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Technical audit · 06.06.2026

omnivagroup.com

Estonia's State Postal Service
EE

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.

Request timeline

+954 ms · the banner begins loading
Cookiebot (consent.cookiebot.com) — loading begins. The banner has not yet rendered.
+957 ms · before the banner
Cloudflare Turnstile (challenges.cloudflare.com) — anti-bot protection. IP address to Cloudflare, USA.
+965 ms · before the banner
Cloudflare Insights (static.cloudflareinsights.com) — an analytics beacon. USA.
+1053 ms · before the banner
GTM (GTM-NZM7ZWK7) — loads while Cookiebot is still not ready.
+1307 ms · banner visible
The Cookiebot SDK fully loads (bc-v4.min.html). The banner appears.
+1445 ms
GA4 G-CSG389Q6FR loads via GTM. A second container, G-L782ZE2F7P, returns a 404 — it doesn't exist.
+1530 ms
A GA collect (G-CSG389Q6FR) — data goes to Google, USA. Before any user interaction with the banner.

Declared versus actual

✓ Various cookies — mentioned in general terms — declared
✓ Cookiebot — mentioned as the consent-management tool — declared
+ Cloudflare Turnstile (challenges.cloudflare.com) — not declared
+ GA4 G-L782ZE2F7P — wired into the code, returns a 404 — not declared

Transfer timings

+954 ms consent.cookiebot.com

Cookiebot starts loading

+957 ms challenges.cloudflare.com

Turnstile anti-bot. USA

+965 ms static.cloudflareinsights.com

Cloudflare Insights beacon

+1053 ms www.googletagmanager.com

GTM-NZM7ZWK7

+1307 ms consentcdn.cookiebot.com

SDK ready, banner visible

+1530 ms region1.google-analytics.com

GA4 collect. USA

Detected trackers

Indicators of GDPR non-compliance

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 does not comply with 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.

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/omnivagroup-com-2026-06-06.har
SHA-256: 612d077d4b3c410766c509943c4aef55ace34618673fa15558acde3882662084
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) — omnivagroup.com

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 omnivagroup.com.

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) 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.


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-omnivagroup-com/

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 — omnivagroup.com

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. GDPR provisions I ask you to examine
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 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]