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    18.12.2025

    Privacy Ticker December 2025

    The December issue of our Privacy Ticker deals with the changes in  the current case law, regulatory investigations and enforcement actions and opinions.

    Topics in this issue are:

    Case law

    • ECJ: Hosting Providers can be Rsponsible for User Content
    • Federal Court of Justice: Damages for Failure to Delete Data by the Processor
    • Berlin Administrative Court: Purpose of the Request for Information Irrelevant for Assertion
    • Lübeck Regional Court: Damages of EUR 5,000 for Meta Business Tools

    Regulatory investigations and enforcement actions

    • CNIL: EUR 1.5 Million Fine Against American Express for Cookie Violations
    • CNIL: EUR 750,000 Fine on Publisher for Cookies without Consent and Ineffective Refusal

    Opinions

    • EDPB: Recommendations on the Admissibility of Mandatory User Accounts in E-Commerce

    The Privacy Ticker is available under this link or in the download area below.

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    Dusseldorf
    Christian Frederik Döpke
    Rechtsanwalt, LL.M., LL.M.
    Senior Associate
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    Frankfurt/Main
    Fabian Eckstein
    Rechtsanwalt, LL.M. (Melit.)
    Senior Associate
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    Frankfurt/Main
    Mirjam Kaiser
    Rechtsanwältin
    Senior Associate
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    Frankfurt/Main
    Susanne Klein
    Rechtsanwältin, LL.M., Licensed Specialist for Information Technology Law, external data protection officer (certified by TÜV Nord)
    Partner
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    Frankfurt/Main
    Jason Komninos
    Rechtsanwalt, LL.M., Licensed Specialist for Information Technology Law
    Senior Associate
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    Frankfurt/Main
    Lennart Kriebel
    Rechtsanwalt
    Partner
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    Frankfurt/Main
    Dr Andreas Lober
    Rechtsanwalt
    Partner
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    Munich
    Katharina Mayerbacher
    Rechtsanwältin, Licensed Specialist for Information Technology Law, external data protection officer (certified by TÜV Rheinland)
    Partner
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    Munich
    Dr Birgit Münchbach
    Rechtsanwältin, Licensed Specialist for International Commercial Law, Commercial and Corporate Law and Information Technology Law
    Partner
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    Dusseldorf
    Mathias Zimmer-Goertz
    Rechtsanwalt
    Partner
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