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Technical audit · 20.06.2026

subito.it

Classifieds Board
IT

Subito.it is Italy's largest classifieds board. Home-page capture: 172 requests, 17 domains. There is a Didomi consent-collection platform to the IAB standard, and in a clean session its consent string means «no consent for any purpose». In the site's favour: Google's advertising delivery observes this — the actual ad request goes out with this string, that is, the advertising is non-personalised. But other services fire before consent: the AppsFlyer marketing attribution SDK, the Google AdSense advertising tag with analytics allowed by default, and the site's own analytics service. That is, the advertising delivery respects the refusal, while the marketing attribution and analytics start before consent.

Request timeline

320 ms · consent platform and advertising library
The Didomi consent-collection platform and the Google Ad Manager advertising library load simultaneously. At this stage the library only prepares the ad slots.
2222 ms · Subito's own analytics
The site's own analytics service (collector) begins collecting events. This is first-party analytics on Subito's domain, before consent.
2377 ms · AppsFlyer marketing SDK
The AppsFlyer marketing-attribution SDK loads. It is listed as a partner in the site's own consent system, that is, its launch requires prior consent — and it is not given.
2674 ms · AdSense advertising tag
The Google AdSense advertising tag sends a utility request. The consent signal shows that analytics is allowed by default.
consent string — «no»
The Didomi platform forms a consent string that means the absence of consent for all purposes. No decision was made in the session, no cookie was set via the headers.
around 89 seconds · ad delivery with the «no consent» flag
The actual Google ad request goes out with the attached «no consent» string — the advertising is non-personalised. Google observes this part correctly.

Declared versus actual

✓ AppsFlyer — declared

Detected trackers

Indicators of GDPR non-compliance

Context

www.subito.it is Italy’s largest classifieds platform (buying and selling goods, cars, real estate, services). The data controller is the Subito operator. The site is commercial, monetised among other ways by publisher advertising. Capture: 172 requests to 17 domains, the home page, taken on a clean Edge browser with no VPN and no blocker. There is a Didomi consent-collection platform to the IAB standard. The technical stack includes Google publisher advertising, marketing attribution and own analytics.

Who receives the data

Spotted here were: Google, AppsFlyer. Google is present through publisher advertising (Ad Manager and AdSense) — Subito displays ad blocks. AppsFlyer is a marketing-attribution service that tracks the effectiveness of advertising campaigns. Additionally, the site’s own analytics service works.

Yes, the site has a Didomi consent-collection platform to the IAB standard. In a clean session it forms a consent string that, when decoded, means: consent is not given for any purpose. And here it is important to note the positive: Google’s advertising delivery observes this string. The actual ad request goes out with the attached «no consent» flag, that is, the advertising is non-personalised. This counts in the site’s favour.

Before consent, the following fire:

  • the AppsFlyer marketing-attribution SDK — and it is listed as a partner in the site’s own consent system;
  • the Google AdSense advertising tag — with analytics allowed by default;
  • the site’s own analytics service. Marketing attribution and analytics are non-technical purposes requiring consent. AppsFlyer, in addition, is explicitly listed as a partner in the site’s consent system, that is, the platform itself acknowledges that its launch should go after the choice. Here it loads in the first seconds.

A mixed picture

Subito has a dual picture, and it is worth separating. Google’s advertising delivery is set up correctly: with no consent the advertising is non-personalised, the «no consent» flag is transmitted. But in parallel the marketing SDK and analytics start before consent. That is, one part of the stack observes the refusal, and another does not.

Conclusion

Subito.it is a moderate case with a mixed picture. Google’s advertising delivery is configured to observe consent — with no consent the advertising is non-personalised, and this distinguishes the site favourably. But the AppsFlyer marketing-attribution SDK and the advertising tag with analytics by default fire before consent, and AppsFlyer is explicitly named a partner in the site’s consent system. The main takeaway for the reader: the advertising delivery observing consent is correct, but it does not close the question if, alongside, marketing attribution and analytics switch on before the choice. It would be enough to switch their launch into consent-waiting mode — just as has already been done for the advertising delivery.

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: it/subito-it-2026-06-20.har
SHA-256: 0a3584756babc83e9a3e39a314cecabaf8f38431a32a7f1b86ed72f87a242aba
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) — subito.it

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 subito.it.

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) The site has a Didomi consent-collection platform to the IAB standard (TCF), and in a clean session its consent string, when decoded, means that consent is not given for any purpose. Google's advertising delivery observes this: the actual ad request goes out with the attached «no consent» string, that is, the advertising is non-personalised, and this counts in the site's favour. But other services fire before consent. The AppsFlyer marketing attribution SDK loads — and it is listed as a partner in the site's own consent system, that is, its launch requires prior choice. The Google AdSense advertising tag sends a utility request with analytics allowed by default. The site's own analytics service (collector) begins collecting events. All of this happens in the first seconds, whereas consent is not given. Marketing attribution and analytics are non-technical purposes requiring consent, and here they start before it.


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/it-subito-it/

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: Italian Data Protection Authority (Garante) — garanteprivacy.it

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 — subito.it

1. Subject of the complaint
I am filing a complaint regarding the processing of my personal data by the website subito.it.

2. Circumstances
I visited the website subito.it and found indications that the processing of my personal data does not comply with the GDPR. The technical analysis published on gdpru.eu on 20 June 2026 (open methodology, reproducible measurements) documents the following indications:

1) The site has a Didomi consent-collection platform to the IAB standard (TCF), and in a clean session its consent string, when decoded, means that consent is not given for any purpose. Google's advertising delivery observes this: the actual ad request goes out with the attached «no consent» string, that is, the advertising is non-personalised, and this counts in the site's favour. But other services fire before consent. The AppsFlyer marketing attribution SDK loads — and it is listed as a partner in the site's own consent system, that is, its launch requires prior choice. The Google AdSense advertising tag sends a utility request with analytics allowed by default. The site's own analytics service (collector) begins collecting events. All of this happens in the first seconds, whereas consent is not given. Marketing attribution and analytics are non-technical purposes requiring consent, and here they start before it.

Full technical documentation is published at: https://gdpru.eu/en/audits/it-subito-it/

3. GDPR provisions I ask you to examine
Art. 6(1)(a) GDPR — marketing attribution and analytics fire before consent

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]