The EU and its collective countries do not have the concept of a deemed export within their laws. Export controls under the EU are based on geographic location, not the nationality of recipients. The EU does, however, have one of the strictest data privacy laws in the world – the General Data Protection Regulation (“GDPR”). Understanding that the US deemed export rule often requires companies to access and retain nationality information and that the purpose of GDPR is to protect and restrict acc...
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