Client Alert: Transfers of Personal Data – No Monkey Business Allowed

The German state-level data protection authority for Bavaria (BDPA) recently issued a decision stating that the transfer of personal data to the US-based email marketing platform Mailchimp, by a company (which has not been officially named), was unlawful.

Ultimately, the BDPA declined to take formal enforcement action because the company stopped using Mailchimp in response to the complaint. Despite the lack of formal enforcement action, this decision by the BDPA is an important development highlighting the continuing repercussions of the Court of Justice of the EU’s (CJEU) ruling in Schrems II for international data transfers out of the European Union. For detail about Schrems II please see our client alert, available here.

To read the full article, please click here.

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

Client Alert: Transfers of Personal Data – No Monkey Business Allowed

The German state-level data protection authority for Bavaria (BDPA) recently issued a decision stating that the transfer of personal data to the US-based email marketing platform Mailchimp, by a company (which has not been officially named), was unlawful.

Ultimately, the BDPA declined to take formal enforcement action because the company stopped using Mailchimp in response to the complaint. Despite the lack of formal enforcement action, this decision by the BDPA is an important development highlighting the continuing repercussions of the Court of Justice of the EU’s (CJEU) ruling in Schrems II for international data transfers out of the European Union. For detail about Schrems II please see our client alert, available here.

To read the full article, please click here.

Related Capabilities

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

News and Insights

Event

Partner David Greenwald to Speak at PLI Program on Privilege and AI

On August 17, David Greenwald will speak at "Fitting New “Tech” Into the Attorney-Client Privilege and Work Product Protection," a virtual program hosted by the Practising Law Institute (PLI).

August 17, 2026

Publications

In Law360, Trump Debarment Threat Calls for Targeted Defense Plan

Partners Ashley Callen and David Robbins authored an article for Law360 examining how entities should respond when suspension or debarment is threatened directly by the president, rather than initiated through the usual agency-driven process.

August 6, 2026

Publications

"DC Circuit Undercuts Congress's Subpoena Power: Important New Authority for Targets of Congressional Investigations," National Law Journal

In the National Law Journal, Congressional Investigations Co-Chair Emily Loeb, Special Counsel David Manners-Weber, and Associate Kate Mather examine a recent DC Circuit decision that gives fresh weight to 2020 Supreme Court dicta on common-law privileges in congressional investigations.

July 30, 2026