Estonia's public transport ticketing platform — Swedbank, SEB, LHV, Visa, Mastercard. There is no consent banner. LaunchDarkly transmits an identifier for every anonymous user to the USA on page load.
Timeline of the leak
Declared versus actual
Transfer timings
Inter. IP address to Google, USA
GTM-MFT2LM8, status 200
SDK goals + evalx, anonymoususer ID
An SSE stream carrying the identifier. USA
Detected trackers
- Google Tag Manager (GTM-MFT2LM8)
- Google Fonts (fonts.googleapis.com, fonts.gstatic.com)
- LaunchDarkly (app.launchdarkly.com, clientstream.launchdarkly.com)
Indicators of GDPR non-compliance
- GDPR Art. 6(1), Art. 5(1)(a)Google Fonts (+83 ms) and GTM (+1350 ms) fire with no consent. LaunchDarkly (+1359 ms) transmits an anonymous user identifier to the USA before consent. There is no consent banner at all.
- GDPR Art. 7There is no consent mechanism. Zero consent requests, zero Set-Cookie. The site processes payment data (Swedbank, SEB, LHV, Visa, Mastercard) — the absence of a banner on such a site is especially significant.
- GDPR Art. 13(1)(e)The policy is Ridango's terms of service, not the site's privacy policy. Google Fonts, GTM, and LaunchDarkly are not mentioned as data recipients.
- GDPR Art. 13(1)(f), Chapter VLaunchDarkly (USA) receives a user identifier on every page load. Google Fonts and GTM — USA. No transfer mechanism is stated.
Context
pilet.ee is Estonia’s public transport ticketing platform, run by Ridango AS. Payment transactions flow through the site: bank links for Swedbank, SEB, and LHV, plus Visa and Mastercard. The privacy policy is, in fact, Ridango’s terms of service — describing the rules for using the service, not the processing of personal data on the site. HAR: 50 requests, 7 domains.
LaunchDarkly — what it is
LaunchDarkly is an American feature-flag management platform: it lets site features be toggled on and off for different user groups without code deployment. A technically useful tool, but on load it transmits every visitor’s identifier to the USA.
Three requests appear in the HAR: sdk/goals (goals), sdk/evalx/…/users/ (flag evaluation for the user), and clientstream (a persistent SSE connection). The URL encodes JSON with an anonymoususer key — LaunchDarkly assigns a unique identifier to every anonymous visitor and transmits it to American servers. All of this happens before any consent banner appears — and there is none at all.
The policy — not about privacy
The document is titled “Ridango teenuste tingimused” — terms of service. It describes ticket-purchase rules, prices, refunds, and the parties’ liability. There is no section on cookies, external services, or personal-data recipients. This is not a privacy policy within the meaning of GDPR Art. 13.
Sensitivity context
pilet.ee is not an informational site. Real payment transactions of Estonian residents pass through it. The absence of a consent banner on a payment platform means data about every visitor is transmitted to Google and LaunchDarkly before a person has even decided to buy a ticket.
Conclusion
50 requests, 7 domains — a relatively clean architecture for a payment platform. But LaunchDarkly transmits every anonymous user’s identifier to the USA, GTM loads with no consent, there’s no banner at all, and the document titled a privacy policy isn’t one. Ridango builds payment infrastructure for urban transport — the same level of care should extend to how it handles site visitors’ data.
951a1f8eba7d9392dcf37b05eeb3c556863ebcb6098e37ca4d77c9c74dbe81dcWhere 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 pilet.ee. 2. Circumstances I visited the website pilet.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 6 June 2026 (open methodology, reproducible measurements) documents the following indications: 1) Google Fonts (+83 ms) and GTM (+1350 ms) fire with no consent. LaunchDarkly (+1359 ms) transmits an anonymous user identifier to the USA before consent. There is no consent banner at all. 2) There is no consent mechanism. Zero consent requests, zero Set-Cookie. The site processes payment data (Swedbank, SEB, LHV, Visa, Mastercard) — the absence of a banner on such a site is especially significant. 3) The policy is Ridango's terms of service, not the site's privacy policy. Google Fonts, GTM, and LaunchDarkly are not mentioned as data recipients. 4) LaunchDarkly (USA) receives a user identifier on every page load. Google Fonts and GTM — USA. No transfer mechanism is stated. Full technical documentation is published at: https://gdpru.eu/en/audits/ee-pilet-ee/ 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]