Freedom Finance Europe Ltd – Complaint Upheld (Cyprus, 2025)

Complaint Upheld
DPA Commissioner22 January 2025Cyprus
final
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.

The controller is Freedom Finance Europe Ltd, operating under the Freedom24 brand. It is an online investment banking firm that assists clients in investing in the stock market, whose main establishment is in Cyprus. In November 2022, the data subject submitted an erasure request to Freedom Finance Germany TT GmbH, a subsidiary of the controller located in Germany. He requested the cancellation of his account, the erasure of his data and to stop receiving advertising emails from the controller. On the same day the data subject received a reply from customer support informing him that he would need to log into his account for identification in order to proceed with the closure of his account. The data subject contacted the controller again, demanding the deletion without logging in to his account, but he did not receive another reply and his account was not deleted; rather, he was still receiving relevant emails. The data subject lodged a complaint with the Berlin DPA (Data Protection Authority for the German state of Berlin- BlnBDI) regarding the controller’s failure to comply with his erasure request. The complaint was subsequently transmitted to the Cypriot DPA (Commissioner for Personal Data Protection), as the supervisory authority of the main establishment of the controller (lead authority), pursuant to Article 56 GDPR. The controller claimed that its response to the data subject’s request was clear and provided all necessary instructions for the identification process in order to cancel his account. The data subject’s second request was similar to the first one so there was no need to provide the same response. In any case, this process was clearly described in its general terms of business which the data subject had accepted. Furthermore, the controller claimed that on February 2024 it closed the data subject’s account and sent him a notification email, including the information relating to GDPR on the retention of personal data for 7 years. The DPA sta

GDPR Articles Cited

Art. 17 GDPR
Art. 56 GDPR
Art. 12(2) GDPR
Art. 12(4) GDPR
Full Legal Summary

The controller is Freedom Finance Europe Ltd, operating under the Freedom24 brand. It is an online investment banking firm that assists clients in investing in the stock market, whose main establishment is in Cyprus. In November 2022, the data subject submitted an erasure request to Freedom Finance Germany TT GmbH, a subsidiary of the controller located in Germany. He requested the cancellation of his account, the erasure of his data and to stop receiving advertising emails from the controller. On the same day the data subject received a reply from customer support informing him that he would need to log into his account for identification in order to proceed with the closure of his account. The data subject contacted the controller again, demanding the deletion without logging in to his account, but he did not receive another reply and his account was not deleted; rather, he was still receiving relevant emails. The data subject lodged a complaint with the Berlin DPA (Data Protection Authority for the German state of Berlin- BlnBDI) regarding the controller’s failure to comply with his erasure request. The complaint was subsequently transmitted to the Cypriot DPA (Commissioner for Personal Data Protection), as the supervisory authority of the main establishment of the controller (lead authority), pursuant to Article 56 GDPR. The controller claimed that its response to the data subject’s request was clear and provided all necessary instructions for the identification process in order to cancel his account. The data subject’s second request was similar to the first one so there was no need to provide the same response. In any case, this process was clearly described in its general terms of business which the data subject had accepted. Furthermore, the controller claimed that on February 2024 it closed the data subject’s account and sent him a notification email, including the information relating to GDPR on the retention of personal data for 7 years. The DPA sta

Outcome

Complaint Upheld

A data subject complaint that was upheld by the DPA.

Related Enforcement Actions (0)

No other enforcement actions found for Freedom Finance Europe Ltd in CY

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

Details

Decision Date

22 January 2025

Authority

DPA Commissioner

GDPRhub ID

gdprhub-9450

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Data: GDPRhub (noyb.eu)
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Cite as: Cookie Fines. Freedom Finance Europe Ltd - Cyprus (2025). Retrieved from cookiefines.eu

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