TL;DR: I got a response from Reddit that basically says they’re not violating anything.
There was a post here 3 weeks ago that talked about the GDPR violations Reddit is committing.
reddit is telling it's future investors with recent news and more info on their IPO, that they're currently selling and looking to sell their user's data to companies wanting to train their LLMs, including Google.
I’m not sure of anyone else has gotten a response from them yet so I thought I’d share the email.
The Email:
Hello,
Thank you for contacting Reddit.
As stated in Reddit's Privacy policy much of the information on the Services is public and accessible to everyone, even without an account. By using the Services, you are directing us to share this information publicly and freely.
Reddit prohibits use of its service to infringe people’s intellectual property rights or any other proprietary rights, and prohibits unauthorized scraping of Reddit content. Please note, however, that when you submit content (including a post, comment, or chat message) to a public part of the Services, any visitors to and users of our Services will be able to see that content, the username associated with the content, and the date and time you originally submitted the content.
Reddit allows moderators to access Reddit content using moderator bots and tools. Reddit also allows other third parties to access public Reddit content using Reddit's developer services, including Reddit Embeds, our APIs, Developer Platform, and similar technologies. We limit third-party access to this content. Reddit's Developer Terms are our standard terms governing how these services are used by third parties.
Please note that you can use the Services without choosing to share information publicly and freely on them, and you can also remove your content from Reddit at your discretion. For more information, please check out our help center articles for more information here
They're not infringing on your copyright, because you agreed to the following:
[...] you grant Reddit the following license to use that Content:
When Your Content is created with or submitted to the Services, you grant us a worldwide, royalty-free, perpetual, irrevocable, non-exclusive, transferable, and sublicensable license to use, copy, modify, adapt, prepare derivative works of, distribute, store, perform, and display Your Content and any name, username, voice, or likeness provided in connection with Your Content in all media formats and channels now known or later developed anywhere in the world. This license includes the right for us to make Your Content available for syndication, broadcast, distribution, or publication by other companies, organizations, or individuals who partner with Reddit. You also agree that we may remove metadata associated with Your Content, and you irrevocably waive any claims and assertions of moral rights or attribution with respect to Your Content.
Is that an EULA? I thought that was for buying software? I mean I'm pretty sure we have other forms of contracts here in the EU?! Like Terms of service.
Is that a known fact about Reddit's terms of service / "EULA", or something you made up?
And some EULA's are valid in the EU. Just not the American ones that you get to read after you bought something.
Ah, that makes more sense. But the GDPR also doesn't regulate the actual content. It is about personal data. You can revoke consent processing that. But that doesn't necessarily touch copyright and the content of some text you licensed to someone. I think copyright is seperate. I mean it's a bit more complicated, there is some overlap...
I think this is the issue here. OP is mixing content copyright with the GDPR. But the GDPR regulates personal data, not copyright on text. And that's what Reddit is trying to sell, the content of posts, not their user's personal data... So the GDPR doesn't apply to that. Hence Reddit say they aren't violating anything, because the copyright is in the ToS.
I think that's also my issue with the original letter. It wants to sound official and legalese, but it confuses several things. Intellectual property, copyright and privacy /data protection laws. I don't think the author(s) understand the GDPR. It includes a definition what personal data is. And the letter is mostly talking about something unrelated. Also there are additional requirements. For example identifiability. And they also fail to address any of that... I also don't like some of the things Reddit does, but I think this is just not a well reasoned argument. If I were in customer support or a lawyer, I'd brush it off, too.