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Carsten A. Kociok

Carsten Kociok is a partner in the Technology, Financial Services and Data Privacy Practice in Berlin and Co-Head of Greenberg Traurig’s global Fintech Group. He advises national and international clients across all industries, including financial services, information technology, artificial intelligence, ecommerce, media, health care, telecoms, retail and real estate, on a wide variety of complex commercial and regulatory matters.

Carsten is a leading technology lawyer, ranked consistently in Band 1 for Fintech Legal in Germany since 2020. He has in-depth and wide-ranging experience in the areas of privacy and cybersecurity, payments law, financial services, e-money products, blockchain technology, and financial and banking regulation, as well as in artificial intelligence regulation - including compliance with the EU AI Act - and the integration of AI technologies into existing software systems.

Carsten regularly assists clients in licensing projects and audit proceedings with financial regulators and advises on the contractual and regulatory aspects of developing, implementing and operating financial technology products and transactions.

On the data privacy side, Carsten counsels clients on complex data-driven business models and regulatory matters, including on international data transfers, data privacy compliance, monetization of data, artificial intelligence, litigation, cybersecurity and data breach response.

Carsten regularly lectures and publishes on various FinTech and data privacy topics. Prior to joining the firm, Carsten worked at Olswang Germany for eight years and in the Capital Transaction Practice Group of an international law firm in New York.

The CJEU’s March 19, 2026, judgment in Case C-526/24 marks a significant development in GDPR enforcement, holding for the first time that even a single data access request may be refused as “excessive” under Article 12(5) GDPR if made in bad faith, while also confirming that an unjustified refusal to comply with such a request can itself give rise to damages liability under Article 82(1) GDPR.

Continue Reading CJEU: First Request for Access May Be Rejected as Abusive Under GDPR

The newly published German Coalition Agreement 2025 (CA 2025), German language version available here, outlines a digital agenda of the new German government, aimed at strengthening Germany’s position as a leader in digital innovation, data protection, and technological sovereignty. This GT Alert provides an overview of key digital policy areas that the CA 2025

On Jan. 16, 2025 the European Data Protection Board (EDPB) published guidelines on the pseudonymization of personal data for public consultation. The Berlin Data Protection Commissioner (BlnBDI) played a leading role in drafting these guidelines (see the German-language BlnBDI press release). The consultation is ongoing, and comments can be submitted until Feb. 28, 2025

  1. Full Steam Ahead: The European Union’s (EU) Artificial Intelligence (AI) Act in Action — As the EU’s landmark AI Act officially takes effect, 2025 will be a year of implementation challenges and enforcement. Companies deploying AI across the EU will likely navigate strict rules on data usage, transparency, and risk management, especially for high-risk AI

The European Data Protection Board (EDPB) has recently (re)positioned itself on several controversial topics and published three new guidelines and opinions. Although not legally binding, they do have a significant influence on proceedings before the supervisory authorities and courts. This GT Alert discusses the EDPB’s new guidelines and their implications for companies dealing with personal

On 13 March 2024, the European Parliament adopted the AI Act. Since the EU Commission presented its first draft almost three years ago, the use of AI and general purpose AI models has increased significantly. Hence, the regulatory proposal was (and still is) the subject of hefty debate.

Continue reading the full GT Alert.

On July 10, 2023, the European Commission adopted its long-awaited adequacy decision on the EU-U.S. Data Privacy Framework (the “Framework”) thereby concluding that the United States ensures an adequate level of protection for personal data that are transferred from the European Union to companies in the U.S. that participate in the Framework.

The

  1. Companies must delete data upon request if the data was processed based solely on consent. The GDPR recognizes that companies may process data based on six alternate lawful grounds.[2] One of these is where

Data typically is needed to train and fine-tune modern artificial intelligence models. AI can use data – including personal information – in order to recognize patterns and predict results.

The EU’s General Data Protection Regulation (GDPR) permits controllers to process personal information if one (or more) of the following six lawful processing purposes applies:[1]

Data typically is needed to train and fine-tune modern artificial intelligence models. AI can use data – including personal information – to recognize patterns and predict results.

Companies that utilize personal information to train an AI may either be acting as a controller or a processor depending on the degree of discretion that they exercise