Recital 23 digs into more detail about what is considered "targeting." Choice quote: > Whereas [...] the use of a language generally used in > the third c

Recital 23 digs into more detail about what is considered "targeting." Choice quote: > Whereas [...] the use of a language generally used in > the third country where the controller is established, > is insufficient to ascertain such intention, factors > such as the use of a language or a currency generally > used in one or more Member States [...] may make it > apparent that the controller envisages offering goods > or services to data subjects in the Union. You are correct that reality is a bit more nuanced, but I think that saying "language and currency have nothing to do with it" is not a supportable claim. Audience and intent matters, but if you have German-language content in a country without a large German-language population, you are going to need a very good excuse why you aren't targeting Germans. People don't have time to type every single caveat and exception. Translating to Polish is going to be targeting Polish geography 99% of the time.