AKI IL

Wix.com Ltd

Proceedings discontinued
Complaint filed
23.04.2026
Decision
17.06.2026
Time to decision
55 days
Decision number
2.1-1/26/769-1568-3
GDPR articles
12, 15, 21, 57
Original decision (PDF) ↓
SHA-256: f9f0efd5eaf95d56b0cd37a516d9ad8dc1b894a26f40d03c73822bb570a6eb84

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
  • no public interest / an individual request
  • the lead authority is another country (Art. 56)

What was in the complaint

Art. 21(3) — direct marketing after a formal objection. The complainant filed an Art. 21 objection to direct marketing on 4 March 2026. Wix continued to send marketing emails — with the complainant’s name and photo — six times from 4 to 25 March. Art. 21(3) is unconditional: after an objection, processing must stop immediately. Wix did not do so for at least 21 days.

Art. 15 — an incomplete reply. The archive was provided on 29 March. An examination of the archive itself showed that Wix’s systems hold data that was not disclosed: a Google OAuth refresh token (access to Google Business without a legal basis) and payment card data (MasterCard, full billing address).

Articles: 21(2)(3), 15, 5(1)(f), 32, 44–46.

What AKI decided

Proceedings discontinued. Grounds: Art. 57(1)(f); the controller is in a third country (Israel).

Analysis

The strongest point here is Art. 21(3). This is one of the few unconditional provisions of the GDPR: after an objection to direct marketing, processing stops immediately, without any balancing of interests. Six emails in three weeks after a formal objection is a direct, unambiguous breach.

On top of that, the finding in the archive itself: Wix stores an access token to the complainant’s Google account and their card data, but did not disclose them in the reply to the request. The evidence was extracted from a document the company itself provided.

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