AKI EE

ESPAK AS

Proceedings discontinued
Complaint filed
22.04.2026
Decision
29.06.2026
Time to decision
68 days
Decision number
2.1-1/26/593-1220-6
GDPR articles
15, 77
Original decision (PDF) ↓
SHA-256: 2c4fed5d6e862878f4e01f772fb899d4ba21a4109381a0989859514c88c248cb

The document is published in full. The complainant's personal data (email address) has been removed from the document.

Grounds for refusal

  • Art. 57(1)(f) — handled "to the appropriate extent"
  • the GDPR does not oblige issuing an order
  • "we take into account that the person can resolve it themselves"
  • no public interest / an individual request

What was in the complaint

Espak AS is a retail chain of building materials with a loyalty-card programme. The complainant is a customer; the card was issued against an ID document in the shop, so the fact of processing is indisputable.

22 February 2026 — an Art. 15 request to info@espak.ee: confirmation of processing (purchase history, profile, segments), a list of third parties, transfers outside the EU, the logic of profiling.

22 March — a reminder from a new address, with proof of the first request attached.

24 March — 30 days expired. No reply at all — neither to the request nor to the reminder.

Article: 12(3).

What AKI decided

Proceedings discontinued. Grounds: Art. 57(1)(f); “we take into account what possibilities the person themselves has to resolve the situation”.

Analysis

The simplest of the cases: an Estonian company, AKI’s full jurisdiction, an indisputable fact of processing (the card was issued against a passport), and complete silence in response to a lawful request. Art. 12(3) was breached obviously.

The regulator closed the case all the same. It is telling precisely because of its simplicity: here there is no disputed reading of a HAR, no unreachable American — there is a local company that simply did not reply. And supervision did not intervene.

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