An English-language blog hosted outside the EU is merely accessible…

Question

An English-language blog hosted outside the EU is merely accessible to occasional EU readers and shows no EU language versions, EU currency, EU shipping, or EU-focused ads. Counsel claims accessibility alone equals GDPR targeting. Which analysis is sound?

Accepted Answer

Mere accessibility of a website in the Union, without targeting factors, does not by itself establish that goods or services are being offered to data subjects in the Union. — A postcard on a global corkboard that anyone might glance at is not the same as mailing German flyers with euro prices. GDPR targeting looks for real outreach cues, not mere reachability. Occasional EU eyeballs alone do not finish the analysis.

Answer

Any hit from an EU IP address conclusively proves offering of goods or services under Article 3(2)(a).

Answer

Blogs are categorically excluded from GDPR territorial scope.

Answer

Accessibility always triggers both the offering and the monitoring limbs simultaneously.

An English-language blog hosted outside the EU is merely accessible to occasional EU readers and shows no EU language versions, EU currency, EU shipping, or EU-focused ads. Counsel claims accessibility alone equals GDPR targeting. Which analysis is sound?

Short Explanation

Full Explanation