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Technical audit · 15.06.2026

kam.lt

Ministry of National Defence of Lithuania
LT

The Ministry of National Defence of Lithuania — 98 requests, 11 domains. Google Analytics sends a page_view event before consent, even though the policy classifies it as statistics selected via consent. Additionally, before consent, Google reCAPTCHA, the MailerLite mailing service, and Google fonts run — none of them named in the policy. No consent manager was found.

Request timeline

+0 ms · portal loads
Content and resources from kam.lt.
+3343 ms · Google Tag Manager
www.googletagmanager.com/gtag/js?id=G-WS22QPYJJT — the tag container and GA4.
+3352 ms · reCAPTCHA and MailerLite
www.google.com/recaptcha/api.js and groot.mailerlite.com/js/w/webforms.min.js — reCAPTCHA and the embedded MailerLite newsletter form (account 799047).
session state — no consent given
No consent manager was found. Zero Set-Cookie headers for the entire session, and no user choice was made.
+4182 ms · GA4 page_view before consent
region1.google-analytics.com/g/collect — a page_view event 'Krašto apsaugos ministerija' with the URL and a client identifier (cid) goes out to Google (US).
+4874–5020 ms · fonts
fonts.gstatic.com and fonts.mailerlite.com — Open Sans fonts. The IP goes out to Google and MailerLite.

Declared versus actual

✓ Google Analytics — declared as a statistical cookie, data transmitted based on the user's choice — declared
✓ The cookie policy describes cookie types in detail — declared
+ GA4 fires before consent, contrary to the declared statistical-cookie selection — not declared
+ MailerLite (account 799047) — mailing form, before consent, not named in the policy — not declared
+ Google reCAPTCHA — before consent, not named in the policy — not declared
+ Google Fonts (fonts.gstatic.com) — before consent, not named — not declared

Transfer timings

+3343 ms www.googletagmanager.com

GTM + GA4 G-WS22QPYJJT. Google, US.

+3352 ms www.google.com

reCAPTCHA api.js. Google, US. Not named in the policy.

+3353 ms groot.mailerlite.com

MailerLite mailing form, account 799047. Not named in the policy.

+4182 ms region1.google-analytics.com

GA4 page_view. Declared as consent-based statistics.

Detected trackers

Indicators of GDPR non-compliance

Context

kam.lt is the site of the Ministry of National Defence of the Republic of Lithuania (Krašto apsaugos ministerija, KAM), a defense and security sector agency. The data controller is KAM (asmens.duomenys@kam.lt). The ministry’s cookie policy was provided. Scan: 98 requests, 11 domains, captured in a clean browser.

Google (US) — GA4 page_view, reCAPTCHA, and fonts; MailerLite — an embedded mailing form.

Declared versus actual

KAM’s cookie policy describes cookie types in detail and explicitly names Google Analytics: analytics is classified as a statistical cookie, and transmission of data to the third party (Google Analytics) is tied to the user’s selection of statistical cookies. This is a model in which analytics activates upon consent. The policy does not mention MailerLite, Google reCAPTCHA, or Google Fonts.

The scan shows different behavior. At +4182 ms, GA4 (identifier G-WS22QPYJJT) sends a page_view event with the title “Krašto apsaugos ministerija,” the address kam.lt, and a client identifier (cid) to region1.google-analytics.com — that is, before consent. No consent manager was found in the scan, not a single cookie was set during the entire session, and no user choice was made. In parallel, starting from +3352 ms, Google reCAPTCHA (www.google.com/recaptcha, www.gstatic.com), the MailerLite email-marketing service (an embedded newsletter form, account 799047, from the domains assets/groot/static/fonts.mailerlite.com and assets.mlcdn.com), and Open Sans fonts load. All of these requests transmit the visitor’s IP to Google (US) and to MailerLite, and none of these services, apart from Google Analytics, is named in the policy. Thus, the declared “consent-based statistics” model is violated with respect to Google Analytics itself, while reCAPTCHA, MailerLite, and Google fonts operate before consent and without disclosure.

External services start from +3343 ms, and the GA4 page_view event goes out at +4182 ms. Consent was not given during the session (zero Set-Cookie headers), and no consent manager was found — all requests occur before any user choice.

What cannot be claimed from this scan

The scan covers the homepage. The GA4 client identifier is not reproduced in full in this publication. MailerLite serves the embedded subscription form; transmission of entered data was not performed in this session — what’s recorded is the loading of the form and related resources before consent. Google and MailerLite may use edge nodes within the EU, so the conclusion regarding recipient affiliation is based on company origin. Server-side processing is not visible in a browser-based scan.

Conclusion

The Ministry of National Defence of Lithuania’s site sends a page_view event to Google Analytics before consent, even though its own policy classifies analytics as a statistical cookie selected by the user. Additionally, before consent and without disclosure in the policy, Google reCAPTCHA, the MailerLite mailing service, and Google fonts run, transmitting the visitor’s IP to Google (US) and MailerLite. No consent manager was found. The combination of analytics firing before consent contrary to the declared model, undisclosed third-party services operating, and data being transmitted to recipients in the US indicates non-compliance with the requirements on consent, disclosure of recipients, and cross-border transfer. Remediation: implement a consent manager that holds GA4, reCAPTCHA, MailerLite, and fonts back until consent; bring actual behavior in line with the declared statistical-cookie selection model; host fonts locally; and disclose all services actually in use in the policy.

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: lt/kam-lt-2026-06-15.har
SHA-256: ede080b0cfc722b788da9d5abce5fb5f8c92833307e96e9584db7ded64e520dc
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) — kam.lt

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 kam.lt.

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 cookie policy explicitly classifies Google Analytics as a statistical cookie, with data transmitted to it based on the user's selection (choosing statistical slapukai). In the scan, GA4 (G-WS22QPYJJT) sends a page_view event to region1.google-analytics.com/g/collect with the title 'Krašto apsaugos ministerija' and the kam.lt URL before consent: zero Set-Cookie headers for the entire session, and the choice mechanism did not fire. Analytics activates before the consent the policy itself requires.

2) Before consent, Google reCAPTCHA (www.google.com/recaptcha, www.gstatic.com), the MailerLite email-marketing service (assets.mailerlite.com and related domains, account 799047, an embedded newsletter form), and Google fonts also load. The visitor's IP is transmitted to Google (US) and to MailerLite. Neither reCAPTCHA, MailerLite, nor Google Fonts is named in the policy.


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/lt-kam-lt/

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: State Data Protection Inspectorate (ADA) — ada.lt

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 — kam.lt

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

2. Circumstances
I visited the website kam.lt and found indications that the processing of my personal data does not comply with the GDPR. The technical analysis published on gdpru.eu on 15 June 2026 (open methodology, reproducible measurements) documents the following indications:

1) The cookie policy explicitly classifies Google Analytics as a statistical cookie, with data transmitted to it based on the user's selection (choosing statistical slapukai). In the scan, GA4 (G-WS22QPYJJT) sends a page_view event to region1.google-analytics.com/g/collect with the title 'Krašto apsaugos ministerija' and the kam.lt URL before consent: zero Set-Cookie headers for the entire session, and the choice mechanism did not fire. Analytics activates before the consent the policy itself requires.

2) Before consent, Google reCAPTCHA (www.google.com/recaptcha, www.gstatic.com), the MailerLite email-marketing service (assets.mailerlite.com and related domains, account 799047, an embedded newsletter form), and Google fonts also load. The visitor's IP is transmitted to Google (US) and to MailerLite. Neither reCAPTCHA, MailerLite, nor Google Fonts is named in the policy.

Full technical documentation is published at: https://gdpru.eu/en/audits/lt-kam-lt/

3. GDPR provisions I ask you to examine
ePrivacy (Lithuanian implementation) + the policy's own rule — GA before consent; GDPR Art. 13(1)(e) + Chapter V — disclosure of recipients and transfer

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]