- Enforcing jurisdiction
- Estonia · Geography does not establish applicable law.
- Confirmed applicable legislation
- Privacy topics
DPA case EDPBI:ee:OSS:d:2022:343 – Complaint Upheld (Estonia, 2022)
Privacy enforcement record
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A financial service provider made it impossible for users to register without agreeing to receive marketing messages. The Estonian Data Protection Authority found this practice unacceptable and required the provider to change it. This ruling is a reminder that companies must allow users to control their marketing preferences.
What happened
A financial service provider required users to consent to direct marketing to register on their website.
Who was affected
Users trying to register on the financial service provider's website.
What the authority found
The DPA ruled that the provider's consent process for marketing was flawed and must be corrected.
Why this matters
This case reinforces the need for companies to respect user consent and provide clear options for opting out of marketing communications.
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Automated check recorded — 18 October 2026.
Processing notes: articles corrected, national law identified.
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The data subject was unable to register as a user of the controller’s website without giving consent for direct marketing. The nature and location of the controller was not specified, but it seemed to be some sort of financial service provider. The data subject was also not able to determine to which third parties his contact data was transferred to, how the data was used and for how long the data was stored. The third parties were also not specifically identified on the controller’s website. The data subject filed a complaint at a German DPA (not clear which German DPA) on 2 January 2020, which transferred the complaint on 7 May 2020 to the Estonian DPA (DPA), the lead supervisory authority in this Article 60 GDPR procedure. The DPA sent several inquiries to the controller. The controller clarified that the way its consent procedure for direct marketing was designed was caused by a ‘technical error’. However, the controller had already changed this and it was now possible to register as a user without giving consent to direct marketing. The controller also specified that it asked for a copy of an ID card. It stored personal data included in this ID card. The controller mentioned that the maximum storage period for contact data specifically was 15 years, which was derived from requirements in national law. According to the controller, this data had to be saved for situations when the controller was obligated to submit data to competent supervision authorities, including data regarding offences that may have been committed using the controller's service. The Estonian DPA consulted the German DPA, with regard to storage periods. The German DPA considered several German provisions, but determined that none of these provisions provided a data retention period of 15 years. For example, according paragraph 47 of the German money laundering Act, the controller must retain data for 5 years after the termination of a business relationship, which could be extended to 10 ye
Outcome
Complaint Upheld
A data subject complaint that was upheld by the DPA.
Related Enforcement Actions (0)
No other enforcement actions found for DPA case EDPBI:ee:OSS:d:2022:343 in EE
This is the only recorded action for this entity in this jurisdiction.
Details
About this data
Cite as: Cookie Fines. DPA case EDPBI:ee:OSS:d:2022:343 - Estonia (2022). Retrieved from cookiefines.eu
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