Technical audit · 2026-04-13

rus.err.ee

Public Broadcasting, News for the Russian-Speaking Audience

A state public broadcaster, funded by taxpayers. While a reader is reading the news, Chartbeat records their every second of behavior, Gemius builds an audience profile, Mux tracks their video viewing. Not one of these trackers is mentioned in the policy. And the consent system itself set 'necessary only' — without asking the user.

Timeline of the leak

+258–259 ms · before consent

Google Fonts (+258 ms, status 200) — 191,078 bytes to Google, an actual transfer. Mux/Litix (src.litix.io, +259 ms) — American video analytics: what you watch, for how long, when you stop.

+3592–4269 ms · before consent

Chartbeat (+3592 ms) — real-time American media analytics: what's being read, for how long, where clicks happen. GTM (+4263 ms) — a container for any scripts. Gemius (+4269 ms) — a Polish audience-measurement platform.

Declared versus actual

✓ Account, comment, and archive-order data — заявлен

+ Chartbeat — reading analytics, a cookie valid until 2027 — не заявлен

+ Gemius — an audience profile, a cookie valid until 2027 — не заявлен

+ Mux / Litix — video analytics — не заявлен

+ Google Tag Manager, Google Fonts — не заявлен

Transfer timings

+258 ms fonts.gstatic.com

Google Fonts, 191,078 bytes to Google (USA). An actual transfer

+259 ms src.litix.io (Mux)

Video analytics, status 0 — the attempt is recorded

+3592 ms static.chartbeat.com

Real-time reading analytics, status 0. The _cb and _chartbeat2 cookies are already set

+4269 ms ee.hit.gemius.pl

Audience measurement, 12 Tracking Prevention warnings. The _gfp_64b cookie is set

Detected trackers

Chartbeat
Gemius
Mux / Litix
Google Tag Manager
Google Fonts
Cloudflare Insights (blocked)

Indicators of GDPR non-compliance

GDPR Art. 6(1), Art. 5(1)(a)
Gemius, Chartbeat, and Mux fire before consent. Analytics cookies (_gfp_64b, _cb, _chartbeat2) are set automatically before any interaction, with an expiration date in 2027.
GDPR Art. 7, Recital 32
errCookieConsent = necessary is set by the system with no user involvement — this is not consent. The system itself recorded the decision in the browser before asking, while the Chartbeat and Gemius analytics cookies are already set. The consent system contradicts itself.
GDPR Art. 13(1)(e)
Gemius, Chartbeat, Mux/Litix, and Google Tag Manager are not declared in the privacy policy. The policy describes only account, comment, and archive-order data.
GDPR Art. 13(1)(f), Chapter V
No cross-border transfer mechanism to the USA is stated for any recipient. Google Fonts — 191,078 bytes to Google with no consent. A transfer with no legal basis.
GDPR Art. 5(1)(a)
The policy describes only account data — the actual list of processors is six times broader.

Context

rus.err.ee is the Russian-language editorial arm of Eesti Rahvusringhääling (ERR), Estonia’s public broadcaster. A state-funded media outlet, financed from the national budget: news, analysis, and culture for Estonia’s Russian-speaking audience. HAR: 226 requests per session, 99 console errors.

On page load, before any interaction: Google Fonts (+258 ms, status 200) transmits 191,078 bytes to Google. Mux/Litix (+259 ms) — American video analytics, recording what and how long you watch. Chartbeat (+3592 ms) — real-time American media analytics: what’s being read, for how long, where clicks happen. Google Tag Manager (+4263 ms) — a container for any scripts. Gemius (+4269 ms) — a Polish audience-measurement platform, generating 12 Tracking Prevention warnings. Cloudflare Insights (+618 ms) — blocked by the browser, but the request is initiated.

ERR’s consent system set the errCookieConsent cookie to the value necessary automatically — before any user interaction. The system decided on its own that the user consents only to necessary cookies, and recorded this in the browser without asking. Meanwhile, analytics cookies are already set: _gfp_64b (Gemius, a user identifier, valid until 2027), _cb and _chartbeat2 (Chartbeat, a reader identifier and session data, valid until 2027) — all on the .err.ee domain. These are not technical cookies — they are trackers. The consent says “necessary only”; the reality is that analytics is already running.

The policy says nothing about the trackers

The privacy policy describes user account, comment, and archive-order data. About the site’s trackers — not a word: Gemius, Chartbeat, Mux/Litix, and Google Tag Manager are mentioned nowhere. The actual list of processors is roughly six times broader than what’s declared. A person reads the news on a state media portal — and while doing so, Chartbeat records their every second of behavior, Gemius builds an audience profile, and Mux tracks their video viewing. All without the reader’s knowledge and with no legal basis.

Conclusion

A state media outlet is funded by taxpayers, and readers trust it as a source of information. That trust presumes their data is protected, at least at a basic level. Here, instead, Chartbeat knows what every rus.err.ee reader reads and for how long; Gemius builds an audience profile; Mux records every video view. The reader doesn’t know this — the privacy policy doesn’t tell them. And instead of asking, the consent system checked “necessary only” on top of trackers that were already running.

Evidence

Original (audit)

HAR file: ee/rus-err-ee-2026-04-13.har

SHA-256: 1ef7a77930fd79812b34e232636b5baef1789f36dc333f8e89fd55d80a3280dc

Re-check snapshot

Awaiting changes

HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.

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.

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 rus.err.ee.

2. Circumstances
I visited the website rus.err.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 13 April 2026 (open methodology, reproducible measurements) documents the following indications:

1) Gemius, Chartbeat, and Mux fire before consent. Analytics cookies (_gfp_64b, _cb, _chartbeat2) are set automatically before any interaction, with an expiration date in 2027.

2) errCookieConsent = necessary is set by the system with no user involvement — this is not consent. The system itself recorded the decision in the browser before asking, while the Chartbeat and Gemius analytics cookies are already set. The consent system contradicts itself.

3) Gemius, Chartbeat, Mux/Litix, and Google Tag Manager are not declared in the privacy policy. The policy describes only account, comment, and archive-order data.

4) No cross-border transfer mechanism to the USA is stated for any recipient. Google Fonts — 191,078 bytes to Google with no consent. A transfer with no legal basis.

5) The policy describes only account data — the actual list of processors is six times broader.

Full technical documentation is published at: https://gdpru.eu/en/audits/ee-rus-err-ee/

3. Provisions violated
GDPR Art. 6(1), Art. 5(1)(a); GDPR Art. 7, Recital 32; GDPR Art. 13(1)(e); GDPR Art. 13(1)(f), Chapter V; GDPR Art. 5(1)(a)

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]