C029-43 Sephora SAS
Case projectData Transfers
Case statusPending (3 - 4 years)
This is one of noyb 101 complaints which were filed after the "Schrems II" judgement in Summer 2020. The judgement invalidated the EU-US data transfer mechanism "Privacy Shield". The cases were generated based on implemented Google Analytics or Facebook tracking code on websites by EU providers, which leads to unlawful data transfers to the United States.
CNIL explained their decision after noyb asked for some clarifications
As the controller has stopped using Google Analytics, CNIL closed the case.
CNIL sent us the decision
CNIL sent us the decision.
CNIL confirmed receipt of that request
CNIL informed us that they ordered the controller to bring the processing into compliance with the GDPR
CNIL informed us that they ordered the controller to bring the processing into compliance with the GDPR and cease the use of GA. On the same day, noyb asked to be provided with the actual decision by the CNIL.
noyb asked for an Update
noyb asked for an Update. CNIL replied on the same day, saying that re C029-40 and 43, there will be a decision soon. Re C029-39 and 41 the investigation continues.
CNIL informed us that the complaint continues to be under investigation
CNIL informed us that the complaints C-029-39 to 43 are still being investigated and we will receive updates.
noyb asked the CNIL for an update
noyb wrote an email to the CNIL explaining how the HAR files showed the data transfers that took place
CNIL asked us to make remarks on the case without providing us with the controllers statement
CNIL asked us to make remarks on the case (without us knowing the controller's submission) and reiterated their position not to share the case files with us.
CNIL wrote us saying that the controller has confirmed it implements Google Analytics on their website
CNIL wrote us, saying that the controller has confirmed it implements Google Analytics on their website. CNIL asked noyb for any additional comments within one month.
CNIL replied that they are the the competent authority to begin investigating
CNIL replied that they are the the competent authority to begin investigating. Cannot confirm that there will be no other supervisory authorities involved, however will let us know if there are. Do not want to disclose documents as they are 'administrative'.
noyb sent follow up email
noyb resubmitted all six HAR files
noyb resubmitted all 6 HAR files to the CNIL and received the acknowledgement from them that they got the files on the same day.