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Technical audit · 2026-06-15

policija.lrv.lt

Police of Lithuania
LT

The Police of Lithuania — 35 requests, 5 domains. Before consent, Google Fonts (IP to Google, US) and Cloudflare Web Analytics with an RUM beacon load. The lrv.lt platform applies a consent model, but these third-party requests bypass it.

Timeline of the leak

+0 ms · redirect
policija.lt redirects to policija.lrv.lt (the police's own domain on the lrv.lt platform).
+673 ms · Google Fonts before consent
fonts.googleapis.com/css2 and fonts.gstatic.com — the Public Sans font. The visitor's IP goes out to Google (US).
+678 ms · Cloudflare Analytics before consent
static.cloudflareinsights.com/beacon.min.js — Cloudflare Web Analytics.
session state — no consent given
Zero Set-Cookie headers for the entire session, and no user choice was made.
+1204 ms · RUM beacon
POST to policija.lrv.lt/cdn-cgi/rum — transmission of Cloudflare Real User Monitoring data.

Declared versus actual

✓ The lrv.lt platform applies a consent model (necessary cookies — automatic, others — with consent) — declared
✓ A privacy policy was not provided as part of the package — declared
+ Google Fonts (fonts.googleapis.com, fonts.gstatic.com) — IP to Google (US), before consent — not declared
+ Cloudflare Web Analytics (static.cloudflareinsights.com) — before consent — not declared

Transfer timings

+673 ms fonts.googleapis.com

Google Fonts (Public Sans). Google, US.

+678 ms static.cloudflareinsights.com

Cloudflare Web Analytics beacon.

+1204 ms policija.lrv.lt/cdn-cgi/rum

Cloudflare RUM beacon (proxied through the site's own domain).

Detected trackers

Indicators of GDPR non-compliance

Context

policija.lrv.lt is the site of the Police of Lithuania (Policijos departamentas prie Vidaus reikalų ministerijos), hosted on the shared government platform lrv.lt. The short domain policija.lt redirects to it. The data controller is the Police Department. A privacy policy was not provided as part of the package. Scan: 35 requests, 5 domains, captured in a clean browser.

Google (US) — IP via Google Fonts; Cloudflare — IP and RUM data via a beacon.

Declared versus actual

The government platform lrv.lt, on which the police site is hosted, applies a consent model: necessary cookies are set automatically, while others require the user’s consent. A separate privacy policy was not provided as part of this audit.

The scan shows that two third-party services fire before consent that do not fall under “necessary.” At +673 ms, Google Fonts loads (the Public Sans font from fonts.googleapis.com and fonts.gstatic.com), transmitting the visitor’s IP address to Google (US). At +678 ms, Cloudflare Web Analytics loads (static.cloudflareinsights.com/beacon.min.js), and Real User Monitoring data goes out via a POST request to /cdn-cgi/rum at +1204 ms. The session state, meanwhile, is one of no consent: not a single cookie was set during the entire session, and no user choice was made. Both services constitute transmission of data to external recipients (Google and Cloudflare) before consent, and neither is disclosed in the available materials.

Google Fonts and Cloudflare Web Analytics load at +673–678 ms, and the RUM beacon at +1204 ms — at the very start of the session. Consent was not given during the session (zero Set-Cookie headers).

What cannot be claimed from this scan

The scan covers the homepage. Google and Cloudflare may use edge nodes within the EU, so the conclusion regarding the recipients’ affiliation is based on company origin (US companies). Cloudflare Web Analytics operates without cookies; the point of discrepancy is the transmission of IP and RUM data to an external recipient before consent. A separate cookie policy for the lrv.lt platform may contain a list of services; no such policy was provided within this audit. Server-side processing is not visible in a browser-based scan.

Conclusion

The Police of Lithuania’s site transmits the visitor’s IP to Google (via Google Fonts) and to Cloudflare (via Web Analytics with an RUM beacon) before consent. The lrv.lt platform declares a consent model, but these third-party requests bypass it. For a police site, transmitting IP to external recipients in the US before consent constitutes a violation of the requirements on consent, disclosure of recipients, and cross-border transfer. Remediation: host fonts locally on the site’s own domain and forgo external Cloudflare web analytics before consent, or replace it with a solution within the platform’s own perimeter, held back by the consent mechanism.

Evidence
Original (audit)
HAR file: lt/policija-lrv-lt-2026-06-15.har
SHA-256: 3e702e3ef69b68a9ab62c1c272cdf9124dbd381daf154ece0758d5aa372dbdf0
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.
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

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 policija.lrv.lt.

2. Circumstances
I visited the website policija.lrv.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) Before consent, Google Fonts loads (fonts.googleapis.com/css2 and fonts.gstatic.com, the Public Sans font, +673 ms), transmitting the visitor's IP to Google (US), and Cloudflare Web Analytics (static.cloudflareinsights.com/beacon.min.js, +678 ms, with a POST beacon to /cdn-cgi/rum, +1204 ms). The lrv.lt platform applies a consent model (necessary cookies — without consent, others — with consent), but these third-party requests do not fall under 'necessary.'

2) Google Fonts and Cloudflare Web Analytics fire at +673–678 ms, before any choice. No consent manager fired in the scan, and zero Set-Cookie headers were recorded for the entire session. A privacy policy was not provided as part of the package.

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

3. Provisions violated
GDPR Art. 13(1)(e) + Chapter V — disclosure of recipients and transfer; ePrivacy (Lithuanian implementation) — third-party resources before consent

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]