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.
Timeline of the leak
Declared versus actual
Transfer timings
GTM + GA4 G-WS22QPYJJT. Google, US.
reCAPTCHA api.js. Google, US. Not named in the policy.
MailerLite mailing form, account 799047. Not named in the policy.
GA4 page_view. Declared as consent-based statistics.
Detected trackers
- Google Analytics 4 (G-WS22QPYJJT) + GTM
- Google reCAPTCHA (www.google.com, www.gstatic.com)
- MailerLite (assets.mailerlite.com, account 799047) — email marketing
- Google Fonts (fonts.gstatic.com)
Indicators of GDPR non-compliance
- ePrivacy (Lithuanian implementation) + the policy's own rule — GA before consentThe 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.
- GDPR Art. 13(1)(e) + Chapter V — disclosure of recipients and transferBefore 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.
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.
Who receives data directly (before consent)
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.
Timing relative to consent
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 constitutes a violation of 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.
ede080b0cfc722b788da9d5abce5fb5f8c92833307e96e9584db7ded64e520dcWhere to file: State Data Protection Inspectorate (ADA) — ada.lt
To: State Data Protection Inspectorate (ADA) 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 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. Provisions violated 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 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]