In Part I, we discussed the European Commission’s (“Commission”) disapproval of Meta’s “pay or consent” subscription model. In Part II, we delve into the European Commission’s findings, prior findings by the European Data Protection Board (EDPB), and how those findings may affect future models where privacy is considered “for sale.”


The privacy law landscape is constantly changing, and it can feel like a daunting task for businesses to keep up with the laws of 50 states in the U.S. plus any international laws that also may be applicable. 2020 seems to be a banner year for change on many fronts. COVID-19 and the 2020 elections