...that Act grants non-U.S. citizens among other rights, a private right of
action for alleged privacy violations that occur in the U.S. but limits the
right to sue to those citizens of countries that (1) permit the “transfer
of personal data for commercial purposes” to the U.S., and (2) do not
impose personal data transfer policies that “materially impede” U.S.
national security interests.
There are implications for the so-called Umbrella Agreement as well as the
new Safe Harbour provisions.
-Carlton
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Carlton A Samuels
Mobile: 876-818-1799
*Strategy, Planning, Governance, Assessment & Turnaround*
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