C037-224 Twitter International Company, Twitter, Inc.

Pointing out to the DPC that they should investigate in full and take into account the legal provisions mentioned in the complaints.

Requested to clarify the choice of the controller (TIC and not Twitter, Inc.), plus requested to adjust the scope of the investigation

DPC has commenced an Inquiry under Section 110 1 of the Act 18

In the meantime, the DPC is continuing its examination of the complaint and in due course we will invite the complainant to make submissions on a Preliminary Draft Decision prior to the submission of a Draft Decision to Concerned Supervisory Authorities under the GDPR's Article 60 process.

We continued to argue that the DPC investigates whether Twitter Inc or TIC was a controller for MoPub

"The DPC will follow up with Twitter in relation to the matters raised in your submission and we will be in contact with you in due course."

Twitter argues that it sold all titles related to the MoPub domain to Applovin. The DPC says we filed the complaint against Twitter Ireland so it will continue to investigate this entity. We insist that Twitter, Inc. is liable for MoPub's past violations and that the deletion of all of the Complainant's data should not prevent the DPC from sanctioning Twitter.

DPC sends a letter to noyb. Twitter claims that it transferred all rights, titles and interests in the mopub.com domain name to Applovin Corporation in February 2022. Moreover, all the data collected has been deleted.

noyb email to the DPC requesting to investigate which of the Twitter entities was factually a controller for MoPub.

Irish lawyers send a letter on behalf of noyb to the DPC

the DPC confirms it will open an investigation against Twitter MoPub

noyb insists the DPC invesitages Twitter MoPub and informs that if no settlement is reached by 1 December 2022 we will refuse to amicably resolve the complaints.

DPC wrote they won't investigate Twitter MoPub because MoPub was acquired by Applovin at the end of 2021.

noyb responded to the DPC that they excluded one case from their list of complaints and requested that all complaints be covered.

DPC confirmed they will start the investigation of 17 complaints.

DPC one-liner they will respond in the coming days

noyb responded that the DPC is competent to investigate the cases under the GDPR and that it does not make sense to forward them to the telecoms authorities abroad. noyb provided evidence that personal data was processed when submitting complaints.

DPC letter insisting they are not competent to investigate

DPC worte that they will respond in the coming days.

noyb responded that that (1) this does not make sense under Irish ePrivacy law and (2) the complaint is brought also under GDPR and their own ePrivacy guidance says that if there is personal data in cookie, GDPR applies too. We told them to get back by 19

DPC wrote that their assessment suggests that the DPC may not be the competent authority to carry out investigations under Regulation 17 of S.I. No. 336 of 2011 because the complainant's device was outside of Ireland at the time of the violation.

DPC wrote "The purpose of this letter is to inform you that the DPC is still considering these complaints and the appropriate legislative framework under which to deal with them."

noyb asked to indicate a specific date when the next update can be expected and when we can get access to the submissions, if any were made.

DPC acknowledged receipt of the complaint and is assessing it.