Douglas asked their customers to give their consent to the privacy notes, the cookie policy, and the General Terms and Conditions all at once. The Data Protection Authority considered this a violation of Article 6 and Article 7 GDPR, as the data subject’s consent could not be considered voluntary due to the lack of separate options for consenting.
Douglas had obtained additional personal data, retained it for an extended period without securing consent from the data subjects, violating the purpose limitation principle.
Further, the data protection authority found that Douglas failed to provide sufficient and accurate information about the data processing and that it did not use the data for direct marketing in accordance with customer consent. For example, customers who had only consented to telemarketing also received SMS marketing messages.
Finally, the Data Protection Authority found that Douglas had breached its accountability obligations regarding the processing of personal data on its blog.
