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Exam CIPT Topic 4 Question 201 Discussion

Actual exam question for IAPP's CIPT exam
Question #: 201
Topic #: 4
SCENARIO
Please use the following to answer the next question:
Jordan just joined a fitness-tracker start-up based in California, USA, as its first Information Privacy and Security Officer. The company is quickly growing its business but does not sell any of the fitness trackers itself. Instead, it relies on a distribution network of third-party retailers in all major countries. Despite not having any stores, the company has a 78% market share in the EU. It has a website presenting the company and products, and a member section where customers can access their information. Only the email address and physical address need to be provided as part of the registration process in order to customize the site to the user's region and country. There is also a newsletter sent every month to all members featuring fitness tips, nutrition advice, product spotlights from partner companies based on user behavior and preferences.
Jordan says the General Data Protection Regulation (GDPR) does not apply to the company. He says the company is not established in the EU, nor does it have a processor in the region. Furthermore, it does not do any "offering goods or services" in the EU since it does not do any marketing there, nor sell to consumers directly. Jordan argues that it is the customers who chose to buy the products on their own initiative and there is no "offering" from the company.
The fitness trackers incorporate advanced features such as sleep tracking, GPS tracking, heart rate monitoring.
wireless syncing, calorie-counting and step-tracking. The watch must be paired with either a smartphone or a computer in order to collect data on sleep levels, heart rates, etc. All information from the device must be sent to the company's servers in order to be processed, and then the results are sent to the smartphone or computer.
Jordan argues that there is no personal information involved since the company does not collect banking or social security information.
Why is Jordan's claim that the company does not collect personal information as identified by the GDPR inaccurate?

Suggested Answer: B Vote an answer

Under the GDPR, personal data includes any information relating to an identified or identifiable natural person. The fitness trackers collect detailed health-related data, such as sleep patterns and heart rates, which are considered sensitive personal data under the GDPR. This type of data directly relates to an individual's health and behavior, making it subject to GDPR protections regardless of whether financial information is collected. Jordan's claim that the company does not collect personal information is inaccurate because health data is a core category of personal data under the GDPR.
Reference:
GDPR Article 4, Definitions.
IAPP Certification Textbooks, particularly the sections on GDPR and the definition of personal data.

by Violet at Jan 31, 2026, 07:44 AM

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