Technical audit · 08.10.2026

toilaspa.ee

Website of the Toila SPA Hotell spa hotel

The website of the Toila SPA Hotell spa hotel — four pages, 425 requests. The CookieYes script loads, but there is no visitor decision in the capture, while the Meta pixel, Google Ads, Google Analytics and Google AdSense advertising run from the first seconds on every page, without consent mode and with the same identifiers throughout. In the booking system, the banner offers only 'Nõustun kõigiga'. The policy says nothing about cookies or about Meta and Google, does not link legal bases to purposes and lists rights incompletely.

Request timeline

+0…+1.3 s · entering
Redirect http → https. CookieYes (+0.9 s), the AdSense script, Cloudflare Turnstile, libraries from unpkg and jsDelivr; fbevents.js and GTM-NM34R8M (+1.3 s).
+2.1…+5.4 s · advertising and analytics
AdSense ad request (+2.1 s). Google Ads without a consent state (+2.4 s). Meta pixel PageView (+2.5 s). GA4 with a client identifier, stats.g.doubleclick.net and ga-audiences (+2.8 s). Ad traffic check via adtrafficquality.google (+3.0…+5.4 s).
+131…+329 s · three more pages
Privacy policy, terms of purchase, the homepage again: on each, the Meta pixel, Google Ads, GA4 with ga-audiences and AdSense anew. Google's identifiers are the same on every page.

Declared versus actual

✓ Controller — AS Toila Sanatoorium; kinkekaart@toilaspa.ee, admin@toilaspa.ee (details in the booking system footer: registration code 10338119, Ranna 12, Toila) — declared
✓ Policy: legal bases — GDPR Art. 6(1)(a), (b), (c), (f) in a single list; six purposes with retention periods, including marketing — declared
✓ Policy: recipients — processors, accountants, couriers, payment services; by name, Maksekeskus AS and Montonio Finance OÜ — declared
✓ Terms of purchase: the customer's personal data is not disclosed to other parties without their consent — declared
✓ Booking system banner: 'Klõpsates „Nõustun kõigiga“, nõustute küpsiste kasutamisega', a single button — declared
✓ Supervisory authority — Andmekaitse Inspektsioon — declared
+ Cookies, web analytics and advertising — not a word in the policy — not declared
+ Meta, Google Ads, Google Analytics, Google AdSense as recipients — not declared
+ Data transfers outside the EU — not declared
+ Rights to erasure, restriction, objection and portability — not declared
+ Refusing cookies in the booking system — not declared

Transfer timings

+2.1 s pagead2.googlesyndication.com

AdSense ad request, ca-pub-8077567627350879.

+2.4 s www.google.com

Google Ads ccm/collect, page_view without a consent state.

+2.5 s www.facebook.com

Meta pixel 226432978018098 PageView.

+2.8 s www.google.ee

ads/ga-audiences with a client identifier.

+132.2 s www.facebook.com

PageView on the privacy policy page.

+327.1 s www.google.com

Google Ads, the same advertising identifier as on the first page.

Detected trackers

Indicators of GDPR non-compliance

Context

toilaspa.ee is the website of the Toila SPA Hotell spa hotel: rooms, packages, the water park and saunas, treatments, restaurants, seminars, a gift card shop and booking. The controller is AS Toila Sanatoorium (registration code 10338119, Ranna 12, Toila). The CookieYes consent platform script is connected on the site. Room booking runs in a separate system by the developer SALBOS, with its own banner.

The measurement is a single capture of four page loads: the homepage, the privacy policy, the terms of purchase, and the homepage again. In total, 425 requests, more than half of them to the site itself. The booking system is documented by screenshots.

Who receives data directly

Meta — through the pixel. Google — Ads, Analytics with the DoubleClick and ga-audiences advertising nodes, AdSense with an ad traffic check, Tag Manager, Fonts. Cloudflare — Turnstile. CookieYes — the consent platform script.

Declared versus actual

First — advertising without a choice. Two and a half seconds after entry, the Meta pixel sends a page view, Google Ads sends one with an advertising identifier, and Google Analytics sends one with a client identifier that immediately goes on to Google’s advertising nodes. At the same time, the site requests a Google AdSense ad. Google’s tags have no consent mode. This happens on every page, and the identifiers stay the same from page to page.

Second — no refusal in booking. The booking system banner states that pressing “Nõustun kõigiga” means consent, and offers no other button.

Third — the policy is silent about cookies and about who receives data. The AS Toila Sanatoorium policy names only two payment services. It has not a word about cookies, analytics or advertising, nor about Meta and Google, nor about transfers outside the EU. Meanwhile, the terms of purchase promise not to disclose customer data to other parties without the customer’s consent.

Fourth — legal bases and rights. Four legal bases are listed separately from the purposes. Of the rights, erasure, restriction, objection and portability are missing.

Proven: the Meta pixel, Google Ads, Google Analytics and AdSense send data without a visitor decision. From +2.1 s on the first page and anew on each of the next three.

Proven: Google’s tags have no consent mode. The gcd parameter has no set states, and no request carries a gcs parameter.

Proven: there is no refusal in the booking system. Screenshots 3 and 4.

Proven: Meta and Google are not named in the policy. A search of the saved text.

Not established: whether the CookieYes banner was shown on toilaspa.ee. The script loads, but there are no decision requests in the capture, and no banner is visible on the homepage screenshot. This is not decisive for the conclusion: data leaves in the first seconds, before a visitor could choose anything.

Not established: what the booking system transmits. Its traffic is not part of the measurement.

Boundaries of this observation

The measurement covers public pages of toilaspa.ee. The shop, booking and payment are not in the capture; the booking system is documented only by screenshots. The observation records browser behavior, not server-side processing. The file has been published cleaned: Cookie headers and POST bodies were removed. Google identifiers are not reproduced in full in this review.

Legal assessment falls to the competent authority — the Andmekaitse Inspektsioon, which is named in the policy itself.

Conclusion

Toila SPA gives the visitor no choice. The Meta pixel, Google Ads, Google Analytics and AdSense advertising run from the first seconds on every page, with persistent identifiers, and the consent platform script has no effect on this. The booking system offers only a consent button. The policy says nothing about cookies or about Meta and Google, and the terms of purchase promise something the capture shows is not kept.

Remedy: configure CookieYes so that the Meta pixel, Google Ads, Google Analytics and AdSense do not load before consent, and enable Google consent mode with a denied default; add a refusal button to the booking system banner; add a cookie section to the policy, name Meta and Google as recipients, describe transfers outside the EU, link each purpose to a legal basis and list all data subject rights.

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/toilaspa-ee-2026-10-08.har
SHA-256: 8c3878b8129bb4a37cf19d7cef91b6ab06ea690e46b6a4048c73d68412c97c95
Screenshot
Скриншот интерфейса
toilaspa.ee homepage: the 'Uuenenud esinejate kava' advertising pop-up, no cookie banner visible · 08.10.2026
Скриншот интерфейса
Terms of purchase, 'Konfidentsiaalsus' section: customer data is not disclosed to other parties without their consent · 08.10.2026
Скриншот интерфейса
Booking system: the 'Me hindame Teie privaatsust!' banner with a single 'Nõustun kõigiga' button; AS Toila Sanatoorium details in the footer · 08.10.2026
Скриншот интерфейса
Russian version of the booking system: a single 'Я согласен со всеми' button · 08.10.2026
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.