2 articles
EU–US transfers
Cross-border data flows after Schrems II and the 2023 Adequacy Decision — TIAs, SCCs, and where the AI providers actually sit.
AI Privacy
When you call OpenAI, who actually processes your data? The AI sub-processor cascade
A trace-walk of one OpenAI API call through every entity in the cascade, with the Article 28, CLOUD Act, Article 48, and DMA layers stacked on top.
13 min read
AI Privacy
Sending data to OpenAI, Anthropic, or Google? The 2026 state of EU-US AI transfers
Section 702 sunsets April 20. The April 2026 state of EU-US AI transfers, what the DPF actually rests on, and the contract review you should do this week.
13 min read