Reddit sent me invitations to their IPO to my "deleted" accounts! That's a GDPR violation! ( lemmy.world )

Any pointers on how to report them?

As requested, I'm posting the full text of the email into this post body. I hope it's screen reader friendly:

u/USERNAME,

tl;dr – you’re invited to a special program that lets redditors purchase stock at the same price as institutional investors when we IPO. Details about eligibility and next steps follow. This (long, dense) email has all the info we can provide due to legal restrictions.

As you may have heard, Reddit has taken steps toward becoming a publicly traded company with the initial public filing of our registration statement with the U.S. Securities and Exchange Commission on February 22, 2024. Yes, it’s happening.

And because you have helped make Reddit what it is today, you now have the opportunity to become Reddit owners at the same price as institutional investors.

We’re offering a Directed Share Program (“DSP”) that invites eligible users and moderators who have contributed to Reddit to participate in our initial public offering (“IPO”). (Including you!)
Program Requirements
While being selected to pre-register is the first step, there are certain legal and regulatory requirements to participate in the DSP that are outside of Reddit’s control. Bear with us here…

To be eligible for the DSP, you must:
• Be a current U.S. resident;
o You will be asked to provide the DSP Administrator a valid social security or permanent resident number, along with other personal information. Reddit will not have access to this data.
o Please note that U.S. residents using a VPN may face application limitations if the VPN locates them in certain non-U.S. jurisdictions.
• Be at least 18 years old;
• Provide your full legal name and an email address;
• Not be a current or former Reddit employee (FTE).
When the DSP launches (a few weeks after pre-registration ends), individuals who have been confirmed for the program will be contacted by our external DSP Administrator. You will then be asked to provide additional information securely to the DSP Administrator to confirm your eligibility.
How to pre-register
The number of people who can participate in the DSP is limited; we will offer this opportunity to as many redditors as we are able to accommodate. If capacity is reached before the deadline, you will be added to the waitlist. Based on demand, we may also limit the number of shares available.

If you are interested in being part of Reddit’s DSP, please go to https://reddit.com/dsp on desktop to complete the pre-registration form. If you are one of the confirmed participants, we will follow up with an email with more details in the coming weeks. You can also refer to the Frequently Asked Questions for more information. Due to regulatory restrictions (yeah… we know…) we are not able to respond to further inquiries or questions.

Pre-registering does not guarantee that you will be invited or able to participate in the DSP; it also does not obligate you to purchase shares.

As with any investment opportunity, you should make an individual decision based on your own personal circumstances and risk tolerance. Therefore, we urge you to review the preliminary prospectus, when available, before deciding whether to invest in Reddit.

The deadline for pre-registering for the DSP is March 5, 2024. If capacity is reached before the deadline, you will be added to the waitlist.
What happens next?
While there won’t be a confirmation email immediately after you pre-register, everyone who pre-registers will receive an email in the coming weeks from “noreply@redditmail.com”, telling them whether they can proceed with the next steps for the DSP.

This is an automated message (beep, boop, beep) and does not receive replies. Please refer to the FAQ for more information. Per our lawyercats, we are not able to respond to further inquiries or questions.
Prospectus and Important Disclosures
The offering will be made only by means of a prospectus. When available, a copy of the preliminary prospectus related to the offering may be obtained from:
Morgan Stanley & Co. LLC, Prospectus Department, 180 Varick Street, New York, New York 10014, or email: prospectus@morganstanley.com; Goldman Sachs & Co. LLC, Attention: Prospectus Department, 200 West Street, New York, New York 10282, telephone: 1-866-471-2526, facsimile: 212-902-9316, or email: prospectus-ny@ny.email.gs.com; J.P. Morgan Securities LLC, Attention:c/o Broadridge Financial Solutions, 1155 Long Island Avenue, Edgewood, New York 11717, telephone: 1-866-803-9204, or email: prospectus-eq_fi@jpmorgan.com; and BofA Securities, Inc., NC1-022-02-25, 201 North Tryon Street, Charlotte, North Carolina 28255-0001, Attention: Prospectus Department, telephone: 1-800-294-1322, or email: dg.prospectus_requests@bofa.com.

A registration statement relating to these securities has been filed with the U.S. Securities and Exchange Commission but has not yet become effective. These securities may not be sold nor may offers to buy be accepted prior to the time the registration statement becomes effective. This notification shall not constitute an offer to sell or the solicitation of an offer to buy these securities, nor shall there be any sale of these securities in any state or jurisdiction in which such offer, solicitation, or sale would be unlawful prior to registration or qualification under the securities laws of any such state or jurisdiction.

No offer to buy the securities can be accepted and no part of the purchase price can be received until the registration statement has become effective, and any such offer may be withdrawn or revoked, without obligation or commitment of any kind, at any time prior to the notice of its acceptance given after the effective date. An indication of interest in response to this notification will involve no obligation or commitment of any kind.

You are receiving this email because a Reddit account, USERNAME, is registered to this email address.
548 Market St., , San Francisco, CA 94104–5401

cqthca ,

Now, what is the 3x Bear Reddit ETN?

coffeeClean ,

You might want to crosspost your story to !uklaw. But if you do that be clever with your phrasing so as to not seem to be asking for advice, but rather for information. E.g. is there any case law for this situation..

(I’m assuming you’re in the UK because other commenters focused on UK law)

planish ,

It cheeses my beans so goram much that they took a perfectly good web site and made it terrible so they could sell it to "the public", notionally the same people who were using the site!!!

I can only conclude that this is some kind of scam and actually most of the thing is going to end up owned by deliberately nebulous "institutional investors" and not the community members who constitute and deserve ownership of the community. Or even the people at Reddit Inc. who did the work of making the thing.

DAE socialism?

dejected_warp_core , (edited )

I can only conclude that this is some kind of scam

That depends on your framing.

Is it a legitimate attempt to sell shares? Absolutely. Completely legal, disregarding OP's claim of a GDPR violation. There might be wiggle-room to suggest this is some flavor of price manipulation, but I'm not a lawyer or SEC investigator. In order to IPO, there's a compliance framework that makes this functionally identical to any other IPO on the market.

Are some people who buy this IPO going to be left holding the bag? In a round-about "we're all playing the same game, but also not" way, yes. For an instant, people will be holding shares in Reddit at the IPO price, and speculation on value will drive that up on the back of the IPO itself. It might plummet later the same day, it may not. But what is going to really burn people is when the primary shareholders "cash out" and sell a huge chunk of that stock. That usually has the effect of signaling that the company isn't worth what it was anymore. It's a gamble where the house can destroy your bid before you can manage to pawn your chips off onto the next guy.

From a spectator standpoint, where this may get interesting is where Reddit IPO intersects with r/wallstreetbets.

Edit: dividends are also a thing, but I never hear about that outside of what mutual funds and 401ks are up to. As someone who has no idea how Reddit does or can actually make money, I'm going to guess that's not going to be a benefit of being a long-term shareholder.

Saurok ,
ILikeBoobies ,

Don’t give websites your email, what a silly thing to do

gmtom ,
@gmtom@lemmy.world avatar

They sent one to my deleted account that was literally called GDPR_Violation lol

banghida ,

0 fucks given

coffeeClean ,

There really needs to be a resource where data subjects can pool their evidence and collaborate on GDPR actions against common data controllers.

Hubi ,

lmfao

merthyr1831 ,

I haven't used my reddit account the API change, beyond maybe 3 or 4 comments. I got an invite. How the fuck was I one of their top 35k most active users? Seems like their site isnt nearly as active as they're claiming

Appoxo ,
@Appoxo@lemmy.dbzer0.com avatar

Karma was a relevant factor. I guess if yoi had a good amount of karma it may have contributed to it.

chiliedogg ,

It's based in Karma. Since I had over 200k I was invited in the first group even though I hadn't logged in since the change.

DragonAce ,

Yeah I just got an invite as well and I haven't logged in since the protest that brought the first wave of us here. So karma has to be a deciding factor, I had over 100k I think so that would be the only reason I got an invite.

chiliedogg ,

100k is the threshold for the second round of invitations.

https://lemmy.world/pictrs/image/ddd7b93d-df97-400e-a981-10fbbc536f94.jpeg

mxcory ,

They must be into round 4, I have never been a mod.

chiliedogg ,

It's either/or. I've never been one, but since I had over 200k Karma I was in round 1.

DoctorRoxxo ,

I have 40k karma on an 12 year old account and was invited. Obviously not buying that sit tho

chiliedogg ,

There are a couple other factors. Were you a mod? Did you ever participate in one of reddit's community programs like the Helper Program or Mod Council?

The 3 criteria are MVP status, which is based on participation in certain programs, Karma, or Mod Actions.

mxcory ,

Just chiming in, 34k karma (only 4 post karma) and haven't posted for 9 months. Never a mod. I also got the IPO offer. Think I was gifted gold one time.

wildebeesties ,

Same. 13 year account with 42,000 karma. Have not been on since the API change. Never a mod, never part of anything special, just a regular user in every way.

merthyr1831 ,

ah i thought it was based on activity (though Reddit wrongly likes to correlate the two)

NightAuthor ,

People should express interest, and go through whatever steps just short of actually buying

fxt_ryknow ,

I got the email, also... And like you, I've not used reddit since the api BS. I've not logged in, commented or anything since just before sync stopped working.

dejected_warp_core ,

Did you post a lot? Do you have email notifications turned on?

My old account has... a lot (six digits worth), of comment karma. But I think I posted a grand total of three times in the last ten years or so. I also have notifications turned off. So, no IPO notification for me.

setsneedtofeed ,
@setsneedtofeed@lemmy.world avatar

I too got an email and haven’t posted at all since the API change.

If I really was in the top 35k before that, then at least I know quitting Reddit made some kind of dent in their content.

cosmicrookie ,
@cosmicrookie@lemmy.world avatar

They once sent me an email, about their new privacy conditions on my deleted account too. If you live in EU I'd recommend forwarding this message and the confirmation of your account being deletes to your local data authorities. It's pretty easy to file a compliant

coffeeClean , (edited )

You are on a privacy-offending Cloudflare site (), so Tor users are blocked from seeing your Cloudflare-jailed image. If you care about privacy you will bounce from that instance.

Without seeing the image, I have to ask how an anonymous user gets rights. Or has started supporting an identification mechanism of some kind? When I start the reg process, it asks for an email address, username, and pw, not a first + lastname (but my test stopped when a Google reCAPTCHA push was attempted). I have zero sympathy for Reddit -- they are rotten to the core scumbags, but I do not see how the GDPR can be applied to anonymous accounts.

(edit) I gather from other comments you must have posted an email. Would be great if you could copy the text of the email into the body of your post so everyone can see it and so people using screen readers can hear it. Thanks!

ChrislyBear OP ,

Will do! Just a moment...

coffeeClean , (edited )

Thanks!

The To: address in the header would be interesting. Of course, you wouldn’t want to disclose it verbatim here but it might be useful to have a rough idea. Was it Firstname.Lastname@yadayada.com or some variation of that, or was it more like commonNickname@yadayada.com? Some people here think it doesn’t matter, that it’s inherently personal info, but the European Commission says it matters. It’s not hard and fast; there are varying shades of gray here. Maybe they kept logs of your IP address and maybe that makes a difference. You might want to read WP136 (I have yet to read that).

I would love to see action taken against Reddit, if anything just to burden their lawyers and create some costs for them. But I doubt it will go anywhere. GDPR enforcement is such a shit-show in Europe. Even dealing with clearly blatant violations that are wholly internal to Europe which should irrefutably incur penalties, simple obvious cases are being ignored by DPAs. So I have little confidence that this cross-border case against a non-EU data controller would actually get results when the law is not really concrete. The one factor in your favor is that Reddit is somewhat high-profile which might take a DPA’s interest.

I don’t think a “delete my account” button constitutes an Article 17 request. It removes the purpose of processing to some extent, which then relies on the data minimization principle (Art.5). Reddit can do a bit of hand-waving to make excuses like needing to retain your email address in case one of your posts sparks a legal inquiry. Your case would be stronger if you had submitted an explicit Art.17 request to Reddit.

From the email:

Per our lawyercats, we are not able to respond to further inquiries or questions.

I wonder if that statement might be actionable. Art.12 and 13 require Reddit to identify a data controller with a point of contact and to tell you your GDPR rights (IIUC). And here they are outright stating in effect “we don’t want to hear from you”. I would stress that in your GDPR complaint, not just the misuse of your email which you expected to be deleted. But note they do provide an address at the bottom of that msg. Although that angle of attack might require Reddit having a way to know you have ties to a GDPR region after the supposedly “deleted” your acct.

Also, I would look into any anti-spam laws your country has. There may be a higher degree of legal actionability there.

Omega_Haxors ,

When companies get desperate they start flagrantly breaking the law.

gapbetweenus ,

I hope EU fucks them.

LaunchesKayaks ,
@LaunchesKayaks@lemmy.world avatar

I hope so, too. Wish I could help out, but I'm in the US lol

Crack0n7uesday ,

I got a message in my email that's linked to a banned account...

cordlesslamp ,

Let me check my "deleted" reddit account email real quick.

collapse_already ,

I had a high karma account that they permabanned. I imagine they probably want to send me an invite, but I never gave them my email.

ipkpjersi ,

I wouldn't expect companies to hard delete in this day and age. I fully expect that they all soft delete, sadly.

VintageTech ,

I just found out my account that I deleted, was in fact not deleted.

a2part2 ,

Which is a GDPR violation and should be treated as such when they get caught

Rodeo ,

And what jurisdiction does the gdpr have over servers hosted in America?

We're all still waiting for the court case that sets this precedent.

scv ,

Reddit has employees and servers in Europe, including EU countries. GDPR most definitely applies.

YoorWeb ,

*According to Article 3(2), a business that targets individuals in the EU for offering goods or services (even if it’s free) or monitoring their behaviour falls under the scope of GDPR. Monitoring activities such as tracking through cookies or other technologies, behavioural advertising, geolocation, market surveys etc performed by a non-EU business can be subject to GDPR. A US business that has no establishment in the EU, but sells goods or services to consumers in the EU, will fall under the scope of GDPR in the US. Note that the law extends to any resident of the EU, irrespective of citizenship. *

Source: https://www.cookieyes.com/blog/gdpr-in-the-us-a-checklist-for-compliance/

Many US companies were fined, it doesn't matter where your servers are, it matters if you target EU customers. In this case, Reddit very clearly targeted EU citizens.

Rodeo ,

Can you cite a case where an American company with no holdings or dealings in the EU was fined successfully?

If the company has no infrastructure within the jurisdiction of the gdpr, how can they hope to enforce it?

reinei ,

IANAL and this obviously won't happen (because it's one of if not the stupidest way to go about it right from the get go) but still:

They can literally demand any and all European ISPs block all their traffic, they can still raise the fees and if they don't pay accrue interest/late claims on it.
Will this change anything? Not immediately, but the moment that company does anything the courts can reach they are in a whole lot of trouble.


Anyway besides this are there really companies that are so US centric that a European court can't (like really absolutely can't) reach them?

Tum ,

Reddit has holdings in Dublin, Ireland, where they have a large contingent of employees. thus they are required to adhere to GDPR.

invertedspear ,

They’re getting desperate to find bag holders.

Kyatto ,
@Kyatto@leminal.space avatar

it's getting more obvious they are going to pull the rug, admittedly I haven't followed too much on the situation or on reddit at all since I stopped using reddit almost a decade ago. the site really went to shit didn't it. I just grab my popcorn when new updates pop up these days, all reddit is for me now is an end result from a google search about a problem.

derpgon ,

They don't have to. There is no "pump" phase, we are already in the "dump" phase and Reddit is just dumping their stock (or gonna be when they IPO).

leanleft ,
@leanleft@lemmy.ml avatar

exit liquidity

altima_neo ,
@altima_neo@lemmy.zip avatar

Youre telling me, they sent me TWO invitations for two of my accounts. One of which I retired years ago because the username was kinda insensitive. Its been inactive for years, yet apparently it has enough karma for them to message me about it.

Contend6248 ,

Tells you about how much karma you have to be an investor

Tbird83ii ,

You should be very VERY vocal about how your account, insensitive name, was asked to own part of Reddit and how willing you are to do that, in order to make sure that the world knows that reddit is owned in part by insensitive name..

dejected_warp_core , (edited )

I think it's more than that.

The price for these shares is probably not cheap for the individual, but won't raise a ton of money internally in the grand scheme of things. At least, that's how it works for employee options and phantom stock. The disparity here is due it's utility as a retention mechanism. The idea is that, if invested, you're less likely to jump ship until after IPO. With options and phantom stock, they typically have a "vestment period", so you have to wait before you can get your money back out.

In this case, Reddit knows it needs its moderators and power users, but can't afford to employ those people. So we get this weird middle-ground where they entice people to stick around, but they're still not employees. As a bonus to Reddit Inc., these "investors" will provide ballast for the IPO, because I'm betting this stuff has a vestment period that extends well past the IPO date. Seeing this all on a balance sheet will make other investors feel a lot better about buying or even holding shares when the IPO kicks off.

What I really don't like about this is that they mention the "DSP" and define it, but are coy about what the actual investment instrument is. What kind of shares are these? What is the price per share?

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