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Usage of EU subsidiaries of US cloud providers deemed unlawful by German court

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Re: Usage of EU subsidiaries of US cloud providers deemed unlawful by German court

#131

Post by xdennis »

the_duke wrote: post #103
intunderflow wrote: post #41

And slowly but surely the tidal wave of the consequences of GDPR versus the CLOUD Act come into view. It will take many years to of delays and fretting (due to the dependence on US clouds) but fundamentally the current legal position is that GDPR is fundamentally incompatible with any personal data transfer to the USA, that's how Google Analytics keeps getting banned too. At some point this will all come to a head an…

The cloud providers can work with independent operators that run their cloud solutions in Europe. Basically an on-premise setup, just on a huge scale. Microsoft initially did this for Azure, I believe. Certainly will cause a lot of friction.

> The cloud providers can work with independent operators that run their cloud solutions in Europe.

Does that exempt them from the CLOUD Act? If US companies have access to independent operators in Europe, presumably they can still be compelled to give that data to the US.

Re: Usage of EU subsidiaries of US cloud providers deemed unlawful by German court

#132

Post by bettysdiagnose »

wins32767 wrote: post #101
bettysdiagnose wrote: post #69

Earlier quoted context omitted.

OK but not wanting our personal records to be arbitrarily sized by the US government is very reasonable. Your government made a law that lets it spy on us... that's your problem.

I don't think it's reasonable that I'm paying more than my share of taxes for the defense capabilities that allows Europe free access to a stable world market and roughly rules based international order that underpins the export economy of Germany in particular. If Europe would fix that, I'd feel a lot worse about the spying.

Complete and utter non-sequitur but I'll humour you.

I never understood American magical thinking that blames Europe for US military spending. In the end, if you want to cut military spending, you can.

Regardless, you're the hegemon. I don't accept that you don't benefit from that position.

Re: Usage of EU subsidiaries of US cloud providers deemed unlawful by German court

#133

Post by mattashii »

AnonMO wrote: post #128
throwaway4good wrote: post #76

Hey America - stop spying on our our citizens or we will stop buying your tech. Seriously. We talk about this cloud stuff like it is rocket science. It is not. It is a box in a basement. We are capable of doing that ourselves. And no. It ain’t cool for NSA to sniff around some German governmental software, even though you are the good guys and on our side.

[flagged]

But you do not need to mention the GDPR to comply with the GDPR.

Re: Usage of EU subsidiaries of US cloud providers deemed unlawful by German court

#134

Post by Macha »

xyzzyz wrote: post #116
solar-ice wrote: post #88

Earlier quoted context omitted.

The procedure and requirements for obtaining a warrant under the CLOUD Act is not sufficient due process according to EU law - which is law which matters when operating a commercial business in the EU.

Sure, and US can pass a law saying that safety regulations of Airbus planes made in France are not sufficient either. Americans just don’t like flying in unsafe planes! If you talk to actual people in Europe, outside of HN, you’ll find that overwhelming majority of people do not give a flying fuck about the “safety of their data” from US government. They just blissfully post shit on Facebook with no care in the world…

> Sure, and US can pass a law saying that safety regulations of Airbus planes made in France are not sufficient either. Americans just don’t like flying in unsafe planes!

That would be rather awkard for Boeing, who would have to strip out half the engines on its 787s and all its 737-MAXes for being certified by the same "insufficient" safety standards.

Re: Usage of EU subsidiaries of US cloud providers deemed unlawful by German court

#135

Post by johannes1234321 »

blocked_again wrote: post #100
johannes1234321 wrote: post #94

Earlier quoted context omitted.

Maybe it's just, that the European law makers understand the risk of being are to transfer sensitive persona data into other legislations, and that a local registered company doesn't mean there are technical bounds.

Quoted post unavailable.

I am not sure which exact incident you are after, but NSA, the largest operater of surveillance in Europe is American and GCHQ, the second alrgest, is British and also outside EU these days. But yes, there are some actions by European governments i condemn.

However as a European citizen I have ways to counter actions by a European government. By voting, by legal means etc. Into the US I have now range and the US has very little responsibility towards me. Laws protecting Americans or actions in America don't protect me as a foreigner.

That said: The court case here at hand was about the government being the (indirect) customer of that cloud. Thus it's their data amthey want to be protected from foreign governments.

Re: Usage of EU subsidiaries of US cloud providers deemed unlawful by German court

#136

Post by jtwaleson »

lispm wrote: post #120
jtwaleson wrote: post #81

Earlier quoted context omitted.

I'm European and I'll happily admit there is no EU alternative to AWS, GCP, Azure. The breadth of services _on_, and the amount of engineers able to work _with_ these platforms is incredible and can't be beat by the likes of Hetzner and OVH. We are so behind that we won't catch up. The arrogance is warranted in this case. I like privacy, but the business person in me is very frustrated by these GDPR rulings as they m…

Lidl: https://www.stackit.de/en/

Are you joking? The products page is laughable compared to the big cloud providers. Hell, it has "We create custom-fit solutions" on the landing page. If anything screams non-cloud it's that.

Re: Usage of EU subsidiaries of US cloud providers deemed unlawful by German court

#137

Post by Macha »

solar-ice wrote: post #127
xyzzyz wrote: post #116

Earlier quoted context omitted.

Sure, and US can pass a law saying that safety regulations of Airbus planes made in France are not sufficient either. Americans just don’t like flying in unsafe planes! If you talk to actual people in Europe, outside of HN, you’ll find that overwhelming majority of people do not give a flying fuck about the “safety of their data” from US government. They just blissfully post shit on Facebook with no care in the world…

> Sure, and US can pass a law saying that safety regulations of Airbus planes made in France are not sufficient either. Americans just don’t like flying in unsafe planes! If you cannot see the difference between this and the GDPR, I have no idea why we're talking. The GDPR is some pretty reasonable law, for the most part - if we had carve-outs for Americans who don't have to adhere to it, it would be entirely pointle…

Actually, it would be worse than pointless - it would advantage american firms over local ones, since only the local ones would have to obey the privacy laws, thereby allowing US ones to undercut local firms with funds obtained from selling user data.

Re: Usage of EU subsidiaries of US cloud providers deemed unlawful by German court

#138

Post by eli »

qeternity wrote: post #123
eli wrote: post #114

Earlier quoted context omitted.

Isn't it easier for the NSA to spy on foreign companies than US companies? There are restrictions on how they can operate on US soil.

Yes. I've never understood this whole "don't host in the US or the NSA will spy on you"...uh, that might be true, but at least on paper there are protections. An EU subsidiary of a US company is fully legal fair game for every 3 letter agency.

As is a fully independent EU alternative.

I support reigning in the NSA, GDPR seems like a weird way to do it. I don't follow the logic.

Re: Usage of EU subsidiaries of US cloud providers deemed unlawful by German court

#139

Post by blocked_again »

simion314 wrote: post #125
blocked_again wrote: post #75

I think this kind of affirms the general opinion that Germany and many traditionally powerful European countries is doing poorly when it comes to modern tech. What went wrong with Germany and Europe? They used to be the front runners in tech once upon a time.

But when is about TikTok I see most americans have completely different values, no sorry americans are consistent, only US citizens deserve rights, the rest can be spied on, tortured,killed etc. Give EU citizens same privacy rights and there so no need to start an economic war because some NSA fat and lazy agent does not want to prepare a file to request a warrant. If you are at it, maybe is tiem to let US citizens t…

You do know that nobody in US is forcing you to use this site or any other US companies for that matter. You are doing it with your own free fill.

Also, remember the time when Germany decided to go after their own people? How does laws like this help when it comes to situations like that?

Re: Usage of EU subsidiaries of US cloud providers deemed unlawful by German court

#140

Post by 3836293648 »

blocked_again wrote: post #113
lizardactivist wrote: post #86

Earlier quoted context omitted.

"European countries doing poorly when it comes to modern tech" has never been an opinion. You're confused, and your petty vindictiveness is unmotivated. The EU as a space of commerce is not yours to do with as you wish. You have to follow rules and regulations just like our own companies have to. And if your country had not been engaging in espionage and sabotage then there would never have been a need for these "unf…

Quoted post unavailable.

If the goal was to stop US companies, the EU parliament wouldn't've thought that the US lived up to the requirements of the GDPR. They assumed they did until courts struck it down
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