Norway DPA with new cookie ePrivacy guidance
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1 min read
If you're based in Norway, this is a must-read!
CJEU C-654/23 Inteligo Media 27 Mar 2025 AG Opinion
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2 min read
AG Szpunar: If someone creates an online account that includes access to your email newsletters, sending them qualifies as 'direct marketing’ under the ePrivacy Directive Article 13 and is covered by the exception in point 2. Under Article 95 GDPR, a lawful basis under Article 6 isn’t needed.
CJEU C-492/23 Russmedia Digital and Inform Media Press 6 Feb 2025 AG Opinion
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1 min read
AG Szpunar: Marketplace operators are processors for ad data (must protect it) and controllers for advertisers' data (must verify identity). Liability applies if you actively manage, modify or promote content.
Consent or Pay resources
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2 min read
Updated this post to gather some of the Consent or Pay resources while we wait for the EDPB's Guidelines!
CJEU C-252/21 Meta Platforms and Others (General terms of use of a social network) 'Bundeskartellamt' 4 Jul 2023
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6 min read
The 'Bundeskartellamt' ruling, where the CJEU applies 'strictly' to the legal bases necessity test for the first time. 🔥 You might rely on legitimate interest for direct marketing, network security or product improvement, but the processing must now meet this higher threshold.
CJEU C-621/22 KNLTB (legitimate interests) 4 Oct 2024
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3 min read
Article 6(1)(f) allows disclosure for a commercial interest if the processing is *strictly* necessary and not outweighed by the interests, rights or freedoms of the data subjects. The interest doesn't have to be determined by law, but it must be lawful. And CJEU nudges consent again.
Dutch DPA on education sector social media marketing
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4 min read
The DPA stresses that their advice applies generally to all social media and "of great importance" to all educational institutions and similar organisations in 🇳🇱.