consent is voluntary, and (c) the consent is specific to the processing purpose. Regulation 4(4) further states that consent is not free where: it is presumed from silence; made a non-negotiable term; withdrawal results in detriment; multiple purposes are bundled without specific consent for each; or the data subject’s intent is ambiguous. 76.The 6th Respondent further submits that the standards under section 2 of the DPA and Regulation 4 (3) and (4) are mirrored in Article 4 of the EU GDPR, which defines consent in the same manner. It is submitted that these provisions require that each distinct purpose for data processing be accompanied by its own, clear consent. 77.According to the 6th Respondent, the Worldcoin Data Consent Form v2.2, submitted by TFH US and TFH GmbH, seeks a single consent for multiple processing purposes. These include calculating and comparing unique identifiers, optimizing algorithms, training AI models using iris images, detecting human users and personnel training. 78.That the form’s introductory paragraph states that users agree to the collection of iris data and its transfer to facilities in Germany and other countries for training neural networks. The concluding statement is said to confirm the explicit consent to transmit data to multiple countries including the U.S., India, Japan, UK and the Germany. It is the 6th Respondent’s submission that the Page 29 of 84

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