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French Privacy Regulator Fines Apple 8 Million Euros for Ad Targeting Violations

On December 29, 2022, France’s privacy regulator (CNIL) imposed an €8 million fine on Apple. The CNIL found Apple in breach of France’s ePrivacy rules for not obtaining mobile users’ consent prior to reading and depositing Identifiers for Advertising (IDFAs) on those users’ devices. Apple has announced that it intends…

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EU Commission Publishes Draft Adequacy Decision on Privacy Shield 2.0

On December 13, 2022, the European Commission published a draft adequacy decision on the EU-US Data Privacy Framework (the “Framework”), the successor to the EU-US Privacy Shield Framework that was famously struck down by Europe’s top court two years ago. While the purpose of the draft adequacy decision, once adopted,…

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EU Standard Contractual Clauses Need Replacing by December 27, 2022

Introduction On June 4, 2021, the European Commission (the “EC”) abolished the old Standard Contractual Clauses (the “Old SCCs”) and published a new more flexible set of clauses (the “New SCCs”) for companies that wish to export personal data from the EU to elsewhere to rely on (for more information,…

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Rulings Awaited Against Both Criteo and IAB Europe: Ongoing Uncertainty for Digital Advertising

On August 5, 2022 news broke that the French Data Protection Authority (“CNIL”) proposes fining adtech company Criteo €60 million for undisclosed GDPR violations as part of an ongoing investigation opened by the CNIL in 2020. The investigation followed a 2018 complaint by the privacy NGO Privacy International against Criteo…

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Use of Google Analytics by EU Websites Violates GDPR

Introduction On 13 January 2022, the Austrian Data Protection Authority (“DSB“) ruled that the use of Google Analytics (“GA”) and the resulting export of personal data to the United States (“US”) violates the GDPR’s data export requirements. On 10 February 2022 the French data protection authority (“CNIL”) also confirmed that…

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The Princeton University Data Access Research: A Timely Reminder to Revisit Data Subject Request Processes

Update: Since going live with the below, the EDPB has published its draft guidelines addressing key aspects of a data subject’s right of access.  More to follow soon. Last month, a large number of EU and US companies received queries about their data access request procedures under the General Data Protection…

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