Mr. A.A.A. v. Aranow Packaging Machinery

€3000 in fines


ARANOW PACKAGING MACHINERY, S.L was fined by AEPD for violations related to its Cookie Policy. AEPD conducted an investigation that included an examination of the information provided in the Cookie Policy, including details on the use of cookies and data collected. AEPD also looked for any mechanism to reject all cookies, but found none.

Our analysis

A complaint was filed against the website ***URL.1 for not complying with data protection regulations, specifically for not having a Privacy Policy, a contact page, and a Cookie Policy in accordance with the current legislation. After examining the Privacy and Cookie policies, the AEPD found that the Privacy policy complied with Article 13 GDPR but the Cookie policy did not align with Article 22.2 LSSI. The website lacked a mechanism to reject all cookies, and there was no link to different browsers to deactivate or delete cookies, which was deemed contrary to legal provisions. Forced action deceptive design was used in this case by not providing users with an option to reject all cookies, which would require them to actively take steps to disable cookies individually in their browser settings. This design effectively forces users to accept cookies as the default option, even if they may not want them. This violates the principle of informed consent, as users are not provided with a genuine choice over whether or not to accept cookies.


ARANOW PACKAGING MACHINERY, S.L was fined by AEPD for violating the rights of service recipients by using cookies without providing necessary information as per Article 22.2 of the LSSI. The company was fined EUR 3000 but used two attenuating factors from the LPACAP to reduce the penalty, resulting in a reduced fine of EUR 1800.


Mr. A.A.A. and Aranow Packaging Machinery

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