A small UK-based app developer stopped using Firebase Analytics and removed their app from EU distribution on Apple and Google Play stores due to concerns about GDPR Article 27 compliance risks...

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  "detected_at": "2026-09-27T16:39:24+00:00",
  "company": {
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    "topics": [
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    "post_id": "1wrow3s",
    "summary": "A small UK-based app developer stopped using Firebase Analytics and removed their app from EU distribution on Apple and Google Play stores due to concerns about GDPR Article 27 compliance risks associated with the product.",
    "category": "security",
    "comments": [
      {
        "url": "https://www.reddit.com/r/gdpr/comments/1wrow3s/comment/pcebcuj/",
        "depth": 0,
        "score": 41,
        "author": "DarlingBri",
        "excerpt": "This was not a targeted email this was just your name on a blast list of app developers. If you collect no personally identifiable information, article 27 does not apply to you at all.\n\n This is basically a scam.",
        "posted_at": "2026-09-27T16:47:38.000Z",
        "author_url": "https://www.reddit.com/user/DarlingBri/"
      },
      {
        "url": "https://www.reddit.com/r/gdpr/comments/1wrow3s/comment/pceeqvz/",
        "depth": 0,
        "score": 14,
        "author": "cortouchka",
        "excerpt": "I applaud you for taking this seriously, doing your own research and even making changes to what you're doing.\n\n As already mentioned though, this is a scammy sales tactic and you were fine as you were.",
        "posted_at": "2026-09-27T17:01:35.000Z",
        "author_url": "https://www.reddit.com/user/cortouchka/"
      },
      {
        "url": "https://www.reddit.com/r/gdpr/comments/1wrow3s/comment/pcev8ir/",
        "depth": 0,
        "score": 6,
        "author": "xasdfxx",
        "excerpt": "real-world risk\n\n falling to a scam.\n\n For starters: it's not at all obvious your app is subject to GDPR. To be so subject, it must target the EU. Because EU, there isn't a bright line there. Things that would make it an obvious yes: advertising in the EU. Almost certainly yes: building in EU-specific languages. Probably yes: offering payment (outside the app store) in euros (only probably because",
        "posted_at": "2026-09-27T18:07:06.000Z",
        "author_url": "https://www.reddit.com/user/xasdfxx/"
      },
      {
        "url": "https://www.reddit.com/r/gdpr/comments/1wrow3s/comment/pceiko2/",
        "depth": 0,
        "score": 4,
        "author": "Comfortable-Fall1419",
        "excerpt": "It’s a scam. Ignore it.\n\n You can even leave firebase on by disabling PIP or put a consent banner before it.",
        "posted_at": "2026-09-27T17:17:06.000Z",
        "author_url": "https://www.reddit.com/user/Comfortable-Fall1419/"
      },
      {
        "url": "https://www.reddit.com/r/gdpr/comments/1wrow3s/comment/pcf852d/",
        "depth": 0,
        "score": 2,
        "author": "Biddles81",
        "excerpt": "It's always helpful to call these organisations out so that they can be subjected to the might of the community's collective scrutiny.\n\n If you don't feel able to, and I recognise why you might not want to, perhaps someone else who recognises these tactics might shine a light on their similar experiences from an anonymous account?",
        "posted_at": "2026-09-27T18:58:02.000Z",
        "author_url": "https://www.reddit.com/user/Biddles81/"
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      {
        "url": "https://www.reddit.com/r/gdpr/comments/1wrow3s/comment/pch1mfi/",
        "depth": 0,
        "score": 2,
        "author": "SiteRelEnby",
        "excerpt": "Not worried. Don't actively market it in the EU specifically, and you're fine until you get big enough that the cost of a GDPR rep (which can be had for closer to $100-200/yr, $500/yr is bullshit) is no longer prohibitive. Until that time, just make sure you have a clear contact like privacy@, gdpr@, etc going to an inbox that's monitored.\n\n Predatory companies being scummy, nothing more. Same sor",
        "posted_at": "2026-09-27T23:36:27.000Z",
        "author_url": "https://www.reddit.com/user/SiteRelEnby/"
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        "url": "https://www.reddit.com/r/gdpr/comments/1wrow3s/comment/pciyycj/",
        "depth": 0,
        "score": 1,
        "author": "Eisn",
        "excerpt": "Do you have a backend server that the app connects to? Do you have a website for the app that also has things like user accounts?",
        "posted_at": "2026-09-28T06:38:27.000Z",
        "author_url": "https://www.reddit.com/user/Eisn/"
      }
    ],
    "evidence": [
      "[post] I did use Firebase Analytics, but I have now completely unlinked Google Analytics from the Firebase project.",
      "[post] As soon as Article 27 was brought to my attention, I removed the app from both Apple and Google Play throughout the EU/EEA."
    ],
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    "post_date": "2026-09-27T16:39:24.000Z",
    "post_kind": "text",
    "post_text": "I’m a UK-based indie developer with a small budgeting app.\n\nA company recently cold emailed me out of the blue saying that because my app had been available to EU users, GDPR Article 27 required me to appoint an EU representative. They were selling this service for around €490/year.\n\nThat email is what prompted me to look into all of this.\n\nMy situation:\n\n- Very few users and essentially no revenue.\n\n- No user accounts or backend.\n\nI don’t collect names, email addresses or other obvious identifying information.\n\n- Users enter their budgeting/financial data locally on their own device.\n\nOptional backups go to the user’s own iCloud/Google Drive account. I don’t receive or have access to those backups.\n\n- I did use Firebase Analytics, but I have now completely unlinked Google Analytics from the Firebase project.\n\nAs soon as Article 27 was brought to my attention, I removed the app from both Apple and Google Play throughout the EU/EEA.\n\nI am no longer offering the app or in-app purchases to EU/EEA users.\n\nI understand that removing the app now doesn’t necessarily determine what the legal position was historically.\n\nWhat I’m trying to understand is the real-world risk for someone in my position.\n\nHas anyone here dealt with Article 27 as a very small non-EU developer?\n\nWould Article 27 actually have applied to an app with this architecture and such limited processing?\n\nNow that...",
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    "subreddit": "gdpr",
    "event_date": "2026-09",
    "post_flair": [
      "EU 🇪🇺"
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    "post_title": "Small UK indie app developer cold-emailed about GDPR Article 27 - how worried should I actually be?",
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    "source_url": "https://www.reddit.com/r/gdpr/comments/1wrow3s/small_uk_indie_app_developer_coldemailed_about/",
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    "total_upvotes": 11,
    "comments_total": 38,
    "total_comments": 33,
    "event_date_text": "now",
    "other_companies": [
      {
        "name": "Apple",
        "role": "partner",
        "domain": "apple.com"
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    "comments_included": 7,
    "products_mentioned": [
      "Firebase Analytics",
      "Google Analytics",
      "Google Play"
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