Adapting the Mechanics of Vulnerability Disclosure to an area where Privacy Rights need to be scrutinized and where transparency becomes paramount.

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How to effectively evade the GDPR and the reach of the DPA (CDPWE-0001)
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Company : Rocketreach
Status  : DPA does not pursue any further
CDPWE : CDPWE-0001 - Does not designate a Representative in the European Union URL : https://blog.zoller.lu/2020/05/how-to-effectively-evade-gdpr-and-reach.html
Vulnerability Disclosure Policy: https://caravelahq.com/b/policy/20949


I. Background
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RocketReach is selling access to millions of European Data Subjects without recognising it is a Data Controller, without a representative
in the EU (ART.27) and with a questionable legal basis for processing.

II. Impact
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Companies around the World can Process and sell Information about European data subjects without that the DPA sanctions them for doing so by simply not designating a EU Representative accourding to Art.27 of the GDPR.

Note: That representative would be held accountable, without it the CNPD (LUX DPA) argues that their is no way for them to proceed.

https://www.privacy-regulation.eu/en/article-27-representatives-of-controllers-or-processors-not-established-in-the-union-GDPR.htm

III. Advisory
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If your data is also included in Rocketreach (just search on their website), then file a complain with your local DPA (it's usually very easy and fast) .


V. Timeline
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5th of April  2019 - Issued a DSAR to RocketReach
5th of April  2019 - Rocketreach responds by deleteing my data
5th of April  2019 - File a complain via my national DPA (CNPD)
6th of March 2020 - The CNPD agrees with my position but claims to not be able to pursue further. See: https://blog.zoller.lu/2020/05/how-to-effectively-evade-gdpr-and-reach.html





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