10 ms·

A good reminder of how things actually work, but the article could use some more balancing… > Let that sink in. You scanned your European passport for a Europe

by csmpltn 7mo ago

A good reminder of how things actually work, but the article could use some more balancing… > Let that sink in. You scanned your European passport for a European professional network, and your data went exclusively to North American companies. Not a single EU-based subprocessor in the chain. LinkedIn is an American product. The EU has had 20 years to create an equally successful and popular product, which it failed to do. American companies don’t owe your European nationalist ambitions a dime. Use their products at your own discretion. Of course an American company is subject to American law. And of course an American company will prioritise other local, similar jurisdiction companies. And often times there’s no European option that competes on quality, price, etc to begin with. In other words I don’t see why any of this is somehow uniquely wrong to the OP. > Here’s what the CLOUD Act does in plain language: it allows US law enforcement to force any US-based company to hand over data, even if that data is stored on a server outside the United States. European law enforcement agencies have the same powers, which they easily exercise.

47282847 7mo ago
> European law enforcement agencies have the same powers. No they don’t, not in the way that is implied here. A German court can subpoena German companies. Even for 100% subsidiaries in other European or non-European countries, one needs to request legal assistance. Which then is evaluated based on local jurisdiction of the subsidiary, not the parent. Microsoft Germany as operator is subject to US law and access. See Wikipedia “American exceptionalism” for further examples.
kleiba 7mo ago
One detail you might have overlooked: even if you're an American company - if you offer your services in Europe (through the web or otherwise), you're subject to European laws and regulations, including the GDPR.
- rrr_oh_man 7mo ago
  "Sue me" is what a purely cis-Atlantean company might say.
  - wolvoleo 7mo ago
    Which is of course exactly what is happening with the likes of Google and Meta.
    - rrr_oh_man 7mo ago
      ...both of which have offices in the EU.
    - csmpltn 7mo ago
      Google and Meta don't need to show up to court :)
birdsongs 7mo ago
> In other words I don’t see why any of this is somehow uniquely wrong to the OP. Did you read the article? It's a dark pattern. It is an act that takes 3 minutes to perform. Yet it takes multiple days of reading legal documents to understand what actually happens. I would argue this feels wrong, to most people who interact with technology. We have a set of laws here that companies are obliged to follow, regardless of where they are incorporated, so we expect that. We are used to having some basic human rights here, perhaps unlike most Americans these days. Data processes and ownership of biometric data should be made explicitly clear. It shouldn't take days of reading to understand. It feels wrong to me too.
deleted 7mo ago
[deleted]
gib444 7mo ago
The "pull yourselves up by your bootstraps" advice has more weight when the person saying it hasn't taken control of all bootstraps for a good 75 years. This is this toxicity in the toxic relationship between the US and EU. Foot in our faces telling us to pick ourselves up. Ditto South America.
- csmpltn 7mo ago
  Victim mentality? Explain what stops Europe from producing a worthy LinkedIn competitor that challenges LinkedIn's hegemony.
  - deleted 7mo ago
    [deleted]
  - gib444 7mo ago
    > Victim mentality Oh please.
    - foxglacier 7mo ago
      He's right though. Blaming someone else for your own failures is victim mentality - regardless of whether they really are the cause or not. Notice how China managed to break free from US tech dominance, no matter how difficult it was, by making itself strong and capable instead of accepting helplessness which is victim mentality.
      - Barrin92 7mo ago
        >Notice how China managed to break free from US tech dominance, no matter how difficult it was They did this because in the Chinese narrative Americans are a bunch of hegemonic brutes and self sufficiency was a matter of survival. Europeans don't use LinkedIn because they're victimized, they use American products because there was a belief that the United States is a civilized country whose companies and government can be relied on. That Americans of all people now adopt the rhetoric of the Chinese about themselves and Europe, which has some terrifying and unflattering implications about their own self image should make people think about what they're saying. Europe didn't go for a different route because of victim-hood, but because the rule of law and the so-called Western values do still mean something on the old continent. If Americans now openly say, Europe you losers you should have treated us the way the Communist party told you to, fair enough but mind you that's how people talk who are at the end of their own civilization, I'm German I know the attitude very well.
poszlem 7mo ago
I see this sentiment constantly. It is genuinely hilarious to watch Americans lecture the world about the free market while feigning shock that Europe hasn't produced its own tech giants. Claiming "the EU had 20 years to build an equally successful product" is the geopolitical equivalent of a deeply dysfunctional 1950s household. For decades, the husband insisted he handle all the enterprise and security so he could remain the undisputed head of the family. Then, after squandering his focus on a two-decade drunken military bender in the Middle East, he stumbles home, realizes he's overextended, and screams at his wife for not having her own Silicon Valley corner office, completely ignoring that he was the one who ruthlessly bought out her ventures and demanded her dependence in the first place. America engineered a digitally dependent Europe because it funneled global data straight to US monopolies. To blame Europeans for playing the exact role the US forced them into is historical gaslighting. And pretending the CLOUD Act's global, extraterritorial overreach is the same as local EU law enforcement is just the icing on the delusion cake.
- register 7mo ago
  Thank you for your words I couldn't say any better. I agree on everything but one thing. I definetely don't find this hilarious. I find it frightening and disgusting.
- Saline9515 7mo ago
  The US is not just alone, EU governments are fully cooperating, happily. A Microsoft official explained during a french parliamentary session that he couldn't guarantee that the State data was safe from US requests. It created a shockwave, as everyone discovered what was evident from the start. Of course, nothing happened, and they renewed every contract since then. We could talk about the F35 procurement.
  - wolvoleo 7mo ago
    They renewed every contract, but the French government is hard at work at replacements for Microsoft stuff, called 'la suite'. The Germans are doing the same under the name 'opendesk' and the suite shares a lot of common tools in fact. This predates Trump II by the way, they did have more foresight than a lot of EU institutions. Things have changed for sure but big ships take long to turn.
register 7mo ago
That response reeks of astonishing arrogance. It doesn’t surprise me that nearly 50% of Americans voted for Donald Trump he perfectly embodies that mindset. Do you genuinely believe you are superior to the rest of the world? What you call “innovation” or a “better product” is often nothing more than the creation of dominant market positions through massive, capital deployment, followed by straightforward rent extraction. The European Union has every right to regulate markets operating within its jurisdiction, especially when there are credible concerns about anti-competitive practices and abuse of dominance. From what I’ve seen, there may be sufficient grounds to consider collective legal action against LinkedIn at the European level. As for so-called “European nationalist ambitions,” rest assured: Europe does not lack capable lawyers or regulatory expertise. I will be forwarding the relevant material to contacts of mine working within the European institutions in Brussels.
- rrook 7mo ago
  Maybe 30% of Americans voted for Donald Trump. This response reeks of ignorance and hubris. > Do you genuinely believe you are superior to the rest of the world? This assertion wasn't made, in any way, by the person you're replying to, and it sounds as though it's being asked in anger. This entire conversation has been about data privacy and stewardship. The OP has pointed out, correctly, that there's nothing that has prevented a EU based professional social network from existing in a way that is satisfying for EU based data policy. If you sign up on an American website, you've decided to do business with Americans in America. Why are you entitled to something that the people you are doing business with are not subject to?
  - pixl97 7mo ago
    >Maybe 30% of Americans voted for Donald Trump If you don't vote, you don't count.
  - register 7mo ago
    Trump received 77,284,118 votes, representing 49.8% of the ballots cast for president. The 30% figure you mention refes to the share of the total voting-eligible population, including those who did not vote. A national poll conducted on February 16–18 found that 42.4% approve of Trump’s job performance, while 54.6% disapprove. Whether you accept it or not and whether you are a Democrat or Republican Trump now is the face of America and most of Europeans are of the same opinion. Regardless of the fact that LinkedIn is an American company, it is required to comply with the GDPR when operating within the European Union. I am not a lawyer, but I don't believe that there is evidence of full compliance here.
Ylpertnodi 7mo ago
> American companies don’t owe your European nationalist ambitions a dime. Use their products at your own discretion. As a fairly vociferous eu person....I fully agree. However, gdpr covers all eu residents, so if US companies don't want to obey eu law, that'sa fine, too.
- csmpltn 7mo ago
  Nobody is forcing you to use LinkedIn. LinkedIn is an American product, made by an American company in America, subject to American law. When you create an account - you agree to American terms and conditions, arbitrated by American courts. LinkedIn doesn't need to obey to EU law. It needs to obey to American law, which allows LinkedIn to do business with anybody (other than people from sanctioned countries) whilst complying with US law. EU's laws don't matter in the US. The EU can sue LinkedIn, but LinkedIn can just safely ignore any lawsuits and ignore sanctions, because they are an American company subject to American laws. EU citizens are willingly subscribing to an American service, then complain the American service doesn't abide by EU laws. That's laughable at every level, to any individual with a modicum of intelligence. If you don't agree to the terms, don't use LinkedIn. You are not entitled to anything.
  - loglog 7mo ago
    Operator of the LinkedIn Website: LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland
  - holistio 7mo ago
    > LinkedIn doesn't need to obey to EU law. Yes, they do. > If you don't agree to the terms, don't use LinkedIn. We agree on that.
  - buzer 7mo ago
    > you agree to American terms and conditions, arbitrated by American courts. "Designated Countries. We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland." "If you reside in the “Designated Countries”, you are entering into this Contract with LinkedIn Ireland Unlimited Company (“LinkedIn Ireland”) and LinkedIn Ireland will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services." "If you live in the Designated Countries, the laws of Ireland govern all claims related to LinkedIn's provision of the Services" "With respect to jurisdiction, you and LinkedIn agree to choose the courts of the country to which we direct your Services where you have habitual residence for all disputes arising out of or relating to this User Agreement, or in the alternative, you may choose the responsible court in Ireland." Source: https://www.linkedin.com/legal/user-agreement https://www.linkedin.com/legal/user-agreement I'm not sure from where you got your information.
deleted 7mo ago
[deleted]
lp4v4n 7mo ago
>The EU has had 20 years to create an equally successful and popular product, which it failed to do. American companies don’t owe your European nationalist ambitions a dime. Use their products at your own discretion. I can see not everybody here will agree with me, but I find this take absolutely reasonable. The European space has the capacity and the resources to create a product that replaces something as trivial as Linkedin, and yet it takes the lazy approach of just using American products. It's the same thing with China's manufactured products, at some point the rest of the world just accepted that everything gets done in China and then keep complaining about how abusive China can be. The most recent issue is the military question. Europe relied for decades on the "cheap" protection of the USA. Now the USA gave the middle finger to Europe and Europe acts shocked, but Europe is not so shocked when it comes to the military budget it did not spend on self defense during all the time the Americans provided protection.
- csmpltn 7mo ago
  > "The most recent issue is the military question. Europe relied for decades on the "cheap" protection of the USA. Now the USA gave the middle finger to Europe and Europe acts shocked, but Europe is not so shocked when it comes to the military budget it did not spend on self defense during all the time the Americans provided protection." Fully agree. Europe expects some kids from nowheresville Tennessee to die in a ditch defending Ukraine. The war will be over the second they need to draft 18 year-olds at scale from anywhere in western Europe to go defend "Europe". Nobody in France will die defending Poland, nobody in Greece will die defending Latvia. The EU is such a joke.
  - holistio 7mo ago
    Nobody is expecting anyone from Tennessee, but I know that's what the likes of Musk are making you believe.
    - csmpltn 7mo ago
      [flagged]
cbeach 7mo ago
> The EU has had 20 years to create an equally successful and popular product, which it failed to do. American companies don’t owe your European nationalist ambitions a dime. So true. There's a lot of passive-aggressive anti-US rhetoric and fearmongering on HN at the moment, while America is simply doing what it's always done - innovating and thriving. As a European, I wish our continent was able to be more like America, as opposed to jealously coveting its outcomes.

by csmpltn 7mo ago

47282847 7mo ago

> European law enforcement agencies have the same powers. No they don’t, not in the way that is implied here. A German court can subpoena German companies. Even for 100% subsidiaries in other European or non-European countries, one needs to request legal assistance. Which then is evaluated based on local jurisdiction of the subsidiary, not the parent. Microsoft Germany as operator is subject to US law and access. See Wikipedia “American exceptionalism” for further examples.

kleiba 7mo ago

One detail you might have overlooked: even if you're an American company - if you offer your services in Europe (through the web or otherwise), you're subject to European laws and regulations, including the GDPR.

rrr_oh_man 7mo ago
"Sue me" is what a purely cis-Atlantean company might say.
- wolvoleo 7mo ago
  Which is of course exactly what is happening with the likes of Google and Meta.
  - rrr_oh_man 7mo ago
    ...both of which have offices in the EU.
  - csmpltn 7mo ago
    Google and Meta don't need to show up to court :)

birdsongs 7mo ago

> In other words I don’t see why any of this is somehow uniquely wrong to the OP. Did you read the article? It's a dark pattern. It is an act that takes 3 minutes to perform. Yet it takes multiple days of reading legal documents to understand what actually happens. I would argue this feels wrong, to most people who interact with technology. We have a set of laws here that companies are obliged to follow, regardless of where they are incorporated, so we expect that. We are used to having some basic human rights here, perhaps unlike most Americans these days. Data processes and ownership of biometric data should be made explicitly clear. It shouldn't take days of reading to understand. It feels wrong to me too.

deleted 7mo ago

[deleted]

gib444 7mo ago

The "pull yourselves up by your bootstraps" advice has more weight when the person saying it hasn't taken control of all bootstraps for a good 75 years. This is this toxicity in the toxic relationship between the US and EU. Foot in our faces telling us to pick ourselves up. Ditto South America.

csmpltn 7mo ago
Victim mentality? Explain what stops Europe from producing a worthy LinkedIn competitor that challenges LinkedIn's hegemony.
- deleted 7mo ago
  [deleted]
- gib444 7mo ago
  > Victim mentality Oh please.
  - foxglacier 7mo ago
    He's right though. Blaming someone else for your own failures is victim mentality - regardless of whether they really are the cause or not. Notice how China managed to break free from US tech dominance, no matter how difficult it was, by making itself strong and capable instead of accepting helplessness which is victim mentality.
    - Barrin92 7mo ago
      >Notice how China managed to break free from US tech dominance, no matter how difficult it was They did this because in the Chinese narrative Americans are a bunch of hegemonic brutes and self sufficiency was a matter of survival. Europeans don't use LinkedIn because they're victimized, they use American products because there was a belief that the United States is a civilized country whose companies and government can be relied on. That Americans of all people now adopt the rhetoric of the Chinese about themselves and Europe, which has some terrifying and unflattering implications about their own self image should make people think about what they're saying. Europe didn't go for a different route because of victim-hood, but because the rule of law and the so-called Western values do still mean something on the old continent. If Americans now openly say, Europe you losers you should have treated us the way the Communist party told you to, fair enough but mind you that's how people talk who are at the end of their own civilization, I'm German I know the attitude very well.

poszlem 7mo ago

I see this sentiment constantly. It is genuinely hilarious to watch Americans lecture the world about the free market while feigning shock that Europe hasn't produced its own tech giants. Claiming "the EU had 20 years to build an equally successful product" is the geopolitical equivalent of a deeply dysfunctional 1950s household. For decades, the husband insisted he handle all the enterprise and security so he could remain the undisputed head of the family. Then, after squandering his focus on a two-decade drunken military bender in the Middle East, he stumbles home, realizes he's overextended, and screams at his wife for not having her own Silicon Valley corner office, completely ignoring that he was the one who ruthlessly bought out her ventures and demanded her dependence in the first place. America engineered a digitally dependent Europe because it funneled global data straight to US monopolies. To blame Europeans for playing the exact role the US forced them into is historical gaslighting. And pretending the CLOUD Act's global, extraterritorial overreach is the same as local EU law enforcement is just the icing on the delusion cake.

register 7mo ago
Thank you for your words I couldn't say any better. I agree on everything but one thing. I definetely don't find this hilarious. I find it frightening and disgusting.
Saline9515 7mo ago
The US is not just alone, EU governments are fully cooperating, happily. A Microsoft official explained during a french parliamentary session that he couldn't guarantee that the State data was safe from US requests. It created a shockwave, as everyone discovered what was evident from the start. Of course, nothing happened, and they renewed every contract since then. We could talk about the F35 procurement.
- wolvoleo 7mo ago
  They renewed every contract, but the French government is hard at work at replacements for Microsoft stuff, called 'la suite'. The Germans are doing the same under the name 'opendesk' and the suite shares a lot of common tools in fact. This predates Trump II by the way, they did have more foresight than a lot of EU institutions. Things have changed for sure but big ships take long to turn.

That response reeks of astonishing arrogance. It doesn’t surprise me that nearly 50% of Americans voted for Donald Trump he perfectly embodies that mindset. Do you genuinely believe you are superior to the rest of the world? What you call “innovation” or a “better product” is often nothing more than the creation of dominant market positions through massive, capital deployment, followed by straightforward rent extraction. The European Union has every right to regulate markets operating within its jurisdiction, especially when there are credible concerns about anti-competitive practices and abuse of dominance. From what I’ve seen, there may be sufficient grounds to consider collective legal action against LinkedIn at the European level. As for so-called “European nationalist ambitions,” rest assured: Europe does not lack capable lawyers or regulatory expertise. I will be forwarding the relevant material to contacts of mine working within the European institutions in Brussels.

rrook 7mo ago
Maybe 30% of Americans voted for Donald Trump. This response reeks of ignorance and hubris. > Do you genuinely believe you are superior to the rest of the world? This assertion wasn't made, in any way, by the person you're replying to, and it sounds as though it's being asked in anger. This entire conversation has been about data privacy and stewardship. The OP has pointed out, correctly, that there's nothing that has prevented a EU based professional social network from existing in a way that is satisfying for EU based data policy. If you sign up on an American website, you've decided to do business with Americans in America. Why are you entitled to something that the people you are doing business with are not subject to?
- pixl97 7mo ago
  >Maybe 30% of Americans voted for Donald Trump If you don't vote, you don't count.
- register 7mo ago
  Trump received 77,284,118 votes, representing 49.8% of the ballots cast for president. The 30% figure you mention refes to the share of the total voting-eligible population, including those who did not vote. A national poll conducted on February 16–18 found that 42.4% approve of Trump’s job performance, while 54.6% disapprove. Whether you accept it or not and whether you are a Democrat or Republican Trump now is the face of America and most of Europeans are of the same opinion. Regardless of the fact that LinkedIn is an American company, it is required to comply with the GDPR when operating within the European Union. I am not a lawyer, but I don't believe that there is evidence of full compliance here.

Ylpertnodi 7mo ago

> American companies don’t owe your European nationalist ambitions a dime. Use their products at your own discretion. As a fairly vociferous eu person....I fully agree. However, gdpr covers all eu residents, so if US companies don't want to obey eu law, that'sa fine, too.

csmpltn 7mo ago
Nobody is forcing you to use LinkedIn. LinkedIn is an American product, made by an American company in America, subject to American law. When you create an account - you agree to American terms and conditions, arbitrated by American courts. LinkedIn doesn't need to obey to EU law. It needs to obey to American law, which allows LinkedIn to do business with anybody (other than people from sanctioned countries) whilst complying with US law. EU's laws don't matter in the US. The EU can sue LinkedIn, but LinkedIn can just safely ignore any lawsuits and ignore sanctions, because they are an American company subject to American laws. EU citizens are willingly subscribing to an American service, then complain the American service doesn't abide by EU laws. That's laughable at every level, to any individual with a modicum of intelligence. If you don't agree to the terms, don't use LinkedIn. You are not entitled to anything.
- loglog 7mo ago
  Operator of the LinkedIn Website: LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland
- holistio 7mo ago
  > LinkedIn doesn't need to obey to EU law. Yes, they do. > If you don't agree to the terms, don't use LinkedIn. We agree on that.
- buzer 7mo ago
  > you agree to American terms and conditions, arbitrated by American courts. "Designated Countries. We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland." "If you reside in the “Designated Countries”, you are entering into this Contract with LinkedIn Ireland Unlimited Company (“LinkedIn Ireland”) and LinkedIn Ireland will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services." "If you live in the Designated Countries, the laws of Ireland govern all claims related to LinkedIn's provision of the Services" "With respect to jurisdiction, you and LinkedIn agree to choose the courts of the country to which we direct your Services where you have habitual residence for all disputes arising out of or relating to this User Agreement, or in the alternative, you may choose the responsible court in Ireland." Source: https://www.linkedin.com/legal/user-agreement https://www.linkedin.com/legal/user-agreement I'm not sure from where you got your information.

deleted 7mo ago

[deleted]

lp4v4n 7mo ago

>The EU has had 20 years to create an equally successful and popular product, which it failed to do. American companies don’t owe your European nationalist ambitions a dime. Use their products at your own discretion. I can see not everybody here will agree with me, but I find this take absolutely reasonable. The European space has the capacity and the resources to create a product that replaces something as trivial as Linkedin, and yet it takes the lazy approach of just using American products. It's the same thing with China's manufactured products, at some point the rest of the world just accepted that everything gets done in China and then keep complaining about how abusive China can be. The most recent issue is the military question. Europe relied for decades on the "cheap" protection of the USA. Now the USA gave the middle finger to Europe and Europe acts shocked, but Europe is not so shocked when it comes to the military budget it did not spend on self defense during all the time the Americans provided protection.

csmpltn 7mo ago
> "The most recent issue is the military question. Europe relied for decades on the "cheap" protection of the USA. Now the USA gave the middle finger to Europe and Europe acts shocked, but Europe is not so shocked when it comes to the military budget it did not spend on self defense during all the time the Americans provided protection." Fully agree. Europe expects some kids from nowheresville Tennessee to die in a ditch defending Ukraine. The war will be over the second they need to draft 18 year-olds at scale from anywhere in western Europe to go defend "Europe". Nobody in France will die defending Poland, nobody in Greece will die defending Latvia. The EU is such a joke.
- holistio 7mo ago
  Nobody is expecting anyone from Tennessee, but I know that's what the likes of Musk are making you believe.
  - csmpltn 7mo ago
    [flagged]

cbeach 7mo ago

> The EU has had 20 years to create an equally successful and popular product, which it failed to do. American companies don’t owe your European nationalist ambitions a dime. So true. There's a lot of passive-aggressive anti-US rhetoric and fearmongering on HN at the moment, while America is simply doing what it's always done - innovating and thriving. As a European, I wish our continent was able to be more like America, as opposed to jealously coveting its outcomes.