The Bavarian Data Protection Authority (DPA) recently fined both a seller and purchaser “for unlawfully transferring customer data as part of an asset deal,” JDSupra reports. Citing the economic value of customer data, the report notes, “It frequently happens that a company tries to sell these high-value assets to another company as part of an asset deal.” In the Bavaria DPA case, the report states, “transferring customer email addresses requires prior customer consent or, alternatively, customers must be informed of the intent to carry out such a transaction beforehand to give them the opportunity to object.” While exact penalties were not released, the DPA “confirmed they were both five-figure sums and emphasised that the penalties were significant and incontestable.”
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