Technical audit · 29.09.2026

mybee.ee

Website of the MyBee long-term car rental service in Estonia

The website of the MyBee long-term car rental service — one page, 393 requests. A Cookiebot banner with a 'Keeldu' button on the first screen, and Google obeys it. The Meta pixel does not: 16 events before any choice and 15 after refusal. In parallel, events go to a server-side Meta Conversions API gateway on Amazon in the US, and the Eskimi advertising platform opens a tracking session in the third second. Neither Meta, nor Eskimi, nor the US gateway is named in the privacy policy.

Request timeline

+0 s · entering the homepage
Redirect http → https. The site's application fetches data from api.mybee.lt.
+2.3…+2.9 s · tags and Eskimi
GTM-KC2GH245, Cookiebot, Google Ads AW-10959715733 (gcs=G100). Eskimi: the script and a tracking session for tracker 36684 with the page address (+2.9 s).
+3.1…+3.4 s · Meta via the browser and via the server
Configuration of pixel 997635436272572, the first event to www.facebook.com/tr, and an event to the server-side Conversions API gateway on AWS us-east-1. Before any choice — 16 pixel events.
+155…+301 s · after refusal
Google switches to a denial updated by the decision. The Meta pixel sends 15 more events, and at +155.3 s an event goes to the Conversions API gateway on AWS.

Declared versus actual

✓ Controller — MyBee Estonia OÜ, Modus Mobility group — declared
✓ Cookiebot banner: 'Keeldu', 'Luba valik', 'Luba kõik'; categories switched off by default — declared
✓ Cookiebot declaration: _fbp (Meta) — marketing; eskimi.com — among the providers — declared
✓ Policy: recipients — UAB CityBee Solutions, UAB Modus Mobility, Twilio Ireland (Sendgrid), and others; transfer to the US — Sendgrid under standard contractual clauses — declared
✓ Supervisory authority — the Andmekaitse Inspektsioon — declared
+ Meta and Eskimi in the privacy policy — not declared
+ The server-side Meta Conversions API gateway on AWS in the US — not declared
+ The Meta pixel and Eskimi run before any choice, and Meta after refusal as well — not declared

Transfer timings

+2.9 s dsp-trk.eskimi.com

Eskimi tracking session, tracker 36684.

+3.4 s www.facebook.com

First Meta pixel event.

+3.4 s d3-…ecs.us-east-1.on.aws

Server-side Meta Conversions API gateway in the US.

+149.1 s consent.cookiebot.com

logconsent, action=decline.

+155.3 s d3-…ecs.us-east-1.on.aws

An event to the Conversions API gateway after refusal.

+300.5 s www.facebook.com

The fifteenth Meta pixel event after refusal.

Detected trackers

Indicators of GDPR non-compliance

Context

mybee.ee is the website of the MyBee long-term car rental service in Estonia. The controller is MyBee Estonia OÜ, part of the Modus Mobility group, which also includes CityBee. The site is a single-page application, with data loaded from the group’s Lithuanian servers api.mybee.lt and images.mybee.lt. Consent is managed by Cookiebot.

The measurement is a single load of the homepage with navigation inside the application. In total, 393 requests. Processing is described by the MyBee Estonia privacy policy and the Cookiebot declaration.

Who receives data directly

Meta — through the pixel in the browser and through a server-side gateway on Amazon Web Services in the US. Eskimi — advertising platform. Google — Analytics and Ads in denied mode, Maps. Sentry — error monitoring.

Declared versus actual

The banner is set up correctly: “Keeldu” on the first screen, categories switched off, and the refusal is recorded. Google complies: before the decision, every request carries a denial, and after refusal, the denial is updated by the visitor’s decision. The discrepancies lie in the rest of the advertising stack.

First — Meta and Eskimi run before any choice. In the third second, Eskimi opens a tracking session with the page address. Next, the Meta pixel sends its first event, and in parallel an event goes to the server-side Meta Conversions API gateway. While the visitor reads the banner, the pixel sends 16 events.

Second — after refusal, Meta carries on, including via the server. The refusal is recorded at +149.1 s. After that, the pixel sends 15 more events, and at +155.3 s an event again goes to the Conversions API gateway. The server-side gateway deserves special mention: it is hosted on Amazon Web Services in the us-east-1 region and transmits Meta events bypassing the browser. The visitor’s blocker cannot see it, and only the site itself can stop it.

Third — the policy says nothing about this. The MyBee policy lists in detail the recipients within the group and the Sendgrid mailing service, with a transfer to the US. Meta, Eskimi, and the server-side gateway in the US are not mentioned. Meta and the Eskimi domain appear only in the technical cookie declaration. The visitor will learn nowhere about the server-side channel to the US.

Proven: Meta, the Conversions API gateway, and Eskimi run before any choice. Eskimi at +2.9 s, the Meta pixel and the gateway at +3.4 s, and 16 pixel events before the decision is recorded.

Proven: a refusal took place. The Cookiebot log records action=decline at +149.1 s.

Proven: the Meta pixel and the gateway run after refusal. 15 pixel events and an event to the gateway at +155.3 s.

Proven: Google respects the denial. Every request carries gcs=G100, and after refusal, a denial updated by the decision.

Not established: the content of the Meta and gateway events. They were sent via POST, and the bodies were removed during cleaning. The gateway was identified by the Meta Conversions API script loaded from capi-automation.s3.us-east-2.amazonaws.com and by the address of the event endpoint.

Boundaries of this observation

The measurement covers the site’s homepage. Registration, the account area, and rental checkout were not examined. The observation records browser behavior, not server-side processing. The file has been published cleaned: Cookie headers and POST request bodies were removed.

Legal assessment falls to the competent authority — the Andmekaitse Inspektsioon.

Conclusion

MyBee has installed an exemplary banner and configured Google correctly, but the Meta pixel and the Eskimi advertising platform do not listen to it. Meta receives events before any choice and after refusal, not only through the browser but also through a server-side gateway in the US that no blocker can stop. Neither Meta, nor Eskimi, nor this gateway is named in the privacy policy.

Remedy: bring the Meta pixel, the Conversions API gateway, and Eskimi under Cookiebot — do not load them or send events without consent to marketing, and stop sending after refusal, including on the server side; name Meta, Eskimi, and the server-side gateway in the policy, stating the transfer to the US and its legal basis.

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/mybee-ee-2026-09-29.har
SHA-256: 6b769c21256975e69a9b712ff9a1f3d0705b6ece82e57902a4ceed865bed53c7
Screenshot
Скриншот интерфейса
The Cookiebot banner on the homepage: 'Keeldu', 'Luba valik', 'Luba kõik'; categories switched off · 29.09.2026
Скриншот интерфейса
The 'Üksikasjad' tab: 'Turundus' — 8 cookies, switched off by default · 29.09.2026
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.