Privacy Minders - EU Representative Services

IS YOUR COMPANY OUTSIDE EU?
DO YOU SELL GOODS OR SERVICES TO PERSONS IN THE EU OR MONITOR PERSONS’ BEHAVIOUR WITHIN THE EU?
THEN YOU MOST LIKELY NEED TO APPOINT AN EU REPRESENTATIVE

Privacy Minders provides EU Representative Services to non-EU clients who must comply with GDPR and their obligation to appoint an EU Representative.
Complete the form below to receive an Offer or to find out for FREE whether your company must appoint an EU Representative.

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We take your privacy seriously. Please read our Privacy Notice.

Why choose Privacy Minders?

In Privacy Minders we pride ourselves as experts in GDPR compliance services and we make sure that the quality of the services provided to our clients shows this expertise.

We evaluate our services and processes to maintain efficiencies and add value wherever possible.

Our very good knowledge of GDPR and data protection, including data subjects’ rights and supervisory authorities’ powers allow us to undertake the EU Representative role and to facilitate any informational or other procedural communication between your company and the data subjects as well as the supervisory authorities.

Pricing

Our quotes are very competitive, and we strike for keeping them at a low level. Our prices start from €400/year and you get a full range of EU Representative services.

Which services does Privacy Minders provide as EU Representative?

Privacy Minders, as EU Representative, supports the non-EU company to comply with the obligation under Art 27 of the GDPR. Our services include:

Company’s representation in all Member States

Direct contact in the EU to the Supervisory Authorities and individuals

EU postal address and dedicated email address for requests from individuals

Being company’s authorized agent to receive legal documents

Retaining a record of Company’s processing activities

Certificate proving our appointment as the company’s EU Representative

Giving you permission to use the certificate and our logo on your website and privacy notice

1. Who needs to appoint an EU Representative?

Under Art 27 GDPR companies outside of the EU, including Russian, UK, Middle Eastern and Asian companies, must appoint an EU Representative if one of the following cases applies:

offering goods and services to individuals in the EU
monitoring the behavior of individuals located in the EU

2. What is the EU Representative’s role?

Τhe EU Representative acts as the liaison between your company and the individuals as well as the supervisory authorities, on all issues related to data processing, for the purposes of ensuring compliance with GDPR.

The EU Representative’s contact details should be easily accessible to supervisory authorities, for example, by publishing it on your website and should also be provided to data subjects, for example, in your privacy notice.
The Data Subjects and the Supervisory Authorities can contact the EU Representative in addition to or instead of the non-EU company on all issues related to data processing. The EU-Representative has to maintain records of processing activities for the non-EU company.

3. When does a company outside of the EU offer goods and services to EU customers?

Companies outside of the EU need to demonstrate an intention to establish commercial relations with EU customers. According to the Guidelines 3/2018 on the territorial scope of the GDPR, the mere accessibility of the website in the EU, of an email address or of other contact details, or the use of a language generally used in the third country where the non-EU company is established, is insufficient to manifest the intention to offer goods and services to EU customers.

In order to assess if goods and services are offered to EU customers, the following factors should be taken into account:

using languages of EU Member States
offering payments in a currency of an EU Member State
having marketing activities directed to EU customers
mentioning of customers or users who are in the EU
referring to addresses or phone numbers to be reached from an EU Member States
using EU domains
offering goods’ delivery in EU Member States

4. When does a company outside of the EU monitor the behavior of individuals located in the EU?

Companies outside of the EU monitor the behavior of individuals located in the EU when they track natural persons on the internet or through wearables and other devices, including online tracking through the use of cookies, CCTV, geo-localization activities and behavioral advertisement.

5. Where should the EU Representative be based?

The EU Representative should be based in one of the Member States where the non-EU companies offer goods or services to Data Subjects, or monitor their behavior. The EU Representative can represent the company in all other Member States and his/her location does not determine the Lead Supervisory Authority.

6. In case of group of companies, does each company have to appoint an EU Representative?

Yes. Every separate company must appoint an EU Representative. Privacy Minders offers special options to manage the representation of the affiliates by choosing one of our group packages (small-, medium- or large-sized). The number of affiliates determines which group package fits the group of companies.

7. Which companies outside of the EU are exempt from the obligation to appoint an EU Representative?

Companies outside of the EU do not have to appoint an EU Representative when all the three following conditions are fulfilled cumulatively:

data processing is occasional, and
data processing does not include large-scale processing of special categories of personal data, or personal data related to criminal convictions and offences, and
data processing is unlikely to result in a risk to the rights and freedoms of natural persons.

Please note that it is highly unlikely for a non-EU company to fulfill all the above conditions and thus to be exempt from the obligation to appoint an EU Representative.

8. Are there any fines to be imposed for non-compliance?

The GDPR applies to companies outside of the EU regarding the obligation to appoint EU Representative under the conditions provided in article 27 of the GDPR. Fines of up to €10 million or 2% of the worldwide annual turnover may be enforced by Data Protection Authorities or Data Subjects claims submitted to the Authorities.

Why choose Privacy Minders?

Pricing

Which services does Privacy Minders provide as EU Representative?

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