WebFun is an internet start-up company operating out of California, but its services are accessed by users globally through its mobile apps and devices available for download on Google Play and the App Store. Some of these services collect and analyze health data of its users (e.g. how many steps taken in a day, heart rate, etc.). WebFun has no office in the EU and the only language its apps, devices, and services offer and run on is English, though it is working to develop a Privacy Policy in Spanish. Do you think WebFun is subject to the GDPR?

Case C 131/12 Google Spain and Google v. Agencia Espaola de Proteccin de Datos (AEPD)[2014] CJEU, C-398/15, Camera di Commercio, Industria, Artigianato e Agricoltura di Lecce v. Salvatore Manni, 9 March 2017. Article 29 Working Party (2014), Guidelines on the implementation of the CJEU judgment on "Google Spain and Inc v. Agencia Espaola de Proteccin de Datos (AEPD) and Mario Costeja Gonzlez" C-131/12, WP 225, Brussels, 26 November 2014. GDPR, Recitals 65, 66; Article 17.