Zu Disain OÜ – Violation Found (Estonia, 2025)

Violation Found
Andmekaitse Inspektsioon6 October 2025Estonia
final
Violation Found

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.

Zu Disain OÜ faced scrutiny from the Estonian data protection authority for using a script to make mass queries from a public land register. The authority found that the company lacked a valid reason to process personal data in this way.

What happened

Zu Disain OÜ used an automated script to perform mass queries from the electronic land register.

Who was affected

Individuals whose property information was accessed through the land register were affected.

What the authority found

The authority decided that the company did not have a legal basis for processing personal data from the electronic land register.

Why this matters

This case serves as a reminder for businesses to ensure they have a valid reason for processing personal data, especially when using automated tools. Companies should review their data processing practices to comply with legal requirements.

GDPR Articles Cited
Automatically processed
Art. 5(1)(a) GDPR
Art. 6(1) GDPR
Art. 6(1)(f) GDPR
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Art. 5(1)(a) GDPR
Art. 6(1) GDPR
Art. 6(1)(f) GDPR

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Secondary-source text retrieved.

Automated check recorded — 19 March 2026.

Processing notes: articles corrected.

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Full Legal Summary
Detailed

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

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
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Cite as: Cookie Fines. Zu Disain OÜ - Estonia (2025). Retrieved from cookiefines.eu

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