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Stefan Arentz

@davidculley Oh they speak from a “TDDDG” perspective. Is that something Germany added on top of the GDPR?

4 October at 11:37 | Wall-to-wall | Open on mastodon.social
6 comments
David Culley

@st3fan It’s not GDPR, it’s the ePrivacy Directive.

TDDDG is the German national implementation of the ePrivacy Directive.

Important (and violated) is Article 5, sentence 3.
eur-lex.europa.eu/LexUriServ/L

4 October at 11:43 | Open on sigmoid.social
Stefan Arentz

@davidculley I am not a lawyer. But I am really not sure if that section means what you think it means.

4 October at 11:53 | Open on mastodon.social
David Culley

@st3fan It’s not what I say. It’s what privacy experts and their lawyers say. I just read their blog.
sigmoid.social/@davidculley/11

4 October at 11:57 | Open on sigmoid.social
David Culley

@st3fan Besides, it says:

> is offered the right to refuse such processing

How can I refuse if the telemetry is sent as soon as I open the app, before I can even go to the settings menu and change opt-out to opt-in? The telemetry was already sent without me being able to refuse.

So I don’t think I misunderstood it.

4 October at 12:03 | Open on sigmoid.social
Stefan Arentz

@davidculley I don't know. I am not a layer and I definitely don't know the German situation well. I do think it is complicated and somewhat ambiguous. It seems the TDDDG specifically applies to the Telecommunications and Telemedia industry? And it mostly talks about websites and cookies. Is a mobile app part of that? Or would K-9 fall under the BDSG, which seems to use the same definitions as the GDPR around classification of personal data and when consent needs to be asked?

4 October at 12:56 | Open on mastodon.social
David Culley

@st3fan I’m just a reader of the blog @kuketzblog. I’m not a lawyer either.

4 October at 13:01 | Open on sigmoid.social
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