AEPD (Spain) - PS-00480-2025
Spain's AEPD fines Tiger Media Inc. €72,000 for placing advertising cookies without consent.
Spain's AEPD has fined Tiger Media Inc. €72,000 for violating GDPR and the ePrivacy Directive. The adult ad network placed advertising cookies on users' devices without prior consent, unlawfully relying on legitimate interest as a legal basis. Additionally, the company, not established in the EU, failed to appoint a valid representative within the Union.
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The lesson from this incident
Full lessonTiger Media Inc. placed advertising cookies on users' devices without obtaining prior consent, incorrectly invoking 'legitimate interest' as a legal basis — a justification explicitly prohibited for non-essential tracking cookies under the ePrivacy Directive. This violation compounds GDPR Article 7 requirements, which demand freely given, specific, informed, and unambiguous consent before processing personal data via cookies. Further, as a non-EU-established company targeting EU users, Tiger Media failed to appoint a designated EU representative as required by GDPR Article 27, a structural compliance gap that impedes regulatory accountability. This case highlights that ad networks, regardless of their geographic location, face full GDPR and ePrivacy obligations when processing EU residents' data. Regulators are increasingly scrutinizing cookie consent mechanisms and the accountability structures of non-EU companies.