Unfortunately, it's not that clear. Per Recital 23, the service must intend to have EU users, and merely being accessible in the EU is not enough to ascertain t

Unfortunately, it's not that clear. Per Recital 23, the service must intend to have EU users, and merely being accessible in the EU is not enough to ascertain that. It must have some signs, such as accepting European currency or mentioning advantages to European users. Thankfully most sites clearly want to accept money from all currencies, but if this corp didn't charge, it might be difficult to show that they envisaged having EU users.