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Spain · Geography does not establish applicable law.
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APOLLONIA TOPCO, S.L. – €30,000 Fine (Spain, 2023)

€30,000Agencia Española de Protección de Datos2 November 2023Spain
final
Fine

Privacy enforcement record

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APOLLONIA TOPCO, S.L. was fined for requiring a customer to submit their driving license for a refund, which was deemed unnecessary. The Spanish DPA found this practice violated data minimization rules, as less intrusive methods could have been used to verify identity. This case underscores the importance of only collecting data that is truly needed.

What happened

The Spanish DPA fined APOLLONIA TOPCO, S.L. for asking a customer to provide their driving license to process a refund.

Who was affected

A customer who filed a complaint about the unnecessary data request was affected.

What the authority found

The DPA determined that the company violated the principle of data minimization by requesting excessive personal information for the refund process.

Why this matters

This case highlights the need for businesses to review their data collection practices and ensure they only ask for information that is essential, promoting better privacy for customers.

Recorded legal citations
Automatically processed
Art. 38 GDPR
Art. 5(1)(c) GDPR
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Art. 5(1) c) GDPR
Art. 38(GDPR)

Original imported citations before automated processing; the processing history does not establish independent verification.

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Linked-source text retrieved.

Automated check recorded — 13 March 2026.

Processing notes: articles corrected, national law identified.

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Full Legal Summary
Detailed

The Spanish DPA has imposed a fine of EUR 30,000 on APOLLONIA TOPCO, S.L.. An individual had filed a complaint with the DPA due to the fact that, in order to receive a refund, they were required to send in their driving license as proof of identity. The DPA considered this to be a violation of the principle of data minimization, as the processing of the data on the driver's license was not necessary for the refund and the identity check could have been carried out with less intrusive means for the privacy of the data subject. In addition, the controller's data protection officer failed to properly respond to a request from the data subject.

Related Enforcement Actions (0)

No other enforcement actions found for APOLLONIA TOPCO, S.L. in ES

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

Details

Fine Date

2 November 2023

Authority

Agencia Española de Protección de Datos

Fine Amount

€30,000

About this data

Data: CMS GDPR Enforcement Tracker
Licensed under CC BY-NC-SA 4.0
Automatically normalized and classified

Cite as: Cookie Fines. APOLLONIA TOPCO, S.L. - Spain (2023). Retrieved from cookiefines.eu

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