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ARTICLE · 10 NOVEMBER 2016

EU Court Rules That Dynamic IP Addresses Are Personal Data…Sometimes

Proskauer Rose LLP
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On October 19, the Court of Justice of the European Union (CJEU) ruled that dynamic IP addresses may qualify as "personal data" under EU privacy law.

European UnionPrivacy

On October 19, the Court of Justice of the European Union (CJEU) ruled that dynamic IP addresses may qualify as "personal data" under EU privacy law. As we covered here on the blog a few months ago, this decision is significant because it clarifies that companies that collect, store, process, and/or transfer dynamic IP addresses belonging to EU users may have to treat them in accordance with the stringent restrictions that EU law imposes on the handling of personal data. As a refresher, an IP (short for "Internet protocol") address is a series of numbers allocated to a specific device that identifies a device and allows it to access an electronic communications network, such as the Internet. IP addresses can be either "dynamic" or "static"; dynamic IP addresses, which are more common, change every time the device connects to the Internet, while static IP addresses remain constant and do not change every time the device re-connects.

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