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When Personal Data Becomes Currency: A German Court’s Interpretation

01 Feb 2026

In the digital economy, one increasingly hears the claim that personal data is the “new currency”. Nevertheless, the Higher Regional Court of Stuttgart recently issued a decision dismissing a lawsuit brought by a consumer association against a retail chain and confirming that it is permissible to advertise participation in a loyalty programme as “free of charge”, even though users, in order to use the app, provide their personal data. The Court took a clear position - the provision of personal data, in and of itself, does not constitute “payment” or a “price” within the meaning of the relevant rules governing the pre-contractual information obligation regarding the total price.

Author:

Sonja Stojcic, Senior Associate,
sonja.stojcic@prlegal.rs