If you are a controller based outside of the EU, but you are offering goods or services (even for free) to EU-based users or you are monitoring their behaviour as far as it’s taking place within the EU, you have to appoint an EU-representative established in one of the EU countries your Users are based in.
You can read more about the requirement in our GDPR Offline Compliance Duties article.
Since we want to help our users on as many fronts as possible, we’ve made an EU Representative Appointment template. The template is currently available via Quip (where you can export – top left corner – into various file formats) and .docx direct download:
Since this is only a starter template, it is provided as-is and its content is offered without warranty of completeness or correctness.