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> There's a real risk of getting sued / getting cease and desist letters from predatory law firms who aim to collect fees for small mistakes in your privacy policy

No there isn't.

When the GPDR fines are 2% of revenue there isn't the incentive for lawyers to go after businesses earning less than a million a year in revenue.

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or 10m euro, whichever is higher

You're mixing up the member states' enforcement (4% of worldwide turnover or €20 million, whichever is higher) and civil suits. There are law firms that send out thousands of cease and desist letters (which is a civil action) based on automated searches for mistakes. It absolutely makes economic sense for lawyers to pursue out-of-court settlements from businesses if it's mostly automated.

This is just nonsense. I don't see how the GDPR possibly allows civil actions for infractions, doubly so for countries outside the EU.

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