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Showing posts from December, 2020

CNIL’s sanctions against Google LLC and Google Ireland Limited and against Amazon Europe Core: summary and main findings

 On 10 December 2020, the CNIL made public two decisions regarding the use of cookies in breach of Article 82 of the French Loi Informatique et Libertés (the “LIL”), which transposes the ePrivacy Directive 2002/58/EC (“ePrivacy Directive”). The first sanction, against a Google LLC and Google Ireland Limited (together “ Google ”) was for a total amount of €100 million (€60m for Google LLC and €40m for Google Ireland Limited, or “GIL”). The other sanction was imposed on Amazon Europe Core (“ Amazon ”) for €35m.  Set out below is a summary of both decisions, with a specific focus on the arguments and reasoning relating to the CNIL’s competence to enforce the provisions of the LIL against Google and Amazon, which is the subject of substantial and interesting developments. The two decisions have a number of points in common, although some of the interesting nuances are noted in our summary.  1. Background In relation to Google, the CNIL conducted an online audit of on 16 March 20