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The #EDPB published the *long awaited* draft #GDPR Territorial Scope #Guidelines today, which also have a section dedicated to the “legal representative” issue. Some takeaways below ⬇️ Thread time 1/14 edpb.europa.eu/sites/edpb/fil…
An “establishment” of a non-EU entity in the EU doesn't require a registered branch/subsidiary. Any stable arrangements will be taken into account 4 data protection law purposes.But merely the fact that the company’s website is accessible from the EU is not an "establishment"2/14
A processor in the EU is not deemed to be an “establishment” of the non-EU controller in the EU. The existence of the controller-processor relationship does not trigger the application of the #GDPR to the non-EU controller 3/14
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