Intent to issue €2.5M fine to Disqus over GDPR breaches

GDPR applies to processors or controllers not in the Union if the processing activities are related to:

1. the offering of goods or services, irrespective of whether a payment of the data subject is required, to such data subjects in the Union; or

2. the monitoring of their behaviour as far as their behaviour takes place within the Union.

(See Article 3).

I believe that in most cases the point of geoblocking is not so much to try to actually stop people in the EU from accessing the sites, but rather to try to ensure that any data processed falls under #1.

One of the Recitals for that section says:

> In order to determine whether such a controller or processor is offering goods or services to data subjects who are in the Union, it should be ascertained whether it is apparent that the controller or processor envisages offering services to data subjects in one or more Member States in the Union. Whereas the mere accessibility of the controller’s, processor’s or an intermediary’s website in the Union, of an email address or of other contact details, or 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 with the possibility of ordering goods and services in that other language, or the mentioning of customers or users who are in the Union, may make it apparent that the controller envisages offering goods or services to data subjects in the Union.

Aside: isn't it weird how often "email addresses" is shortened to "emails"? At first glance I had to contextually infer whether it was 215M addresses or 215M messages (pieces of mail) because we also often shorten the latter to "emails" when working through our inboxes.

If you're running a marketing campaign and say "today we finally hit 1000 emails" without further clarification, nobody will know if that's 1000 subscribers or 1000 newsletters.

> Did the Norwegian fishing (salmon farming) industry have a big part in the EU vs EEA decision?

We definitely have to split the Norwegian fisheries industry into two: Norway has, and has for a long time had, a sizable wild fishing industry. The fish farming industry is a much newer one.

I was a kid last time we had a referendum on membership (1994), so I'm not sure, but I believe the fish farming industry wasn't even a major thing back then. The classical fisheries industry definitely was a big part of the reasoning. Today, I would wager that opponents of full membership are mostly riding on the same vague of opaque euroskepticism that brought us Brexit, combined with the sickening idea that Norwegians are somehow magically special and exceptionally good at things. Granted, my personal views on the matter definitely color this take.

> From what I’ve seen lately about Norwegian Salmon farming I wonder if it would get past the EU regulations, if they even have any related to fish farming.

I doubt that would be an issue.

> Some documentaries even call it the worlds most toxic food.

I really wish people would stop spreading this unsubstantiated bullshit. I have no connection with or investments in fish farming, but this claim was making the rounds a few years back, and as far as I can tell it's a completely unsubstantiated smear. It keeps getting repeated, but trying to actually get to the source just reveals a tangled web of self-referential claims.

There's plenty of problems with fish farming without having to make up shit about "toxic food". The two biggest being the horrid effect the escaped farmed fish have on the natural populations (they carry different diseases and parasites that can wipe out whole rivers of salmon, for instance), and the effect of over-feeding on the nearby ecosystem (you dump enormous amounts of feed into a relatively small volume of water, and far from all of it is actually consumed by the farmed fish). In addition to this, the feed often comes from just as unsustainable sources as the worst of the "Amazon beef". Hopefully the latter can be fixed with transparancy and regulations, though.

Plenty of problems with fish farming without needing to fabricate new ones. But then again, it may be the only solution to prevent overfishing (if we want to keep eating fish, which is certainly better overall than eating beef).

Forgetting for a single country (which is also not part of the EU) certainly seems plausible, more plausible than a targeted attempt at undermining the GDPR in a very specific country

curious can't it be done by disabling third party cookies alone as Disqus need cookies to work?