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Anyone here know which country laws apply to user data when a startup based in a different country (ex: UK), than where user data resides (ex: Switzerland) ?

Switzerland have better privacy (not perfect) than other countries, So I am deciding to store user data in Switzerland data center, so user data is protected by Swiss laws.

But I am not sure which country laws apply to user data?

Someone please help. Thanks in advance!

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The country where you are, where the user is and where the data is

So if you are in the UK, your data is in Switzerland and your user is in China and is an Australian/Thai dual national then potentially the laws of the UK (noting that this is 3 separate jurisdictions), Switzerland (each canton being a separate jurisdiction), China (which I think is only a single jurisdiction), Australia (8 possible jurisdictions) and Thailand (single jurisdiction I think) all potentially apply.

Of course, your second user may introduce more jurisdictions.

It is certain that all these jurisdictions will impose different, even incompatible, requirements.

If this is hard, the governments of those jurisdictions don’t care.

You need a lawyer.

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  • Thanks for the answer, so simply you means laws of every users country can be applied, but the mix of country laws (data center located country, user country, HQ country) can make things complicated?
    – kaushalyap
    Mar 8, 2020 at 10:43
  • @user158 yes, jurisdiction doesn’t stop at national (or state/province/canton etc) boundaries. It’s complicated but there are lawyers who know the complexities.
    – Dale M
    Mar 8, 2020 at 11:27
  • I wonder what happens if it is dapp (on decentralized blockchain)? Will it make things much more complicated?
    – kaushalyap
    Mar 8, 2020 at 11:32

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