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Technical audit · 06.06.2026

pilet.ee

Estonia's Public Transport Ticketing Platform
EE

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.

Request timeline

+83 ms · before consent
Google Fonts (fonts.googleapis.com) — the Inter typeface, IP address to Google, USA.
+1350 ms · before consent
GTM (GTM-MFT2LM8) — loads with no consent.
+1359 ms · before consent
LaunchDarkly (app.launchdarkly.com) — SDK goals and evalx requests. Transmits an anonymoususer identifier to the USA.
+1522 ms · before consent
LaunchDarkly clientstream — a persistent SSE connection carrying the user identifier.
Consent banner
Completely absent. Zero consent requests, zero Set-Cookie.

Declared versus actual

+ Google Fonts (fonts.googleapis.com, fonts.gstatic.com) — not declared
+ Google Tag Manager (GTM-MFT2LM8) — not declared
+ LaunchDarkly (app.launchdarkly.com, clientstream.launchdarkly.com) — not declared

Transfer timings

+83 ms fonts.googleapis.com

Inter. IP address to Google, USA

+1350 ms www.googletagmanager.com

GTM-MFT2LM8, status 200

+1359 ms app.launchdarkly.com

SDK goals + evalx, anonymoususer ID

+1522 ms clientstream.launchdarkly.com

An SSE stream carrying the identifier. USA

Detected trackers

Indicators of GDPR non-compliance

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.

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/pilet-ee-2026-06-06.har
SHA-256: 951a1f8eba7d9392dcf37b05eeb3c556863ebcb6098e37ca4d77c9c74dbe81dc
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) — pilet.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 pilet.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 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.


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-pilet-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 — pilet.ee

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. 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]