This contradicts Lauristin’s views as you describe them earlier: they implement different articles. Everyone is unclear on the relationship between ePrivacy and GDPR, but I think ePrivacy is *only* Lex Specialis when dealing with privacy issues for personal data transported through electronic means. When subjects are concerned with other rights and freedoms than privacy, the ePrivacy is no longer Lex Specialis, although it is still relevant. For instance ePrivacy consent might have been obtained, (possibly) granting GDPR portability right.