Your EU Data Act Legal Representative in Ireland

Yes, if the Data Act applies to you. The Data Act representative under Article 37(11) is a separate appointment from the GDPR representative under Article 27 and from the DSA representative under Article 13. A company can need two or all three. Gabsor can appoint all of them and manage them from one account.

An item that obtains, generates or collects data about its use or environment and can communicate that data, whether over a network connection, through physical access or on-device access. Examples are IoT devices, smart home products, wearables, connected vehicles, industrial machinery and sensors, and medical devices that generate usage data. Apps and services that make a connected product function or add features to it are "related services" and are also covered.

It can. Providers of data processing services, which includes cloud, edge, IaaS, PaaS and SaaS, are within the scope of the Data Act. If you offer such services in the EU and are not established there, Article 37(11) requires you to designate a legal representative.

No. Article 37(11) has no size exemption. Some substantive Data Act obligations have exemptions for micro and small enterprises, but the representative obligation is not among them.

Under Article 37(13), you are treated as under the competence of the Member State where your representative is located. Our representative is established in Ireland, so the Irish competent authority under the Data Act becomes your point of contact. That replaces the default position, where every Member State may exercise jurisdiction over you until a representative is designated.

No. The Data Act has no publication requirement, unlike the DSA. Article 37 only requires you to designate a representative. We still recommend listing the details in your terms or legal notice so authorities and EU customers can reach your representative directly, and we give you ready-to-paste text for that.

No. Unlike the DSA representative, the Data Act representative does not assume liability for your compliance. The representative is a point of contact that cooperates with competent authorities and, on request, demonstrates the steps you have taken to comply. Legal responsibility stays with you. That makes this a clean, low-friction appointment.

Under Article 37(14), until a representative is designated the competent authorities of every Member State may exercise jurisdiction over you, including imposing penalties. Penalties are set by each Member State and must be effective, proportionate and dissuasive. Where personal data is involved, GDPR fines can also apply. Designating a representative consolidates jurisdiction to one Member State.

They are separate appointments under separate regulations. The DSA representative under Article 13 is for intermediary services such as hosting, platforms and search engines, and can be held liable for the provider's non-compliance. The Data Act representative under Article 37 is for connected products, related services, data holders and recipients, and data processing services, and does not assume liability. A company offering both a connected product and a hosting service may need both.