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I'm developing an application for mobile/web/desktop that will (in very watered down basic terms) store free text strings they've self-contributed and access them freely.

As it stands, these applications can run without processing data and storing everything locally on the device. However, if I want to save the users data to a server in order for them to load the same information on multiple devices, I will be storing and processing data.

The reason I'm hitting a brick wall in trying to track down the legal issues involved here are twofold:

  1. If the developer is based in the EU and the server is based in the US, which jurisdiction does this fall under?
  2. If I'm storing just an e-mail address and unique identifier key in the database for login, would this in itself, be identifiable information? Would a user storing the text string "Mop floor tonight" be considered personal data? I ask because as this is free text, I'm aware a user could essentially type "My name is Dave Smith and I live at 742 Evergreen Terrace" and suddenly that's very personal data.

I'm just trying to get my head around the risks/efforts involved in having a simple "sync to all devices" command that can be manageable by a 1 person developer team. Are there perhaps exemptions for small businesses who's IP is the code itself and not the data (ie, I'm just collecting a username/email for login, no other data, not writing to the e-mail or using that data to generate revenue etc), and the self-supplied data is essentially just there to enable a feature? Or is this a legal framework I'll have no choice but to consider globally for all users?

  • Where are the data subjects? – Lag Jun 3 at 15:50
  • Hi @RazorKillBen, I am voting to close because this question is asking for legal advice. Please generalize the question if possible. – Andrew Jun 3 at 17:35
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  1. If the developer is based in the EU and the server is based in the US, which jurisdiction does this fall under?

Every jurisdiction where the app is accessible. So, pretty much every jurisdiction.

  1. If I'm storing just an e-mail address and unique identifier key in the database for login, would this in itself, be identifiable information?

Yes. Email addresses are personal information.

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