website visitor and Google user (data subject and complainant) – Complaint Upheld (Austria, 2021)

Complaint Upheld
Datenschutzbehörde22 December 2021Austria
final
ePrivacy
Complaint Upheld

General GDPR enforcement action

This case relates to broader data protection obligations, not specifically to cookie or consent banner compliance. It is not included in cookie statistics or the Risk Calculator.

An Austrian website was found to have used Google Analytics to track visitors without their consent. The Data Protection Authority upheld a complaint that the website placed third-party cookies before getting permission. This case highlights the importance of obtaining user consent before tracking their online behavior.

What happened

The Data Protection Authority upheld a complaint against a website for using Google Analytics to track visitors without consent.

Who was affected

Website visitors who were tracked by Google Analytics while browsing the site were affected.

What the authority found

The authority found that the website violated GDPR rules by placing third-party cookies without obtaining user consent first.

Why this matters

This case serves as a warning for website operators to ensure they have proper consent mechanisms in place before using tracking tools.

GDPR Articles Cited

AI-verified

Art. 4(1) GDPR
Art. 44(GDPR)
Art. 4(7) GDPR
Art. 4(8) GDPR
Art. 46(2)(c) GDPR
Art. 55(1) GDPR
View original scraped data
Art. 4(1) GDPR
Art. 4(2) GDPR
Art. 4(7) GDPR
Art. 4(8) GDPR
Art. 5(GDPR)
Art. 44(GDPR)
Art. 46(1) GDPR
Art. 46(2)(c) GDPR
Art. 51(1) GDPR
Art. 57(1)(d) GDPR
Art. 57(1)(f) GDPR
Art. 77(1) GDPR
Art. 80(1) GDPR
Art. 93(2) GDPR

Original data from scraper before AI verification against source document.

Entities Involved

website visitor and Google user (data subject and complainant)
Austrian website provider (data exporter and respondent #1)
Google LLC (data importer and respondent #2)
Source verified 9 April 2026
articles corrected
Full Legal Summary
Detailed

= About a month after the "Schrems II ruling" by the CJEU (CJEU - C-311/18 - Schrems II) the NGO noyb filed 101 complaints regarding data transfers from EEA based websites to Google LLC and Facebook Inc. in the U.S (see [https://noyb.eu/en/101-complaints-eu-us-transfers-filed here] and [https://noyb.eu/en/update-noybs-101-complaints-eu-us-data-transfers here]). In order to coordinate the work of all involved DPAs, the EDPB created a [https://edpb.europa.eu/news/news/2020/european-data-protection-board-thirty-seventh-plenary-session-guidelines-controller_en?mkt_tok=eyJpIjoiTVRrMVlqRmpOMlF3TnpCbCIsInQiOiJFekdLKzFydWlOSHpaU1RDUTNUaHVWR2JxTVN4MnRDUm9jYTRkOGRxWG1LSDBWY1lBQkhaM2dsTkdoSEdYNlQrN2lFbm84d1Y3STRWMFlXZk5lM0dzeGFMd2p2NGFjVmltS1wvNnlCSmhrK3Nra1dGcGNjd2lEQWN6UW9EQVdtNmsifQ%3D%3D special task force]. The Austrian DPA (Datenschutzbehörde - DSB) now issued the first decision on one of these 101 complaints. = On 14.08.2020, the data subject visited a website on health topics hosted by an Austrian company while logged into his personal Google account. The website used Google Analytics, a tool provided by Google LLC used to measure and track website use. According to the website provider and Google LLC, the website controller qualifies as controller (Article 4(7) GDPR) and Google LLC as processor (Article 4(8) GDPR) for data processing in connection with Google Analytics. Furthermore, according to the privacy documents provided on the website or included via hyperlink, the website provider and Google LLC entered into standard contractual clauses under Article 46(2)(c) GDPR ([https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=celex%3A32010D0087 Commission Decision2010/87 of 05.02.2010]; SCCs) as a mechanism for transfers of personal data with regard to Google Analytics. On 18.08.2020, the data subject (represented by noyb) filed a complaint with the DSB against both the website provider (in its role as data exporter) and Google LLC (in its role as data importer), argui

Outcome

Complaint Upheld

A data subject complaint that was upheld by the DPA.

Violations (2)

Cookies Placed Before Consent
critical

Non-essential cookies (tracking, advertising) are placed on the user's device before obtaining valid consent.

Art. 6(1) GDPR

Third-Party Cookies Without Consent
critical

Third-party tracking cookies or scripts are loaded without obtaining prior user consent.

Art. 13, 14 GDPR

Related Enforcement Actions (0)

No other enforcement actions found for website visitor and Google user (data subject and complainant) in AT

This is the only recorded action for this entity in this jurisdiction.

Details

Decision Date

22 December 2021

Authority

Datenschutzbehörde

GDPRhub ID

gdprhub-4486

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
AI-verified and classified

Cite as: Cookie Fines. website visitor and Google user (data subject and complainant) - Austria (2021). Retrieved from cookiefines.eu

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