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Reddit is worse. They will just flat out ignore you. HN isn't much better. I've emailed them asking for my data to be removed, as is my right as an EU citizen
by counttheforks 4y ago
Reddit is worse. They will just flat out ignore you.
HN isn't much better. I've emailed them asking for my data to be removed, as is my right as an EU citizen and dang simply refused saying it wouldn't be fair to other users. As if that overrides the law.
- denton-scratch 4y agodang is not subject to EU law.
- ceejayoz 4y agoHe's likely subject to California law, though. California residents might get a different answer to such a request. https://oag.ca.gov/privacy/ccpa https://oag.ca.gov/privacy/ccpa > Right to delete: You can request that businesses delete personal information they collected from you and tell their service providers to do the same, subject to certain exceptions (such as if the business is legally required to keep the information).
- pc86 4y agoYes, this is how legal jurisdictions work. He can receive one request from someone in Mississippi, one from someone in California, and one from someone in the EU, and provide three completely different responses.
- ceejayoz 4y agoYes, but he doesn't have to. One of my clients willingly applies GDPR to everyone, regardless of jurisdiction. If you want your data, you can get it. If you want your stuff deleted, you can do so. I think this is the ethical approach.
- GabrielTFS 4y agoIt is also, from what I know, the legal approach. The EU perhaps doesn't have jurisdiction over a service, but what they can do is ask all the ISPs in Europe to block access to it, for example.
- ciupicri 4y agoIf I'm not mistaking if your site operates in the EU as in it's accessible from the EU, you have to comply with GDPR. It's the reason I can't read some American websites. The infamous: > Unfortunately, our website is currently unavailable in most European countries. We are engaged on the issue and committed to looking at options that support our full range of digital offerings to the EU market.
- counttheforks 4y agoThis, and also ycombinator has investments in the EU
- denton-scratch 4y agoBeing accessible from the EU doesn't make your business subject to EU law. The EU doesn't claim universal jurisdiction. Those US newspaper sites you can't access: well, you can access them via archive.org.
- manuelmoreale 4y agoFrom this point of view, can the entire freedom of speech in the US be solved if a company simply moves the headquarters to the EU because at that point US laws no longer apply? > Being accessible from the EU doesn't make your business subject to EU law. The EU doesn't claim universal jurisdiction. Collecting data related to EU individuals does make you subject to the specific GDPR law though, unless I'm mistaken.
- debugnik 4y agoI believe he does have a cop-out if HN isn't selling to or marketed towards the EU, but I thank you for sharing your experience because I'm looking to shut my account in the near future.
- i_am_jl 4y ago>I believe he does have a cop-out if HN isn't selling to or marketed towards the EU Nope, GDPR attaches regardless of whether you market in the EU/to EU residents, as long as you provide goods or services to people in the EU you're beholden to their rules. Theoretically, a company that only offers services to US residents (mortgage/banking/legal) could still be beholden to GDPR, since their cardholders might access their website (i.e. be provided services) while in Europe, though as far as I know it's never been tested in court.
- pc86 4y agoRespectfully, this is utter nonsense. The EU has full jurisdiction within the EU, and zero without. The EU has no ability to demand action or inaction from an entity in the United States. They can ask all they want but it's just that - a request.
- Bouncingsoul1 4y agoRespectfully, this is also not correct. "The EU has full jurisdiction within the EU, and zero without" like in software there are always corner cases, as with e.g. Norway or Liechtenstein. Also on some more specific stuff via bilateral agreements. Has nothing to do with this case, but still your statement is false
- pc86 4y agoIs it though? Isn't the enforcement authority in Norway still the Norwegian government and not the EU? Can't Norway vote to rescind that bilateral agreement?
- manuelmoreale 4y ago
- batch12 4y ago> HN isn't much better. I've emailed them asking for my data to be removed, as is my right as an EU citizen and dang simply refused saying it wouldn't be fair to other users. As if that overrides the law. Please read this in good faith: If you want your data gone, why do you keep sending more (posting)? Is it about retention time?
- counttheforks 4y agoIt's personal. And also regarding a different account than this one.
- pc86 4y agoAnd the idea that the EU has any jurisdiction is California is completely outside the law.
- wizzwizz4 4y agoI think dang might be covered under legitimate interest (unlike pretty much everyone who tries to claim the "legitimate interest" basis). Personal data, yeah, your interests probably override it – but blanket deletion of your posts, probably not.
- eigenvalue 4y agoIf I were dang, I would disable your account so you can no longer log in and post. But the moment you’ve made an intentional public post on a public forum hosted in a foreign country, from my perspective you have lost any and all moral right to demand anything whatsoever in regards to your previous posts, no matter the absurd overreaching of your domestic regulators.
- counttheforks 4y agoThe law is the law. Your perspective is irrelevant.
- eigenvalue 4y agoYes, I’m pointing out that you are acting in bad faith and your continued presence on this site shouldn’t be tolerated given your repeated outbursts against the admins. Your perspective on my viewpoint is irrelevant.
- counttheforks 4y agoAsking for the law to be followed is an "outburst"? Okay buddy. You americans are really far gone.
- rootusrootus 4y agoIs HN hosted in the EU? If not, then the law is in fact not the law.
- kova12 4y agoSomething tells me there is an untold story behind...
- helmholtz 4y agoNah. Had the same thing happen to me. I once asked dang to delete my account, and he stated much the same to me. In his defence, he was polite, and offered to rename my account to a random name, dissociating me from it. He also On the other hand, I agree with GP. It's surprising that you cannot delete an account. That HN stay "readable" without the [deleted] is clearly secondary to the possibility of having an account be deleteable. Imagine if I were part of an at-risk group.
- dspillett 4y agoWhat data have you asked to be removed? If it is PII then EU laws like GDPR apply, but if it is posts more generally then they are not covered, and it would be unfair to people who have responded to them and those reading those responses later (sans context, if your post were removed). The right to be forgotten covers information about you, not information by you (with an edge-case that if somehow your words in a post unambiguously identify you, that post falls into the first category as well as the second so is covered).