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No B2C tech company can avoid doing business involving EU member state or UK citizens. You have to assume you’re in-scope unless you have zero contacts with Europe.


I thought it was EU/UK residents, rather than citizens. Even if all of your users are US citizens, some US citizens reside in Europe.


Neither residence nor citizenship are tests for GDPR’s territorial application.

It applies to any data collected in the Union: https://gdpr-info.eu/art-3-gdpr/




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