Q: 14
SCENARIO
Please use the following to answer the next question:
T-Craze, a German-headquartered specialty t-shirt company, was successfully selling to large German
metropolitan cities. However, after a recent merger with another German-based company that was
selling to a broader European market, T-Craze revamped its marketing efforts to sell to a wider
audience. These efforts included a complete redesign of its logo to reflect the recent merger, and
improvements to its website meant to capture more information about visitors through the use of
cookies.
T-Craze also opened various office locations throughout Europe to help expand its business. While
Germany continued to host T-Craze’s headquarters and main product-design office, its French
affiliate became responsible for all marketing and sales activities. The French affiliate recently
procured the services of Right Target, a renowned marketing firm based in the Philippines, to run its
latest marketing campaign. After thorough research, Right Target determined that T-Craze is most
successful with customers between the ages of 18 and 22. Thus, its first campaign targeted university
students in several European capitals, which yielded nearly 40% new customers for T-Craze in one
quarter. Right Target also ran subsequent campaigns for T- Craze, though with much less success.
The last two campaigns included a wider demographic group and resulted in countless unsubscribe
requests, including a large number in Spain. In fact, the Spanish data protection authority received a
complaint from Sofia, a mid-career investment banker. Sofia was upset after receiving a marketing
communication even after unsubscribing from such communications from the Right Target on behalf
of T-Craze.
Why does the Spanish supervisory authority notify the French supervisory authority when it opens
an investigation into T-Craze based on Sofia’s complaint?
Options
Discussion
Option C fits here. The French affiliate runs all marketing and sales, so under GDPR, the French supervisory authority is the lead for those processing activities. That’s why Spain notifies France if it opens an investigation about marketing to Spanish users. Pretty sure that’s how the one-stop-shop mechanism works. Let me know if you read it differently.
Be respectful. No spam.
