by hnbad | 2025-12-16 11:03:16+00:00
Note that this is a pretty blatant GDPR violation and you should report this to the local data protection agency if you are a EU resident and care about this (especially if you've used this extension). Their privacy policy claims the data collection is consent-based and that the app settings also let you revoke this consent. According to the article, the latter isn't the case and the user is never informed of the extent of the collection and the risk of sensitive or specially protected personal information (e.g. sexual orientation) being part of the data they're collecting. Their privacy policy states the collected data is filtered to remove this kind of information but that's irrelevant because processing necessarily happens after collection and the GDPR already applies at the start of that pipeline.

If Urban VPN is indeed closely affiliated with the data broker, a GDPR fine might also affect that company too given how these fines work. There is a high bar for the kind of misconduct that would result in a fine but it seems plausible that they're being knowingly and deliberately deceptive and engaging in widespread data collection that is intentionally invasive and covert. That would be a textbook example for the kind of behavior the GDPR is meant to target with fines.

The same likely applies to the other extensions mentioned in the article. Yes, "if the product is free, you are the product" but that is exactly why the GDPR exists. The problem isn't that they're harvesting user data but that they're being intentionally deceptive and misleading in their statements about this, claim they are using consent as the legal basis without having obtained it[0], and they're explicitly contradicting themselves in their claims ("we're not collecting sensitive information that would need special consideration but if we do we make sure to find it and remove it before sharing your information but don't worry because it's mostly used in aggregate except when it isn't"). Just because you except some bruising when picking up martial arts as a hobby doesn't mean your sparring partner gets to pummel your face in when you're already knocked out.

[0]: Because "consent" seems to be a hard concept for some people to grasp: it's literally analogous to what you'd want to establish before having sex with someone (though to be fair: the laws are much more lenient about unclear consent for sex because it's less reasonable to expect it to be documented with a paper trail like you can easily do for software). I'll try to keep it SFW but my place of work is not your place of work so think carefully if you want to copy this into your next Powerpoint presentation.

Does your prospective sexual partner have any reason to strongly believe that they can't refuse your advances because doing so would limit their access to something else (e.g. you took them on a date in your car and they can't afford a taxi/uber and public transport isn't available so they rely on you to get back home, aka "the implication")? Then they can't give you voluntary consent because you're (intentionally or not) pressuring them into it. The same goes if you make it much harder for them to refuse than to agree (I can't think of a sex analogy for this because this seems obvious in direct human interactions but somehow some people still think hiding "reject all non-essential" is an option you are allowed to hide between two more steps when the "accept all" button is right there even if the law explicitly prohibits these shenanigans).

Is your prospective sexual partner underage or do they appear extremely naive (e.g. you suspect they've never had any sex ed and don't know what having sex might entail or the risks involved like pregnancy, STIs or, depending on the acts, potential injuries)? Then they probably can't give you informed consent because they don't fully understand what they're consenting to. For data processing this would be failure to disclose the nature of the collection/processing/storage that's about to happen. And no, throwing the entire 100 page privacy policy at them with a consent dialog at the start hardly counts the same way throwing a biology textbook at a minor doesn't make them able to consent.

Is your prospective sexual partner giving you mixed signals but seems to be generally okay with the idea of "taking things further"? Then you're still missing specific consent and better take things one step at a time checking in on them if they're still comfortable with the direction you're taking things before you decide to raw dog their butt (even if they might turn out to be into that). Or in software terms, it's probably better to limit the things you seek consent for to what's currently happening for the user (e.g. a checkbox on a contact form that informs them what you actually intend to do with that data specifically) rather than try to get it all in one big consent modal at the start - this also comes with the advantage that you can directly demonstrate when and how the specific consent relevant to that data was obtained when later having to justify how that data was used in case something goes wrong.

Is your now-active sexual partner in a position where they can no longer tell you to stop (e.g. because they're tied up and ball-gagged)? Then the consent you did obtain isn't revokable (and thus again invalid) because they need to be able to opt out (this is what "safe words" are for and why your dentist tells you to raise your hand where they can see it if you need them to stop during a procedure - given that it's hard to talk with someone's hands in your mouth). In software this means withdrawing consent (or "opting out") should be as easy as it was to give it in the first place - an easy solution is having a "privacy settings" screen easily accessible in the same place as the privacy policy and other mandatory information that at the very least covers everything you stuffed in that consent dialog I told you not to use, as well as anything you tucked away in other forms downstream. This also gives you a nice place to link to at every opportunity to keep your user at ease and relaxed to make the journey more enjoyable for both of you.