4 ms·

You've hit the nail on the head. A company is only subject to UK law if it operates from the UK. Facebook's European office is in Dublin, which is why it is sub

You've hit the nail on the head. A company is only subject to UK law if it operates from the UK. Facebook's European office is in Dublin, which is why it is subject to Irish/EU privacy legislation.When Twitter establishes its European office, it will similarly become subject to the same laws. As far as I know, Klout has no UK/EU presence so it's not subject to these laws.

alexchamberlain 15y ago
I wonder if this is entirely true... By accepting registration from EU users, are they operating in the EU and thereby subject to EU law?
- cstross 15y ago
  That's my understanding.
- salvadors 15y ago
  I don't believe so. If I walk into a store in New York and tell them I'm from the UK, they won't suddenly become subject to UK/EU law if they choose to serve me. I'm the one subjecting myself to US law if I shop there, not vice versa. Further, even if they were subject to EU law on this, how would any action for a breach be enforced?
  - alexchamberlain 15y ago
    But you are on US soil when you walk into that shop. There are many examples of UK firms not selling to US clients - poker firms, National Lottery...
vidarh 15y ago
> A company is only subject to UK law if it operates from the UK. That's wrong. This is the UK's Crown Prosecution Service advice on the matter: http://www.cps.gov.uk/legal/h_to_k/jurisdiction/ http://www.cps.gov.uk/legal/h_to_k/jurisdiction/ As you can see, it sets out a long range of situations where UK jurisdiction extends outside the UK, in many cases even if the criminal behavior happened entirely outside of the UK. I'm not a lawyer, and I don't know all the details and whether or not it'd be likely to be possible to get a court in the UK to accept jurisdiction in a case against Klout, but courts in the UK have a lot of flexibility and the fact that they are in the US by no means automatically means UK courts won't or can't claim jurisdiction.
- alexchamberlain 15y ago
  Passive personality is particularly interesting.

alexchamberlain 15y ago

I wonder if this is entirely true... By accepting registration from EU users, are they operating in the EU and thereby subject to EU law?

cstross 15y ago
That's my understanding.
salvadors 15y ago
I don't believe so. If I walk into a store in New York and tell them I'm from the UK, they won't suddenly become subject to UK/EU law if they choose to serve me. I'm the one subjecting myself to US law if I shop there, not vice versa. Further, even if they were subject to EU law on this, how would any action for a breach be enforced?
- alexchamberlain 15y ago
  But you are on US soil when you walk into that shop. There are many examples of UK firms not selling to US clients - poker firms, National Lottery...

vidarh 15y ago

> A company is only subject to UK law if it operates from the UK. That's wrong. This is the UK's Crown Prosecution Service advice on the matter: http://www.cps.gov.uk/legal/h_to_k/jurisdiction/ http://www.cps.gov.uk/legal/h_to_k/jurisdiction/ As you can see, it sets out a long range of situations where UK jurisdiction extends outside the UK, in many cases even if the criminal behavior happened entirely outside of the UK. I'm not a lawyer, and I don't know all the details and whether or not it'd be likely to be possible to get a court in the UK to accept jurisdiction in a case against Klout, but courts in the UK have a lot of flexibility and the fact that they are in the US by no means automatically means UK courts won't or can't claim jurisdiction.

alexchamberlain 15y ago
Passive personality is particularly interesting.