Full Disclosure mailing list archives
Re: [CDPWE-0001] - RocketReach
From: Thierry Zoller <thierry () zoller lu>
Date: Thu, 11 Mar 2021 13:33:35 +0100
===================================================================Adapting the Mechanics of Vulnerability Disclosure to an area where Privacy Rights need to be scrutinized and where transparency becomes paramount.
===================================================================On the 29.05.2020 I reported a way to bypass the GDPR as the Data Protection Authorities claimed to not have a possibility to act against
such abuse. I am happy to announce that a Patch is being developed and that NOYB is taking the CNPD to court on this matter. You can read more about it here: https://noyb.eu/en/luxemburgs-watchdog-refuses-show-its-teeth-us-companies ================================================================Adapting the Mechanics of Vulnerability Disclosure to an area where Privacy Rights need to be scrutinized and where transparency becomes paramount.
________________________________________________________________________ How to effectively evade the GDPR and the reach of the DPA (CDPWE-0001) ________________________________________________________________________ Company : Rocketreach Status : DPA does not pursue any furtherCDPWE : 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 ----------------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 ----------------------------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 ----------------------------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 ---------------------------- 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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- Re: [CDPWE-0001] - RocketReach Thierry Zoller (Mar 11)