Estonia's state postal service. Cookiebot loads at +954 ms, GTM at +1053 ms. A GA collect fires at +1530 ms — before the user has seen the banner. Two GA4 containers: one active, one returning a 404.
Timeline of the leak
Declared versus actual
Transfer timings
Cookiebot starts loading
Turnstile anti-bot. USA
Cloudflare Insights beacon
GTM-NZM7ZWK7
SDK ready, banner visible
GA4 collect. USA
Detected trackers
- Google Tag Manager (GTM-NZM7ZWK7)
- Google Analytics GA4 (G-CSG389Q6FR)
- Cloudflare Insights (static.cloudflareinsights.com)
- Cloudflare Turnstile (challenges.cloudflare.com)
- Cookiebot (consent.cookiebot.com)
Indicators of GDPR non-compliance
- GDPR Art. 6(1), Art. 5(1)(a)Cookiebot (+954 ms) and GTM (+1053 ms) load almost simultaneously. Cloudflare Insights (+965 ms) and Cloudflare Turnstile (+957 ms) fire before the banner has fully loaded. A GA collect fires at +1530 ms — by which point the banner has not yet been shown to the user.
- GDPR Art. 7GTM and GA4 activate before Cookiebot has finished rendering the banner and displaying it to the user. A GA collect at +1530 ms goes to the USA before any interaction with the banner.
- GDPR Art. 13(1)(e)Cloudflare Turnstile (anti-bot protection) is not mentioned in the policy as a data recipient. The policy describes cookies in general categories, with no listing of specific recipients.
- GDPR Art. 13(1)(f), Chapter VGoogle Analytics (G-CSG389Q6FR) — USA. Cloudflare (Insights, Turnstile) — USA. No transfer mechanism is stated.
Context
Omniva is Estonia’s state postal service, AS Eesti Post. It operates a network of parcel lockers across the Baltics, handling packages and letters for millions of customers. The site omnivagroup.com is the group’s corporate portal. The HAR was captured on the cookie usage policy page. HAR: 66 requests, 7 domains.
Load order — 353 milliseconds
Cookiebot begins loading at +954 ms. GTM at +1053 ms. The gap between them is 99 ms. The Cookiebot SDK is fully ready at +1307 ms — only then does the banner physically appear on screen. A GA collect fires at +1530 ms — 223 ms after the banner appears, but before any user interaction with it.
This is a borderline case, similar to zalando.ee and boozt.com: a CMP is present, but the script load order violates the principle of consent before processing.
A dead GA4 container
GTM loads two GA4 containers: G-CSG389Q6FR (active, status 200) and G-L782ZE2F7P (status 404 — nonexistent). The second container is wired into GTM, initiates a request, receives a 404 — and no data goes out. But the very fact that a nonexistent analytics identifier is wired into a production GTM configuration points to an outdated setup.
Cloudflare Turnstile
challenges.cloudflare.com/turnstile is Cloudflare’s replacement for Google reCAPTCHA. Technically more privacy-friendly than reCAPTCHA Enterprise, but it still transmits data to Cloudflare (USA). Not mentioned in Omniva’s privacy policy.
Conclusion
Omniva uses Cookiebot — the right choice. The policy, in Estonian, describes cookie categories. But GTM loads 254 ms before Cookiebot is fully ready, a GA collect fires before any interaction with the banner, a dead GA4 container points to an outdated configuration, and Cloudflare Turnstile is undeclared. For a state company with millions of customers, these are technically simple fixes.
612d077d4b3c410766c509943c4aef55ace34618673fa15558acde3882662084Where 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 omnivagroup.com. 2. Circumstances I visited the website omnivagroup.com 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) Cookiebot (+954 ms) and GTM (+1053 ms) load almost simultaneously. Cloudflare Insights (+965 ms) and Cloudflare Turnstile (+957 ms) fire before the banner has fully loaded. A GA collect fires at +1530 ms — by which point the banner has not yet been shown to the user. 2) GTM and GA4 activate before Cookiebot has finished rendering the banner and displaying it to the user. A GA collect at +1530 ms goes to the USA before any interaction with the banner. 3) Cloudflare Turnstile (anti-bot protection) is not mentioned in the policy as a data recipient. The policy describes cookies in general categories, with no listing of specific recipients. 4) Google Analytics (G-CSG389Q6FR) — USA. Cloudflare (Insights, Turnstile) — USA. No transfer mechanism is stated. Full technical documentation is published at: https://gdpru.eu/en/audits/ee-omnivagroup-com/ 3. Provisions violated GDPR Art. 6(1), Art. 5(1)(a); GDPR Art. 7; 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]