ZMLUK Limited – €122,850 Fine (United Kingdom, 2025)

€122,850Information Commissioner's Office11 December 2025United Kingdom
final
ePrivacy
Fine

ZMLUK Limited was fined for not giving users clear choices about cookies and for placing cookies on their devices without consent. This is significant because it emphasizes the need for transparency in how companies use cookies. Small businesses should ensure they offer clear options for users to consent to cookies to avoid fines.

What happened

ZMLUK Limited placed cookies on users' devices without obtaining proper consent and failed to provide clear cookie information.

Who was affected

Users whose devices had cookies placed by ZMLUK Limited without their informed consent were affected.

What the authority found

The Information Commissioner's Office found that ZMLUK Limited violated ePrivacy rules by not obtaining valid consent for cookie usage.

Why this matters

This case reinforces the importance of clear cookie consent mechanisms and transparency for businesses using cookies for marketing.

National Law Articles
AI-identified
Article 22 UK PECR

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Full Legal Summary
Detailed

ZMLUK Limited (the controller) is a financial intermediation and advertising agency. The DPA received several complaints relating to marketing emails sent in 2023 by the controller. The controller specified that it obtained the personal data used in sending the emails through customer activity, thus relying on Article 22(3) the Privacy and Electronic Communications (EC Directive) Regulations 2003 (UK PECR), the transposition into UK law of the E-Privacy Directive 2002/58/EC. Furthermore, it also obtained personal data for direct marketing purposes from a third-party provider, in which case it relied on consent under Article 22(2) UK PECR. The controller further alleged that the data subjects who filed complaints with the DPA had opted in to receiving marketing communications. The DPA’s inspection of a third-party website providing personal data to the controller showed that it was unclear whether individuals could consent to specific third parties for direct marketing, out of the 300 plus organisations listed. The DPA analysed if the controller obtained valid consent for sending direct marketing, as well as if the controller was able to rely on the exception to the consent rule. Firstly, the DPA found that the consent was not informed, since data subjects were unable to select which companies they wished to receive marketing from, out of over 300 entities listed, on the third-party website. Alternatively, the DPA explained that the exception to the consent rule for direct marketing can only be relied upon by the controller that collected the contact details of the data subject. In this case, the controller obtained the data from a third party and thus could not rely on the exception. Therefore, the DPA found that the controller violated Article 22 UK PECR by sending over 67 million emails using data sourced from third parties for the purposes of direct marketing without valid consent. The DPA fined the controller GBP 105,000 (approximately €120,000).

Violations (4)

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

Unclear Cookie Information
high

The cookie banner or cookie policy provides vague, incomplete, or unclear information about what cookies are used and why.

Art. 12, 13 GDPR

No Granular Cookie Choice
high

Users cannot select or deselect individual cookie categories; consent is presented as all-or-nothing.

Art. 4(11) GDPR

Related Enforcement Actions (0)

No other enforcement actions found for ZMLUK Limited in UK

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

Details

Fine Date

11 December 2025

Authority

Information Commissioner's Office

Fine Amount

€122,850

105,000 GBP

GDPRhub ID

gdprhub-9758

About this data

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

Cite as: Cookie Fines. ZMLUK Limited - United Kingdom (2025). Retrieved from cookiefines.eu

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