It depends on where your customers are
Most modern privacy laws reach beyond their own borders. They apply because of whose data you handle, not just where your company is registered. A company in India selling to customers in Europe is covered by GDPR; a US company selling to customers in India is covered by the DPDP Act.
| Law | What brings a foreign business in |
|---|---|
| India: DPDP Act 2023 | Processing connected with offering goods or services to people in India (s.3) |
| EU GDPR | Offering goods or services to, or monitoring the behaviour of, people in the EU (Art 3(2)) |
| UK GDPR | The same tests, for people in the UK (Art 3) |
| Brazil: LGPD | Processing personal data of individuals located in Brazil, or offering goods or services to them (Art 3) |
| Canada: PIPEDA | Personal information collected, used or disclosed in the course of commercial activities (s.4) |
| California: CCPA/CPRA | Doing business in California and meeting a revenue, volume or data-sales threshold (1798.140(d)) |
Other US states have their own thresholds. See the US state privacy law checker.
The good news: the security work overlaps
These laws differ on legal bases, notices and rights, which is work for privacy counsel. But they all expect reasonable security and a working breach response. One set of controls (encryption, access control, logging, tested backups, a breach runbook) covers the security duty in all of them.
The checker above tests two things: where you are incorporated and where your customers are. It ignores exemptions, revenue tests and sector rules, so use it as a starting list. Read about the DPDP Act and GDPR Article 32.
Sources
- DPDP Act, 2023, s.3 (MeitY); GDPR Art 3 (EUR-Lex); UK GDPR Art 3
- LGPD Art 3; PIPEDA s.4; Cal. Civ. Code 1798.140
Facts checked against the sources above on 22 October 2026. General information, not legal advice.
