[majewsky]

I read your link, and I think it depends on what "being in" means in the phrase "data subjects who are in the [European] Union". It could refer either to physical location (as in "I am in Germany") or to membership (as in "Germany is in the EU"), or possibly to both. I would also expect it to refer to physical location after reading this, but I'm most definitely not a lawyer.

[icebraining]

Germany is not a data subject, so I don't think it can be read that way. Others agree: https://www.linkedin.com/pulse/gdpr-does-apply-eu-citizens-g...