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By Vincent WELLENS and Sigrid HEIRBRANT, NautaDutilh Avocats Luxembourg S.à r.l.
A few months ago, the Irish Data Protection Commission imposed an administrative fine of EUR 225 million on WhatsApp Ireland Limited, declaring the company’s data protection notice non-compliant with the General Data Protection Regulation (Regulation (No) 2016/679 or the «GDPR»).
Although the decision is mostly cited with reference to the transfer of personal data from WhatsApp to Facebook, many points have more general relevance, specifically as regards the content of data protection notices. In addition, the decision is interesting as it was subject to the consistency mechanism and based on a binding Article 65 decision of the European Data Protection Board ...
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