AKI US

IQzone, Inc.

Proceedings discontinued
Complaint filed
13.05.2026
Decision
08.06.2026
Time to decision
26 days
Decision number
2.1-1/26/1020-2020-2
GDPR articles
12, 15, 57
Original decision (PDF) ↓
SHA-256: eae4186559075563409916dab42640fc6a02aa54b88a5bf824590366e34e4fea

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

What was in the complaint

An Art. 15 request was sent on 6 April 2026. The 30-day deadline expired on 6 May without a reply.

8 May — IQzone’s CTO Matthew A. Feadler replied in a single sentence: “IQzone does not store any personal data about you”.

8 May — the complainant challenged this technically: the HAR of the site soov.ee recorded identifiers (a UUID and a hash identifier) transmitted to cs.iqzone.com. These are personal data under Art. 4(1) — the Breyer case (C-582/14).

12 May — the CTO replied: “the platform associated with cs.iqzone.com no longer exists — it has been decommissioned, and all associated data has been destroyed”.

Breaches

Art. 12(3) — there was no reply within the deadline.

Art. 15 — “the data has been destroyed” does not meet the requirements: Art. 15 obliges disclosure of all data processed, including historical data, purposes, basis, recipients, periods.

Art. 27 — no representative in the EU appointed.

Destruction of evidence — the company confirmed the destruction of data after the subject’s request.

What AKI decided

Proceedings discontinued. Grounds: Art. 57(1)(f); the controller is in the USA.

Analysis

The complainant presented specific identifiers from the network log. The reply “we decommissioned the platform and destroyed everything” was made after the Art. 15 request. If the data existed at the moment of the request (and the HAR records this), its destruction does not release the company from the obligation to disclose what exactly was being processed.

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