The EDÖB has, tog­e­ther with Order of April 17, 2026 An inve­sti­ga­ti­on under Art. 49 of the Data Pro­tec­tion Act (DSG) against Cream del­la Cream Switz­er­land and Phil­ipp Plein Inter­na­tio­nal (both head­quar­te­red in Switz­er­land) has been con­clu­ded. The two com­pa­nies ope­ra­te the online retail busi­ness for the Phil­ipp Plein brand and are listed as data con­trol­lers in the pri­va­cy poli­ci­es. The decis­i­on was published on June 26, 2026, and, accor­ding to the FDPIC, is legal­ly binding.

This was prompt­ed by seve­ral com­plaints from peo­p­le who, after shop­ping, Adver­ti­sing via Email and Text Mes­sa­ge had recei­ved wit­hout having given their con­sent. The text mes­sa­ges did not pro­vi­de a simp­le way to unsub­scri­be, and the unsub­scri­be links in the emails did not lead to an opti­on to unsub­scri­be. In the event of an objec­tion or a request for dele­ti­on, the request remain­ed unans­we­red or the Dele­ti­on was con­firm­ed; the ad was not remo­ved in eit­her case. Two infor­mal inter­ven­ti­ons The EDÖB’s requests in Decem­ber 2023 and Octo­ber 2024 went unans­we­red, and the par­ties had not sub­mit­ted any state­ments during the inve­sti­ga­ti­on pro­ce­e­dings either.

In this case, the EDÖB makes short work of the mat­ter: Pro­ce­s­sing data in spi­te of the objec­tion con­sti­tu­tes a vio­la­ti­on of per­so­nal rights (Art. 30(2)(b) of the Data Pro­tec­tion Act). In addi­ti­on, the EDÖB found a vio­la­ti­on of good faith (Art. 6(2) of the Data Pro­tec­tion Act): Anyo­ne who con­firms dele­ti­on and yet con­ti­nues to send adver­ti­sing is acting in bad faith. Fur­ther­mo­re, the prin­ci­ples of pur­po­se limi­ta­ti­on and pro­por­tio­na­li­ty give rise to a right to era­su­re unless a sta­tu­to­ry reten­ti­on obli­ga­ti­on or an over­ri­ding inte­rest justi­fi­es fur­ther processing.

The order requi­res the com­pa­nies to cea­se pro­ce­s­sing per­so­nal data for adver­ti­sing pur­po­ses within 30 days of the order beco­ming final in the event of a past or future objec­tion, to dele­te per­so­nal data upon request, unless the­re is an over­ri­ding inte­rest (a reser­va­ti­on that is eit­her not sub­ject to con­trac­tu­al modi­fi­ca­ti­on or rai­ses inte­re­st­ing que­sti­ons regar­ding enforce­ment), and to cea­se pro­ce­s­sing the data of indi­vi­du­als who have alre­a­dy objec­ted. The order is issued under thre­at of a penal­ty pur­su­ant to Art. 63 of the Data Pro­tec­tion Act (DSG). The fee amounts to CHF 5,500.

Art. Art. 3(1)(o) UWG (mass elec­tro­nic adver­ti­sing gene­ral­ly per­mit­ted only with con­sent) was not taken into account by the EDÖB (alt­hough it would not be far-fet­ched to view a vio­la­ti­on of Art. 3(1)(o) UWG as unlawful data processing).