> IANAL, but only one person in this discussion has mentioned that they
> HAVE consulted one that specializes in data privacy - who confirms that
> specifically, for a US keyserver operator operating a US keyserver, GDPR
> has *absolutely no bearing* even if we *weren't* exempt.

Minor nit: that was the advice I received, tailored to my specific
situation.  Other US-based operators in different situations may have
different legal exposure.  The more connections a US operator has to the
EU, the greater the EU's ability to apply leverage.

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