72. In passing, the Board would also indicate its agreement with the submission of the Respondent that practically it will be difficult to dissect the data cycle at different stages for the purpose of applying different Data Protection Principles and provisions of the Ordinance to different stages. That adds to the illogic of treating the processing requirement as a sufficient requirement or that both control and processing requirements need to be satisfied in the context of territorial jurisdiction of the Ordinance. G . Whether Google LLC Lies Outside of the Territorial Jurisdiction of the Ordinance 73. It is not in dispute that Google search is operated by Google LLC and not Google HK. As submitted by Google LLC, Google LLC does not have any establishment or ofice in a company based in Hong Kong. 74. As submitted by Google LLC, which the Board accepts，Google search is a search engine which helps web users to find websites they are likely to be interested in. Google LLC operates Google search in three ways: crawling, indexing and serving of results. Crawling: Google LLC uses a software called crawler. The a . crawler first sends requests to web servers for the contents of the websites the web servers host. The operators or publishers of the websites then respond, say by accepting the requests and providing all or part of the contents, or by refusing the requests. b . Indexing: Google LLC compiles indexes for the crawled contents. As crawling is an ongoing process, any updates 53