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This is an excellent example of the problems people are worried about though. Q: is it possible to be in violation of the gdpr in a situation where you could n

• jkaplowitz 9y ago
  The official answer isn't necessarily yes, though. The official answer is more ambiguous than that - "offering" can mean what you think it means, but it can also mean what the official guidance says. Also, both answers are official and from the EU institutions. One is the law, and the other is meant to help interpret and apply the law. I'm not talking about third party compliance guides (except for the link I shared), of which there are many. With all of that said... If you have both taken steps to avoid serving EU countries AND have also done things which they view as targeting EU countries, the answer would be murkier. For example, if you block European IP addresses but also use .de and .fr IP addresses and accept Euros, they might consider it to apply despite the IP block. I'm also not sure what would happen if you took no explicit steps to target, but saw 80% of your customers coming from Europe on a sustained basis and did nothing to stop that. Overall, the law will be interpreted with its own intent in mind: it should apply if you're engaging with Europe, but not automatically globally. I understand if you want more certainty, but that's how computer programs operate, not laws.