Procedure Rules, 2010. 70.On the question of whether there was an adequate Data Protection Impact Assessment (DPIA) by TFH US, TFH GmbH and the WorldCoin Foundation, it is submitted that Regulation 49 of the Data Protection (General) Regulations, 2021 classifies processing operations likely to present high risks, including: (a) automated decision-making or profiling with legal or similar effects; (b) largescale processing for a purpose other than originally intended; (c) processing of biometric or genetic data; (d) changes increasing risk to data subjects; (e) largescale processing of personal data; and (f) use of innovative technology or organizational methods. 71.The 6th Respondent further submits that the statement by the 5 th Respondent’s director denying that Platinum De Plus was a data processor contradicts his own depositions on oath at paragraphs 20 to 22 of his affidavit, where he depones that Platinum De Plus helped users claim WLD tokens and had no interaction with personal data. It is also submitted that even so, the Multi-Agency Investigation Report (MAIR) (page 61 of Thomas Scott’s affidavit) concluded that Platinum De Plus operated as an Orb operator and collected personal data under the guise of marketing Worldcoin. 72.That the MAIR Report further discloses (at page 66) that some “Worldcoin staff” installed the Worldcoin App for users, accepted the terms and conditions Page 27 of 84

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