Zu Disain OÜ – Violation Found (Estonia, 2025)

Violation Found
Andmekaitse Inspektsioon6 October 2025Estonia
final
Violation Found

General GDPR enforcement action

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The Estonian land register is publicly accessible and includes information about immovable property and its owners. A company, Zu Disain OÜ (the controller), used an automated solution (i.e. a script) to perform mass queries from the electronic land register. The Estonian DPA (AKI) launched an investigation into the controller for its processing of personal data from the electronic land register. The DPA noted that the controller may primarily rely on legitimate interest (Article 6(1)(f) GDPR) for the processing of personal data through automated queries. However, the DPA found that the controller could not have a legitimate interest for processing the data from the electronic land register due to its main business activity being non-specialised wholesale trade. Thus, the DPA concluded that the controller did not have a legal basis for the processing of personal data from the electronic land register. Furthermore, the controller did not provide an official explanation to the DPA’s inquiry during the investigation. Therefore, the DPA ordered the erasure of all personal data processed by the controller form the electronic land register, or, refusing to do so, a justification regarding the legal basis the controller relies upon for the processing activities. A penalty of €2,000 may be imposed repeatedly if the controller failed to comply with the order.

GDPR Articles Cited

Art. 5(1)(a) GDPR
Art. 6(1) GDPR
Art. 6(1)(f) GDPR
Full Legal Summary

The Estonian land register is publicly accessible and includes information about immovable property and its owners. A company, Zu Disain OÜ (the controller), used an automated solution (i.e. a script) to perform mass queries from the electronic land register. The Estonian DPA (AKI) launched an investigation into the controller for its processing of personal data from the electronic land register. The DPA noted that the controller may primarily rely on legitimate interest (Article 6(1)(f) GDPR) for the processing of personal data through automated queries. However, the DPA found that the controller could not have a legitimate interest for processing the data from the electronic land register due to its main business activity being non-specialised wholesale trade. Thus, the DPA concluded that the controller did not have a legal basis for the processing of personal data from the electronic land register. Furthermore, the controller did not provide an official explanation to the DPA’s inquiry during the investigation. Therefore, the DPA ordered the erasure of all personal data processed by the controller form the electronic land register, or, refusing to do so, a justification regarding the legal basis the controller relies upon for the processing activities. A penalty of €2,000 may be imposed repeatedly if the controller failed to comply with the order.

Outcome

Violation Found

The DPA found a violation but did not impose a fine.

Related Enforcement Actions (0)

No other enforcement actions found for Zu Disain OÜ in EE

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

Details

Decision Date

6 October 2025

Authority

Andmekaitse Inspektsioon

GDPRhub ID

gdprhub-9822

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Data: GDPRhub (noyb.eu)
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Cite as: Cookie Fines. Zu Disain OÜ - Estonia (2025). Retrieved from cookiefines.eu

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