Outside the EU

Answer:

The mere accessibility of your website by individuals in the Union, sporadic emails, or use of the languages of one of the Member States in the Union (if the same as the language of your home state) should not by itself make you subject to the GDPR. However, the following factors are a strong indication that you are offering goods or services to individuals in the Union and therefore you are subject to the Regulation:

Language - You are using the language of a Member State and that language is not relevant to customers in your home state (e.g. the use of Hungarian by a US website).
Currency - You are using the currency of a Member State, and that currency is not generally used in your home state (e.g. showing prices in Euros).
Domain name - Your website has a top level domain name of a Member State (e.g. use of the .de top level domain).
Delivery to the Union - You will deliver your physical goods to a Member State (e.g. sending products to a postal address in Spain).
Reference to citizens - You use references to individuals in a Member State to promote your goods and services (e.g. if your website talks about Swedish customers who use your products).
Customer base - You have a large proportion of customers based in the Union.
Targeted advertising - You are targeting advertising at individuals in a Member State (e.g. paying for adverts in a newspaper).

So I would guess, based on your description, that you don’t have a large proportion of your data base contained details of individuals in the EU nor will you specifically target them, so the GDPR should not be a concern at least for now.

To learn more about the EU GDPR check out our “EU GDPR Foundations Course” (https://advisera.com/training/eu-gdpr-foundations-course//).