Sherry Gong, Tommy Liu, Tong Zhu, and Flora Feng of Hogan Lovells write:
On April 25, 2023, the state-backed Guiyang Big Data Exchange (GYDE) announced that it has facilitated and supervised the unprecedented floor trading of personal data in China. To date, no provisions have been put in place to specifically address the compliance requirements for data sales at the national level. With this context and the vague language of the trading frame of GYDE, this case will greatly inspire other market players who intend to be engaged in data sales involving personal data in China.
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