D.A.A.A (Claimant) on behalf of Neptunos Formación, S.L. v. Iweb Internet Learning, S.L.

€7,800 voluntary fine


Iweb Internet Learning, S.L. was fined by the Spanish Data Protection Agency for failing to identify the data controller, not allowing separate consent for each purpose, and providing insufficient information on the use of cookies.

Our analysis

The AEPD initiated a sanction procedure against the defendant after receiving a complaint from Neptunos Formación, S.L., which highlighted the absence of any information on the identity of the defendant on their website. The AEPD investigated whether the defendant had complied with the applicable laws, specifically whether the privacy policy provided information on the data controller and whether the website offered a choice for users to provide specific and separate consent for each purpose. However, this information was not readily available on the website. Furthermore, the website did not include any banner or information on the use of cookies. The AEPD found the defendant in potential violation of Article 13 GDPR, Article 7 GDPR, and Article 22(2) LSSI due to their bundling of information and hidden presentation of key details.


The AEPD found that the defendant had violated Article 13 GDPR, Article 7 GDPR, and Article 22(2) LSSI by not identifying the data controller, not providing a separate consent option for each purpose, and not providing sufficient information on the use of cookies. The AEPD determined that, due to aggravating circumstances such as the defendant's intentionality and the length of time the violations occurred, a fine of €13,000 would be imposed if the sanction procedure was successful. However, the AEPD offered the defendant the opportunity to settle the matter by voluntarily paying part of the fine and acknowledging its liability before a final decision was made. The defendant agreed, and the AEPD closed the sanction procedure.


Neptunos Formación, S.L. and Iweb Internet Learning, S.L.

Case number


Related deceptive patterns

Related laws

Legal enforcement database by Leiser, Santos and Doshi

The information about laws and cases on this website is brought to you by the Leiser, Santos and Doshi enforcement database.

About us