Finnish Posti Group in Estonia. GTM loads at +574 ms — 267 ms before OneTrust. New Relic uses the EU instance (bam.eu01.nr-data.net) — a deliberate choice. But the load order of GTM violates the principle of consent before processing.
Timeline of the leak
Declared versus actual
Transfer timings
Posti Group fonts and styles
GTM-NHWQ4B77 — 267 ms before OneTrust
OneTrust begins loading
OneTrust fully ready
The New Relic SPA agent
New Relic's EU instance. Data to the EU
Detected trackers
- Google Tag Manager (GTM-NHWQ4B77)
- OneTrust (cdn-ukwest.onetrust.com)
- New Relic (js-agent.newrelic.com, bam.eu01.nr-data.net)
- unpkg.com CDN (web-vitals)
- Contentful CDN (images.ctfassets.net)
- Posti CDN (cdn.posti.fi, www.posti.fi)
Indicators of GDPR non-compliance
- GDPR Art. 6(1), Art. 5(1)(a)GTM (+574 ms) loads 267 ms before OneTrust begins loading (+841 ms). Posti CDN (+128 ms) and Contentful CDN (+132 ms) fire immediately. New Relic (+1472 ms) activates after OneTrust, but before any user interaction with the banner.
- GDPR Art. 7GTM loads 267 ms before OneTrust. OneTrust fully loads by roughly +1145 ms. Between GTM loading and the banner appearing, there is a roughly 600 ms window during which analytics could have initialized.
- GDPR Art. 13(1)(e)The privacy policy mentions Google Analytics in general terms. New Relic, Contentful CDN, unpkg.com, and Posti CDN (www.posti.fi) are not mentioned as data recipients.
- GDPR Art. 13(1)(f), Chapter VGTM, unpkg.com, and Contentful — servers in the USA. No transfer mechanism is stated for any recipient.
Context
SmartPost Estonia OÜ is a network of parcel lockers in Estonia, a subsidiary of the Finnish Posti Group Oyj. A competitor to Omniva in Estonia’s parcel-locker market. HAR: 55 requests, 9 domains. Session on a page for business clients.
GTM before the banner — 267 milliseconds
GTM loads at +574 ms. OneTrust begins loading at +841 ms. The gap: 267 ms. OneTrust is fully ready by roughly +1145 ms. Between GTM loading and the banner appearing, there is nearly a 600-millisecond window. This is the same problem seen at Zalando, Omniva, and SmartPost — the script load order violates the principle of consent before processing.
New Relic EU — a deliberate choice
New Relic collects SPA performance data: transactions, JavaScript errors, events. SmartPost uses the EU instance: bam.eu01.nr-data.net — data is processed within the EU. This is the third site in the series, after IIZI and Zalando’s Sentry EU, where performance monitoring is deliberately kept on European infrastructure.
Posti CDN — dependency on the parent company
cdn.posti.fi loads fonts and CSS from the Finnish Posti Group (+128 ms). www.posti.fi/federated-module (+663 ms) loads a JavaScript module via Webpack Module Federation — a smart component pulled directly from the Finnish site. This is an architectural choice: the Estonian site imports live components from its Finnish parent. Every visitor’s IP address is transmitted to Finland on every site open.
Contentful and unpkg
images.ctfassets.net — the CDN for Contentful, an American CMS platform. Images are hosted on US servers. unpkg.com loads web-vitals@5.0.1 — Google’s performance-measurement library. Neither is mentioned in the privacy policy.
Comparison with Omniva
Both are postal operators in the Estonian market, both use a CMP (Omniva — Cookiebot, SmartPost — OneTrust). Both load GTM before the banner. SmartPost chose New Relic’s EU instance — an advantage over Omniva. Omniva uses Cloudflare Turnstile; SmartPost does not.
Conclusion
SmartPost demonstrates deliberate choices regarding EU infrastructure: New Relic EU, Posti CDN in Finland. But GTM loads 267 ms before OneTrust — the standard load-order problem. Contentful CDN and unpkg.com are undeclared. The privacy policy describes Google Analytics and Facebook in general terms, without naming the other actual recipients.
82ad889d7edfee4be865fcbcf5cb8651e5e11f0344981079a91d5cc45f48c85dWhere 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 smartposti.ee. 2. Circumstances I visited the website smartposti.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) GTM (+574 ms) loads 267 ms before OneTrust begins loading (+841 ms). Posti CDN (+128 ms) and Contentful CDN (+132 ms) fire immediately. New Relic (+1472 ms) activates after OneTrust, but before any user interaction with the banner. 2) GTM loads 267 ms before OneTrust. OneTrust fully loads by roughly +1145 ms. Between GTM loading and the banner appearing, there is a roughly 600 ms window during which analytics could have initialized. 3) The privacy policy mentions Google Analytics in general terms. New Relic, Contentful CDN, unpkg.com, and Posti CDN (www.posti.fi) are not mentioned as data recipients. 4) GTM, unpkg.com, and Contentful — servers in the USA. No transfer mechanism is stated for any recipient. Full technical documentation is published at: https://gdpru.eu/en/audits/ee-smartposti-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]