1E86) — wired into the code, not mentioned in the policy — not declared

Transfer timings

+1324 ms www.googletagmanager.com

GTM G-BL74ZJ1E86 — status 0, no data goes out

+10161 ms www.googletagmanager.com

A repeat request — status 0

+23154 ms www.googletagmanager.com

A repeat request — status 0

+30868 ms www.googletagmanager.com

A repeat request — status 0

Detected trackers

Indicators of GDPR non-compliance

Context

EVEA — Eesti Väike ja Keskmiste Ettevõtjate Assotsiatsioon — is a nonprofit association of small and medium-sized businesses in Estonia. The site runs on WordPress with WooCommerce — meaning it processes member data, event registrations, and possibly payments. 197 requests per session, 2 domains.

What the HAR shows

External traffic is minimal: the entire site runs on the proprietary domain evea.ee, with the only external domain being www.googletagmanager.com. Zero Set-Cookie responses across the entire session.

Google Analytics (G-BL74ZJ1E86) is wired into the code via the google-analytics-for-wordpress plugin and initiates requests to googletagmanager.com on every page load — 4 times per session, at intervals of +1324 ms, +10161 ms, +23154 ms, +30868 ms. All four requests return status 0: the request is initiated by the browser, but no data is transmitted. The blocking is likely caused by the cookie banner (the beautiful-and-responsive-cookie-consent plugin) intervening before data transfer.

Declaration versus fact

EVEA’s privacy policy is written in Estonian and describes processing of member data: collecting names, contact details, event registrations. Mentioned: the site’s developer and IT support (a general formulation), Maksekeskus AS as the payment processor, and transfer outside the EU only where a legal basis exists.

Google Analytics is mentioned nowhere — neither as a data recipient nor as an analytics tool. Yet it is wired into the site’s code and initiates requests on every visit. The policy declares that data transfer outside the EU occurs only with a legal basis and appropriate safeguards — but no transfer mechanism to the USA is stated for Google.

Worth noting separately: the policy references the outdated Privacy Shield mechanism as one basis for transferring data outside the EU. Privacy Shield was invalidated by the Schrems II ruling back in July 2020. The current mechanism is the EU-US Data Privacy Framework, adopted in 2023.

Conclusion

Against the series, evea.ee looks relatively clean: one external domain, GTM blocked, no data actually leaving. But Google Analytics is wired into the code and not declared in the policy — a gap between reality and the document. Additionally, the policy references a Privacy Shield mechanism that’s been invalid since 2020. Both points need fixing.

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/evea-ee-2026-04-13.har
SHA-256: e7088a08c70ab4da45ef740717eacb5f7f3ec8fcbb17acfe9e4a4ecd0381956a
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) — evea.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 evea.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) Google Analytics (G-BL74ZJ1E86) is wired into the code and initiates requests to googletagmanager.com, yet it is not mentioned in the privacy policy as a data recipient.

2) The policy declares transfer of data outside the EU only where a legal basis exists, yet no transfer mechanism to the USA is stated for Google.


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-evea-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 — evea.ee

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

2. Circumstances
I visited the website evea.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) Google Analytics (G-BL74ZJ1E86) is wired into the code and initiates requests to googletagmanager.com, yet it is not mentioned in the privacy policy as a data recipient.

2) The policy declares transfer of data outside the EU only where a legal basis exists, yet no transfer mechanism to the USA is stated for Google.

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

3. GDPR provisions I ask you to examine
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]