But here, the controller of the data is the airline, the transfer to the data broker might be illegal, and an airline is the worst company to commit GDPR violations with: They have a lot of global revenue but a relatively thin margin, very little of that margin comes from data abuse (so they can't just shrug off the GDPR fine as a small cost of doing shady business), and they are reachable in the EU (worst case a member state can ground and confiscate their planes, and essentially ban them from flying to the EU by threatening to confiscate any other plane that lands). And yes, Germany will impound a plane to get debts paid: https://www.reuters.com/article/world/thai-prince-to-pay-bon...