Digital rights group noyb has filed two complaints in Spain and Germany against Apple's tracking code IDFA. IDFA (Apple's Identifier for Advertisers) allows Apple and all apps on smartphones to track a user and aggregate information about online and mobile behaviour. Noyb argues that Apple places these tracking codes without the knowledge or agreement of the users, whereas such tracking is strictly regulated by the EU 'Cookie Law' (Article 5(3) of the e-Privacy Directive) and requires the users' informed and unambiguous consent. According to the Guardian, as Noyb's complaint is based on the e-Privacy Directive (and not the GDPR), Germany or Spain could decide to directly fine Apple if they agree with the complaint.