NEWS
Ireland’s draft GDPR decision against Facebook branded a joke
Facebook’s lead data protection regulator in the European Union is inching toward making its first decision on a complaint against Facebook itself. And it looks like it’s a doozy.
Privacy campaign not-for-profit noyb today published a draft decision by the Irish Data Protection Commission (DPC) on a complaint made under the EU’s General Data Protection Regulation (GDPR).
The DPC’s draft decision proposes to fine Facebook $36 million — a financial penalty that would take the adtech giant just over two and a half hours to earn in revenue, based on its second quarter earnings (of $29 billion).
But even more worrying for privacy advocates is the apparent willingness of the DPC to allow Facebook to simply bypass the regulation by claiming users are giving it their data because they’re in a contract with it to get, er, targeted ads.
In a summary of its findings, the DPC writes: “There is no obligation on Facebook to seek to rely solely on consent for the purposes of legitimising personal data processing where it is offering a contract to a user which some users might assess as one that primarily concerns the processing of personal data. Nor has Facebook purported to rely on consent under the GDPR.”
“I find the Complainant’s case is not made out that the GDPR does not permit the reliance by Facebook on 6(1)(b) GDPR in the context of its offering of Terms of Service,” the DPC also writes, suggesting it’s totally bona fide for Facebook to claim a legal right to process people’s information for ad targeting because it’s now suggesting users actually signed up for a contract with it to deliver them ads.
Yet — simultaneously — the DPC’s draft decision does find that Facebook infringed GDPR transparency requirements — specifically: Articles 5(1)(a), 12(1) and 13(1)(c) — meaning that users were unlikely to have understood they were signing up for a Facebook ad contract when they clicked “I agree” on Facebook’s T&Cs.
So the tl;dr here is that Facebook’s public-facing marketing — which claims its service “helps you connect and share with the people in your life” — appears to be missing a few critical details about the advertising contract it’s actually asking you to enter into, or something.
Mind the enforcement gap
The GDPR came into application across the EU back in May 2018 — ostensibly to cement and strengthen long-standing privacy rules in the region which had historically suffered from a lack of enforcement, by adding new provisions such as supersized fines (of up to 4% of global turnover).
However EU privacy rules have also suffered from a lack of universally vigorous enforcement since the GDPR update. And those penalties that have been issued — including a handful against Big Tech — have been far lower than that theoretical maximum. Nor has enforcement led to an obvious retooling of privacy hostile business models — yet.
Adtech giants especially have managed to avoid a serious reckoning in Europe over their surveillance-based business models despite the existence of the GDPR — through the use of forum shopping and cynical delay tactics.
So while there is no shortage of GDPR complaints being filed against adtech, complaints over the lack of regulatory enforcement in this area are equally stacking up.
And complainants are now also resorting to legal action.
The issue is, under GDPR’s one-stop-shop mechanism, cross-border complaints and investigations, such as those targeted at major tech platforms, are led by a single agency — typically where the company in question has its legal base in the EU.
And in Facebook’s case (and many other tech giants’) that’s Ireland.
The Irish authority has long been accused of being a bottleneck to effective enforcement of the GDPR, with critics pointing to a glacial pace of enforcement, scores of complaints simply dropped without any discernible activity and — in instances where the complaints aren’t totally ignored — underwhelming decisions eventually popping out the other end.
One such series of adtech-related GDPR complaints were filed by noyb immediately the regulation came into application three years ago — targeting a number of adtech giants (including Facebook) over what noyb called “forced consent.” And these complaints of course ended up on the DPC’s desk.
noyb’s complaint against Facebook argues that the tech giant does not collect consent legally because it does not offer users a free choice to consent to their data being processed for advertising.
This is because under EU law consent must be freely given, specific (i.e., not bundled) and informed in order to be valid. So the substance of the complaint is not exactly as complicated as rocket science.
Yet a decision on noyb’s complaint has taken years to emerge from the DPC’s desk — and even now, in dilute draft form, it looks entirely underwhelming.
Per noyb, the Irish DPC has decided to accept what the campaign group dubs Facebook’s “trick” to bypass the GDPR — in which the company claims it switched away from relying on consent from users as a legal basis for processing people’s data for ad targeting to claiming users are actually in a contract with it to get ads injected into their eyeballs the very moment the GDPR came into force.
“It is painfully obvious that Facebook simply tries to bypass the clear rules of the GDPR by relabeling the agreement on data use as a ‘contract,’” said noyb founder and chair, Max Schrems, in a statement which goes on to warn that were such a basic wheeze allowed to stand it would undermine the whole regulation. Talk about a cunning plan
“If this would be accepted, any company could just write the processing of data into a contract and thereby legitimize any use of customer data without consent. This is absolutely against the intentions of the GDPR, that explicitly prohibits to hide consent agreements in terms and conditions.”
“It is neither innovative nor smart to claim that an agreement is something that it is not to bypass the law,” he adds. “Since Roman times, the Courts have not accepted such ‘relabeling’ of agreements. You can’t bypass drug laws by simply writing ‘white powder’ on a bill, when you clearly sell cocaine. Only the Irish DPC seems to fall for this trick.”
Ireland has only issued two GDPR decisions in complaints against Big Tech thus far: Last year in a case against a Twitter security breach ($550,000 fine); and earlier this year in an investigation into the transparency of (Facebook-owned) WhatsApp T&Cs ($267 million fine).
Under the GDPR, a decision on these type of cross-border GDPR complaints must go through a collective review process — where other DPAs get a chance to object. It’s a check and balance on one agency getting too cosy with business and failing to enforce the law.
And in both the aforementioned cases objections were raised on the DPC drafts that ended up increasing the penalties.
So it is highly likely that Ireland’s Facebook decision will face plenty of objections that end in a tougher penalty for Facebook.
noyb also points to guidelines put out by the European Data Protection Board (EDPB) — which it says make it clear that bypassing the GDPR isn’t legal and must be treated as consent. But it quotes the Irish DPC saying it is “simply not persuaded” by the view of its European Colleagues and suggests the EDPB will therefore have to step in yet again.
“Our hope lies with the other European authorities. If they do not take action, companies can simply move consent into terms and thereby bypass the GDPR for good,” says Schrems.
noyb has plenty more barbs for the DPC — accusing the Irish authority of holding “secret meetings” with Facebook on its “consent bypass” (not for the first time); and of withholding documents it requested — going on to denounce the regulator as acting like a “‘Big Tech’ adviser” (not, y’know, a law enforcer).
“We have cases before many authorities, but the DPC is not even remotely running a fair procedure,” adds Schrems. “Documents are withheld, hearings are denied and submitted arguments and facts are simply not reflected in the decision. The [Facebook] decision itself is lengthy, but most sections just end with a ‘view’ of the DPC, not an objective assessment of the law.”
We reached out to the DPC for comment on noyb’s assertions — but a spokesperson declined, citing an “ongoing process.”
One thing is beyond doubt at this point, over three years into Europe’s flagship data protection reboot: There will be even more delay in any GDPR enforcement against Facebook.
The GDPR’s one-stop-shop mechanism — of review plus the chance for other DPAs to file objections — already added multiple months to the two earlier DPC Big Tech decisions. So the DPC issuing another weak draft decision on a late-running investigation looks like it’s becoming a standard procedural lever to decelerate the pace of GDPR enforcement across the EU.
This will only increase pressure for EU lawmakers to agree alternative enforcement structures for the bloc’s growing suite of digital regulations.
In the meanwhile, as DPAs fight it out to try to hit Facebook with a penalty Mark Zuckerberg can’t just laugh off, Facebook gets to continue its lucrative data-mining business as usual — while EU citizens are left asking where are my rights?
Choosing the correct dose of Delta 8 is one of the most critical steps when starting cannabis. Everyone is unique, and their body chemistry and THC tolerance will affect their experience.
This is especially true with edibles. They can take hours to kick in, so you don’t want to rush your doses by taking them too soon.
Start Low and Go Slow
One fundamental rule of thumb when dosing Delta 8 Gummies is to start low and go slow. This is because everyone’s body is different, and the way it reacts to a dose will vary from person to person.
Likewise, the type of delivery method used will also influence how fast you experience the effects. For example, vaping or smoking Delta 8 takes a much shorter time to reach your bloodstream than edibles or tinctures, which can take hours or more to kick in.
However, if you want to avoid these unpleasant side effects, it’s essential to start with a low dose and work your way up. Doing this will give you a better idea of how your body responds to Delta 8 and help you find the proper dosage.
Once you’ve found the correct dose, continue with it regularly. This will prevent you from building up a tolerance, which can make the dosage feel much more potent over time.
Delivery Methods
Delta 8 gummies are among the most popular ways to get this famous cannabinoid. They come in various flavors and can be quickly taken anywhere, anytime. But it’s essential to choose the proper dosage for your needs.
For example, an oral dose may be the best option if you’re trying to manage stress or insomnia. However, vaping or Flower may be more appropriate if you want something to help with your chronic pain.
If you’re looking for a quick and easy way to take your dose of delta 8 THC, online delivery is the way to go! Most reputable companies offer free priority shipping for orders above a certain amount.
Another great thing about ordering Delta 8 gummies online is that you’re not restricted by store hours. Most wellness brands operate around the clock, so you can rate your product when it’s convenient for you – day or night!
In addition, buying from an online retailer eliminates the high price tag of shopping in a brick-and-mortar store. This is because stores have to add overhead costs, which can be up to 15-25% more than buying online.
When you buy Delta 8 gummies for sale online, you also avoid dealing with pushy salespeople who charge up-front fees and hidden charges that defy explanation. This can make you feel pressed for time and tempted to walk out without your purchase.
Tolerance Levels
There are no hard and fast rules when choosing the correct dose of Delta 8 Gummies for your needs. It all depends on how you consume it, your selected delivery method, and your weight and size.
For people new to consuming D8, starting with a small dose and working your way up is best. This will help you avoid overdosing the first time.
You should also pay close attention to how much Delta 8 THC is in each product you use. Most of the time, this is indicated on the label or the packaging.
If a product is sold in a bottle, it usually has a dropper with a substantial volume that allows you to measure the correct amount. Start with a small ml dropper of oil, then work up.
A tincture is another option for new users of D8. These come in a glass bottle with a dropper that makes it easy to get a precise amount.
These products come in various potencies, so it’s essential to read the product’s recommended serving size and start with the smallest amount suggested. It’s also good to start with a short-lived delivery method like a flower or vaporizer, which wears off quickly and won’t build up your tolerance.
Side Effects
Delta 8 is a famous cannabinoid that produces many therapeutic benefits. It helps relieve pain, improves sleep, and boosts mood.
It is also a great stress reliever. However, there are some side effects to consider when taking it.
While it is generally safe, heavy doses may cause several side effects. Some common side effects include dry mouth, drowsiness, and dizziness.
The best way to avoid these side effects is to start small and go slow. Once you have a good idea of what the product does for you, increase your intake gradually as you need it.
You should also make sure that your gummies are lab-tested by a third party. This will ensure you get the total THC per gummy and avoid contaminants like pesticides and heavy metals.
Crosswords are a fun and challenging pastime that people of all ages can enjoy. But if you’re starting or are having trouble with them, there are a few things you can do to make them more manageable.
Start with the most superficial clues first and work your way up. This strategy will give you more hints and help you fill your grid faster.
Fill-in-the-blank clues
A crossword clue is a word or phrase placed across or down in a grid of squares. The answers to the clues are placed in the grid as well.
Some crosswords, especially those in British newspapers, feature fill-in-the-blank clues. These clues are often the easiest in a puzzle and are an excellent place to start solving.
Other clues involve a combination of words, usually designated with parentheses and brackets. These clues are often called “before and after” hints but could also be wordplay or pun clues.
Another type of clue is a cipher clue, which is closer to a code than a quiz, and requires more advanced problem-solving skills. English-language cipher crosswords are pangrammatic (all alphabet letters appear in the solution) and need some basic cryptographic techniques to solve.
The crossword solver uses a neural questioning answering algorithm to produce candidate solutions for each clue and a score indicating how good the solution might be. Some hints are simple definitions that are easy for a program to find, while others involve wordplay and puns, which are more challenging for machines to solve.
Multiple-letter answers
A grid of squares filled with letters that form words and phrases makes up a crossword puzzle, a type of word game. Answers are typically placed “across” the grid (left to right) and “down” the grid (top to bottom).
As you probably know, two kinds of clues are used to form words in a crossword puzzle: structural clues and semantic clues. Structural clues can be derived directly from the design of the unknown, while semantic clues often require general knowledge of a given topic.
One way to improve your chances of solving a puzzle is using multiple-letter answers. These are usually found in cryptic crosswords, where the words in a grid must be identified by filling in the blanks of the other solutions.
These multiple-letter answers are a great way to get your mind thinking about the clues and their possible meanings. They also help you recall information about the puzzle later on.
Several psychological studies have shown that generating an answer to a clue can improve memory retention. It may be due to the cognitive process of lateral and critical thinking involved in constructing crossword puzzles.
Fill-in-the-blank squares
Learning how to fill in the blanks in crossword puzzles is one of the best methods to get better at them. These squares can help you solve the mystery and make educated guesses.
Solving a crossword can be fun to pass the time and improve your vocabulary. It also helps improve your English language skills, as you need to pay attention to the nuance of the clues and how they relate to each other.
Typically, crosswords comprise a grid with white-shaded squares and a list of clues to the left and right. In each of the courts, you must use the right word.
Most of the answers in a crossword are written in a single direction, from left to right or top to bottom “across” and from bottom to top “down.” The letters may overlap with each other in some cases.
Many people find solving a crossword easier when they use fill-in-the-blank techniques to make educated guesses. These squares are often the hardest to get right, so practicing them before you try a crossword is essential.
Fill-in-the-blank gimmes
Crossword puzzles are a popular pastime that sharpens the brain and increases vocabulary. Some tips and tricks can help you solve crosswords more easily.
One of the most popular techniques is to use fill-in-the-blank gimmes. These gimmes differ from regular crosswords because they do not provide clues for the missing words.
In fill-in-the-blank puzzles, you will need to find the words in the correct order and place them correctly in the puzzle. It is a great strategy to use when trying to get a high score on a crossword.
Another technique to use when solving a fill-in-the-blank crossword is to look for words that have low-frequency letters. These letters are easier to spot, so they can help you make educated guesses when solving the puzzle.
If you are stuck on a clue, consider the puzzle’s theme to see if anything in it might help you find the answer. You can look for clues that contain quotations.
Make educated guesses
Crossword clues hold more information than you think, so take the time to read them carefully. It will assist you in reducing your options and preventing confusion.
It’s also a good idea to pay attention to the punctuation in the clues. For example, if the clue is in the past tense, you’ll probably see an answer in the present or future tense.
In addition, try to remember that many words have vowels disrupted regularly within them. It can be advantageous when looking at crossing clues, as it will help you make educated guesses about the first letters of the answers.
I want to learn some popular abbreviations and suffixes used frequently in American-style puzzles. It will make solving them more convenient.
You were reading the clues closely for homonyms, wordplay, and less-obvious answers. These clues can be tricky to interpret, but they will challenge you to think creatively. These tips will help you solve crosswords more efficiently and decrease your frustration.
To ensure that everything is magical and absolutely perfect on your special day, it’s vital to be organised. When placing an order for your luxurious and beautiful personalised wedding invites, don’t forget to put in a request for your wedding thank you cards.
The thank you card is an essential piece of wedding stationery. It’s what every happy couple uses to stylishly convey gratitude and love to family, friends and other guests that joined them in celebrating their nuptials. If you’re planning to wed, our ultimate guide to sending thank you cards offers everything you need to know to make the task of writing and mailing the important cards enjoyable and easy…
The Perfect Cards
Impress your VIP guests by showing off your personality, style and taste in the form of a stunning handcrafted wedding card that reflects your gratitude. While many couples choose to match all items of their luxury wedding stationery, there really are not hard and fast rules regarding the little cards that say a big ‘thank you’.
Keep it classy by choosing a bespoke thank you card design that complements your chic save the dates, wedding invites and RSVP cards. Alternatively, you can opt for a unique one-off design that’s creative, original and handmade.
If you’re tying the knot in a lavish ceremony with hundreds of guests in attendance, do bear in mind that it may not be practical to handcraft each thank you card yourself. Paying someone else to design and make your thank yous can seriously dent your wedding budget.
Professionally printed cards make much more sense, regardless of the size of your wedding party, as they free up your time to focus on other aspects of your event planning. To make your thanks yous look expensive, exclusive and luxurious, choose a design that includes stunning metallic inks, foiling, embossing or stamping.
The Recipient List
Although not every guest that you are inviting to your wedding may be able to attend, they may still choose to send you their best wishes and a wedding gift. You therefore need to ensure that you have sufficient wedding thank you cards available to send to everyone on your VIP guest list.
It’s helpful to create a list of guests and gifts received that you can easily check over when you finally set aside some time to write the cards. Make a note of any guests unable to attend that have kindly sent you a gift, so that you don’t accidently overlook them.
Personalise Your Prose
Wedding thank you cards offer a stylish and thoughtful way for you to thank everyone who contributed to your special day in some manner. Wedding etiquette dictates that these cards should cover the basics, and also include some prose personalisation.
When handwriting the thank you notes, it’s best to stick to a composition formula that allows you to speed up the process. Start by thanking your guest/s for making your wedding day so special and memorable. Express your genuine gratitude for their kindness and generosity by carefully choosing your words. Mention the specific gift, and write about how you plan to use it. Don’t be afraid to exercise some creativity, especially when thanking your family and friends for generic and practical household items.
If you’re stuck for writing inspiration you can always consider including a line of your favourite romantic poetry or song lyrics, or a classic quote that is love or marriage themed. A cheeky joke that puts a smile on the face of the thank you card recipient is another great idea.
Try not to get carried away when personalising your thank you prose. Keep the message short and sweet, and finish off with your preferred words that convey love and best wishes. If you and your spouse are not sharing the task of handwriting the notes of gratitude, it’s perfectly acceptable for you to sign off on their behalf.
Add A Photo
Many newly wed couples choose to include a striking wedding day photo with the thank you note. If the idea appeals to you too, you can choose to feature your favourite romantic image on the front of your beautiful handmade cards, or enclose a snap, in addition to the note, inside the envelope.
You can also ask a family member or a trusted friend to take candid shots throughout the big day, for later use with your thank yous. Get the images uploaded on your computer, or have them professionally processed and printed, and select the best ones to send with your handwritten cards.
Including a wedding photo is a lovely and thoughtful idea that will be appreciated by all guests in attendance, and those unable to join you at your celebration.
Sending Thank You Cards
Wedding etiquette recommends that you write and send your wedding thank you cards to everyone on your guest list within two weeks of getting married. So that you don’t break the traditional rule, pick a date and mark it on your calendar. Have a cosy night in with your spouse and share the workload of handwriting the notes and addressing the envelopes. If you’re including a photo, don’t forget to insert it in the envelope before sealing.
If you have a huge pile of cards to write, pace yourself so that your handwriting remains clear, tidy and readable. Working together will ensure that the task is completed in a timely manner, and you can catch the morning post!
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