Greece: Hellenic Data Protection Authority issued interim ruling in investigation into DeepSeek Artificial Intelligence requiring appointment of EU representative

On 21 May 2025, the Hellenic Data Protection Authority (HDPA), in the context of its ex officio investigation into the DeepSeek Artificial Intelligence application, issued Interim Ruling 18/2025. The ruling found that Hangzhou DeepSeek Artificial Intelligence Co., Ltd. falls within the territorial scope of the General Data Protection Regulation (GDPR) pursuant to Article 3(2)(b), as its processing activities relate to the offering of services to individuals located in the European Union, and in particular in Greece, despite the company not being established in the EU. The Authority determined that the company had failed to comply with the obligation under Article 27 GDPR to designate a representative within the EU, and accordingly issued a corrective order requiring the company to appoint an EU-based representative in writing and to notify the Authority.