Technical audit · 29.08.2026

ast.lv

Website of Latvia's electricity transmission system operator

Corporate website of Latvia's electricity transmission system operator — one recording, 49 requests, five nodes. There is no active analytics or advertising: no Google Analytics, no Tag Manager, no advertising services, no social pixels. But three third-party nodes nonetheless receive the visitor's IP address without consent and without disclosure: Google Fonts (the Open Sans font), the AddToAny share-buttons widget, and Cloudflare telemetry. Meanwhile the privacy notice names only Google Analytics as a recipient — which is precisely what is absent from the recording — and does not mention the actual recipients. During capture the browser sent a DNT: 1 header.

Request timeline

+0 ms · navigation
Opening of the site. A move from http to https (307), then to the language version /lv (301→200). A Drupal 11 application, delivered via Cloudflare (cf-ray …-TLL, Tallinn). Headers: Referrer-Policy same-origin, X-Frame-Options SAMEORIGIN, X-Content-Type-Options nosniff, X-XSS-Protection, Expect-CT enforce; some responses carry a Content-Security-Policy in report-only mode. The browser sent a DNT: 1 header.
+467 ms · Google Fonts
fonts.googleapis.com/css?family=Open+Sans — the font descriptor, initiated by the markup of the /lv page. It is followed, at +752…+1100 ms, by three .woff2 font files from fonts.gstatic.com. On these requests the visitor's IP address becomes visible to Google.
+561 ms · AddToAny
static.addtoany.com/menu/page.js — the script of the share-buttons widget, then its core.js module and the sm.25.html menu. The widget loads only its own static assets; there are no outbound requests carrying identifiers or pixels from it in the recording. The visitor's IP address is visible to the AddToAny server when the script loads.
+562 ms · provider telemetry and protection
static.cloudflareinsights.com/beacon.min.js — Cloudflare RUM; then /cdn-cgi/challenge-platform (a bot check) and /cdn-cgi/rum (204). This is the delivery provider's infrastructure, first-party by domain.
· during the session · internal data
Repeated requests to /lv/ajax/charts/imports-exports — the site's internal AJAX, data for the electricity import-export charts. First-party, it does not go out.

Declared versus actual

✓ Controller — JSC Augstsprieguma tīkls (AST), Rīga, Dārzciema iela 86; data-protection specialist DPO@ast.lv — declared
✓ Cookies are used for website functionality, visit statistics (number of visitors, time spent on the site) and improving operational efficiency — declared
✓ The server registers the visitor's requests (open addresses, device and browser, IP address, access time) for technical purposes only — declared
✓ AST does not use cookies to track user habits, so it informs about cookies but does not request consent to place them — declared
✓ The site may contain third-party cookies, in particular google analytics; the tool belongs to Google Inc. (US), which has adhered to the EU-US Privacy principles — declared
✓ A transfer of data outside the EU is possible when using external storage solutions; in that case standard contractual clauses apply — declared
+ Google Fonts — transmission of the visitor's IP address to Google when the Open Sans font is loaded; the recipient is not named — not declared
+ AddToAny — a third-party share-buttons widget; the recipient is not named — not declared
+ Cloudflare — RUM telemetry and bot protection of the delivery provider; not named — not declared
+ Google Analytics, named in the policy as being used, is in fact absent from the recording — not declared

Transfer timings

+467 ms fonts.googleapis.com

Open Sans font descriptor. The visitor's IP address is visible to Google.

+561 ms static.addtoany.com

Share-widget script. The IP address is visible to the AddToAny server; there is no outbound data carrying identifiers.

+562 ms static.cloudflareinsights.com

beacon.min.js — Cloudflare RUM, first-party by infrastructure.

+752 ms fonts.gstatic.com

Open Sans .woff2 font files. The visitor's IP address is visible to Google.

Detected trackers

Indicators of GDPR non-compliance

Context

ast.lv is the corporate website of JSC Augstsprieguma tīkls (AST), Latvia’s electricity transmission operator (the high-voltage backbone grid). The controller’s address is Rīga, Dārzciema iela 86, LV-1073; the data-protection specialist’s contact is DPO@ast.lv. The site is built on Drupal 11 and delivered via Cloudflare (cf-ray with the TLL label — Tallinn). The set of security headers on the home page is decent: Referrer-Policy same-origin, X-Frame-Options SAMEORIGIN, X-Content-Type-Options nosniff, X-XSS-Protection, Expect-CT in enforce mode; some responses carry a content security policy in report-only mode.

Processing is described by the AST privacy notice (bilingual, English and Latvian parts). The site itself is addressed directly by the “Cookies” and “Cookies of third parties” sections.

The measurement consists of one recording: the home page with a transition to the language version /lv. Forty-nine requests, five nodes. The recording was made on 15 June 2026.

Who data goes to directly

Google (Fonts), AddToAny; Cloudflare — as the delivery provider. There is no active analytics or advertising in the recording.

Declared versus actual

The cookie section of the notice describes the processing narrowly: cookies are used for functionality, visit statistics and improving efficiency; the server registers technical request data (address, device, browser, IP, time) for technical purposes; consent for cookies is not requested, since AST “does not track user habits.” A separate section on third-party cookies names exactly one external tool: “the website may contain third-party cookies, in particular google analytics,” noting that the tool belongs to Google Inc., US.

The measurement yields a discrepancy in both directions at once.

The named recipient does not operate in the recording. There is not a single request to google-analytics.com or googletagmanager.com, not a single measurement identifier (properties of the form G-, AW-, UA-, GTM-) in the recording. Google Analytics, the only third-party tool named by name in the policy, is in fact not engaged on the observed page.

The actual recipients are not named. Instead, the recording contains three other external nodes. The first is Google Fonts: at +467 ms the page markup requests the Open Sans font descriptor from fonts.googleapis.com, followed at +752…+1100 ms by three font files from fonts.gstatic.com. On these requests the visitor’s IP address becomes visible to Google. The second is AddToAny: at +561 ms the script of the share-buttons widget (static.addtoany.com/menu/page.js), its module and menu are loaded; the widget loads only its own static assets and makes no outbound requests carrying identifiers or pixels in the recording, but when its script loads the visitor’s IP address is visible to the AddToAny server. The third is Cloudflare telemetry (static.cloudflareinsights.com) and its bot protection (/cdn-cgi/challenge-platform, /cdn-cgi/rum), the delivery provider’s infrastructure. Neither Google Fonts, nor AddToAny, nor Cloudflare is mentioned in the privacy notice.

There is no consent for the third-party requests. The policy removes the question of consent outright, citing the absence of habit tracking. But the requests to Google Fonts and AddToAny go out automatically as the page is parsed, before any user action, and transmit the IP address to third-party services. There is no choice or consent mechanism for these requests on the site. This is not analytics tracking with a user identifier, but the transmission of the IP address to third parties without disclosure and without consent is present.

The internal requests to /lv/ajax/charts/imports-exports are the site’s own AJAX (data for the electricity import-export charts), first-party, and do not go out.

Proven: there is no active third-party analytics or advertising in the recording. No requests to Google Analytics, Google Tag Manager, advertising services, social networks or RTB infrastructure arise; measurement identifiers are absent from the addresses.

Proven: the third-party resources load without consent. Google Fonts (+467 ms) and AddToAny (+561 ms) are requested from the page markup automatically, before the user could make any choice; there is no consent-management platform in the recording.

Proven: the visitor’s IP address becomes available to Google and AddToAny. This follows from the very fact of the browser’s requests to fonts.gstatic.com, fonts.googleapis.com and static.addtoany.com — on any network request the sender’s IP address is visible to the receiving server.

Not proven and not asserted: any analytics payload from AddToAny. In the recording the widget only loads its own static assets and sends no requests carrying identifiers. Whether AddToAny collects data by other means beyond the observed page is not established by a browser measurement and is not part of the conclusion.

Separately: during capture the browser sent a DNT: 1 header. This had no effect on the composition of the requests.

Bounds of observation

The measurement covers a single page — the home page with a transition to the language version. Observation captures the browser’s behaviour, not the internal side of the services: server-side processing and contractual relationships with recipients are not verified by a browser measurement. The legal assessment is made by the competent authority — in Latvia, Datu valsts inspekcija.

The file is published redacted under a “lean” profile: cookie values in requests have been removed, the Cookie and Set-Cookie headers stripped, response bodies and static resources cut. The response headers in this file are preserved, so the set of security headers and the composition of nodes are verified from the recording directly. Full addresses and identifiers are not reproduced in the analysis; the conclusion about the visibility of the IP address to third-party servers rests on the very fact of network requests to their domains.

The identification of services relies on domains and address patterns: Google Fonts — by fonts.googleapis.com and fonts.gstatic.com with the Open Sans font path; AddToAny — by static.addtoany.com and the widget paths /menu/; Cloudflare — by cloudflareinsights.com and the /cdn-cgi/ paths. The absence of Google Analytics is established by the absence of requests to its domains and of measurement identifiers in the addresses.

Conclusion

The corporate website of Latvia’s electricity transmission operator runs no active analytics or advertising: there is no Google Analytics, no Tag Manager, no advertising services and no social pixels in the recording. Nonetheless, three third-party nodes do receive the visitor’s IP address without consent and without disclosure: Google Fonts when the Open Sans font is loaded, the AddToAny share-buttons widget, and Cloudflare telemetry. The privacy notice, meanwhile, names Google Analytics as the sole third-party tool — which is precisely what is absent from the recording — and does not mention the actual web recipients at all; what is named is not what operates, and what operates is not named. Consent for the third-party requests is not sought, although they go out automatically when the page opens.

Remediation: host the Open Sans font on the site’s own domain to stop the transmission of the IP address to Google Fonts, or place its loading under consent management; name the actual third-party web recipients in the privacy notice — Google Fonts, AddToAny, Cloudflare — with the nature of the transmission stated, and remove Google Analytics, which is not used on the site, from the document, or bring the document into line with the actual set of services; for third-party resources that transmit the IP address, provide a consent mechanism or refrain from loading them before consent.

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: lv/ast-lv-2026-06-15.har
SHA-256: 4e34a2b537b3e15592eb37e683a1e0a917066140fe887a323bf3bef68bbf0bfe
Re-check snapshot
Awaiting changes
HAR files are stored on EU infrastructure (Proton Drive). SHA-256 is published for integrity verification.