Technical audit · 29.09.2026

swedbank.ee

Website of Swedbank in Estonia

The Swedbank website in Estonia — four pages, 168 requests, and only three of them leave the bank's own domains. A banner with three equally weighted buttons, including 'Nõustun vajalike küpsistega', with categories switched off. The only third-party request is statistics about the banner itself in Adobe Analytics: how many times it was shown and how many times 'save' was clicked, without a visitor identifier. The cookie declaration is detailed. No violations recorded.

Request timeline

+0 s · entering
Redirect to swedbank.ee/private. A strict Content-Security-Policy header and the bank's own scripts.
+1.8 s · banner statistics
swedbankab.d3.sc.omtrdc.net — a cookieConsentView event in a separate report suite for the cookie banner. Page address, language, and country; no visitor identifier.
+196…+343 s · bank pages
Private clients, the Gold segment, the cookie page: only the bank's own domains. Not a single request to analytics or advertising, apart from one more click event in the banner statistics.

Declared versus actual

✓ Website of the financial companies Swedbank AS, Swedbank Liising AS, Swedbank P&C Insurance AS, Swedbank Life Insurance SE, Swedbank Investeerimisfondid AS — declared
✓ Banner: 'Nõustun kõigi küpsistega', 'Nõustun vajalike küpsistega', 'Haldan küpsiseid'; functional, analytics, and marketing cookies switched off by default — declared
✓ Cookie declaration: Adobe (AMCV_*, s_vi_*) and Glassbox — among analytics cookies, with descriptions and durations — declared
✓ Consent can be withdrawn on the cookie page — declared

Transfer timings

+1.8 s swedbankab.d3.sc.omtrdc.net

cookieConsentView, the cookie report suite.

+188.2 s swedbankab.d3.sc.omtrdc.net

A save-my-preferences click.

Detected trackers

Context

swedbank.ee is the website of Swedbank in Estonia and of the group’s financial companies: Swedbank AS, Swedbank Liising AS, Swedbank P&C Insurance AS, Swedbank Life Insurance SE, and Swedbank Investeerimisfondid AS. The site is served from the bank’s own domains and protected by a strict Content-Security-Policy header.

The measurement is a single capture of four pages: the private clients homepage, the private clients section, the Gold segment, and the cookie page. In total, 168 requests, of which only three leave the bank’s domains.

Processing is described by the cookie banner, the cookie declaration, and the “Küpsiste kasutamine” page.

Who receives data directly

Only Adobe — statistics about the cookie banner itself, without a visitor identifier.

Declared versus actual

Here, what is described and what runs match. The banner offers three equally weighted buttons: accept all, accept only necessary, and manage. Functional, analytics, and marketing cookies are switched off by default. The cookie page has a link to change preferences and withdraw consent. The declaration is detailed: for each cookie, it gives the provider, purpose, and duration, including for Adobe and Glassbox.

Across the whole capture, three requests left the bank’s domains, all of them to Adobe Analytics, into a separate report suite for the cookie banner. The first reports that the banner was shown, the other two that the visitor clicked “save preferences”. The requests transmit the page address, language, and country, but no visitor identifier: no mid, aid, or vid. Neither full Adobe analytics, nor Glassbox, nor any advertising appears in the capture.

One remark that does not affect the conclusion. The banner view statistics go to Adobe before the visitor’s choice. For requests without an identifier or cookies, this is a minimal intrusion, but it does pass the visitor’s IP address to Adobe. It would be more accurate to describe these statistics as a separate line in the declaration.

Proven: refusal of non-essential cookies is available on the first layer. The “Nõustun vajalike küpsistega” button in screenshot 1.

Proven: analytics and advertising did not run in the capture. Apart from the banner statistics, not a single third-party request.

Proven: the banner statistics carry no visitor identifier. The parameters of the requests to Adobe contain no identifiers.

Not established: whether Adobe sets a cookie on its own domain. Cookie and Set-Cookie headers were removed during cleaning. The finding that no identifier is present rests on the request parameters.

Not established: behaviour after full consent. The visitor saved settings without enabling additional categories.

Boundaries of this observation

The measurement covers the site’s public pages. Internet banking and login were not examined. The observation records browser behavior, not server-side processing. The file has been published cleaned: Cookie headers were removed.

Legal assessment falls to the competent authority — the Andmekaitse Inspektsioon.

Conclusion

Swedbank shows what it looks like at a large bank when it is done carefully: three equally weighted buttons on the first screen, categories off by default, a detailed declaration, and almost no third-party requests. The only thing to leave the site before any choice is anonymised statistics about the banner itself. No violations recorded.

Suggestion: list the banner statistics in Adobe Analytics as a separate line in the cookie declaration.

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/swedbank-ee-2026-09-29.har
SHA-256: bc632f51e38bc68a2c9623dc2f35f5884fc7e4c9280b99ff09445134717dca72
Screenshot
Скриншот интерфейса
The 'Küpsised' banner: 'Nõustun kõigi küpsistega', 'Nõustun vajalike küpsistega', 'Haldan küpsiseid' — three equally weighted buttons · 29.09.2026
Скриншот интерфейса
'Küpsiste seaded': functional and analytics cookies switched off by default · 29.09.2026
Скриншот интерфейса
The 'Küpsiste kasutamine' page with a link to change preferences and withdraw consent · 29.09.2026
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.