The following content does not constitute legal or business advice. For specific practices, professional lawyers and business consultants should be consulted. The model discussed below is only a theoretical discussion, that is, how to reduce data privacy risks through cross-border layout, compliance arrangements and technical means, rather than encouraging circumvention or violation of data protection regulations in any country. [Overall Idea] Taking advantage of the differences in data protection laws in different countries, common means include: 1. Distributing data storage, processing, analysis and other links under multiple legal systems; 2. Using "firewalls" or "buffer layers" in the data flow, so that key data has been desensitized or anonymized before entering the strictly regulated area; 3. Data segmentation through contractual arrangements and technical means, so that even if a certain area is strictly regulated, it is difficult to simply attribute the entire business to "infringement". It should be emphasized that any model that uses legal differences to reduce legal risks must be based on the premise of fully complying with the laws of the location (or the user's location) and meeting transparent compliance requirements. [Model Example Design] 1. Distributed data processing architecture a. Data classification and stratification: First, classify and stratify user data according to sensitivity. For highly sensitive data, try to process it in the country where it is collected or where the user is located; for some analytical, statistical, and computational data, anonymization or aggregation is implemented when it is collected. b. Cross-border processing nodes: Build multiple data processing nodes. Choose countries with more relaxed laws as data storage or preliminary analysis centers, but ensure that they have been desensitized or converted into information that cannot be directly associated with personal identity before data transmission. Use technical means to lock the original data only in the original collection country to ensure that subsequent processing does not contain intuitively identifiable information. 2. Legal and strict desensitization and anonymization a. Implement privacy protection algorithms and anonymize the data during the data collection process. In this way, even if the data subsequently flows into a more relaxed jurisdiction, the responsibility definition will be clearer because it is already anonymous. b. Take continuously evolving desensitization measures for data to ensure that the degree of desensitization meets the latest global privacy protection technology standards to prevent privacy infringements due to improper desensitization methods. 3. Legal isolation and contract protection a. Clarify data processing partners, cloud service providers, and cross-border transmission agreements in various places through contracts to ensure that each link has independent and rigorously reviewed data protection responsibility provisions. b. Design a "legal security firewall" and use a transit agency when transferring data across borders, whose legal responsibilities are independently divided in the contract. For example, set up a special conversion platform between the strictly regulated area and the loosely regulated area to ensure that the responsibilities of each link in the data transmission are clear. 4. Dynamic compliance and regulatory monitoring a. Establish a special international regulatory monitoring team to track the changes in information protection laws of various countries in a timely manner, especially pay attention to countries and regions with stricter regulations. b. Regularly invite third-party audits to ensure the compliance of each node, and dynamically adjust the business model based on the audit results. 5. User transparency and proactive communication a. Detailed description of the data processing, storage and transmission process in the user agreement and privacy policy, and clearly explain what kind of legal protection the data may be subject to in different countries. b. Even if the sensitivity of data is reduced by technical means, the user's consent should be obtained proactively, and the data subject should be provided with a way to query and control the relevant process. [Risk Tips and Precautions] 1. Reputation risk: Using legal differences to process data may cause controversy among the public and regulators. Enterprises need to balance the relationship between reducing legal risks and public trust. 2. Regulatory evolution risk: Data protection laws in different countries are constantly evolving. Previously “relaxed” regions may also introduce stricter regulatory measures in the future, so a long-term response plan is required. 3. Compliance challenges: Cross-border data transfer, anonymization technology, and contractual arrangements must be approved by regulatory authorities in various countries. Any lack of transparency or technical omissions may be regarded as circumvention or violation of privacy. 4. Professional consultation: In any design and implementation process, a professional legal team, data security experts, and international business consultants must participate to ensure that the entire architecture meets both business needs and the legal requirements of various countries. [Conclusion] In theory, a distributed data processing and storage business model can be designed to reduce the legal risks arising from direct possession of sensitive data by taking advantage of the differences in privacy protection laws in various countries under the premise of legality and compliance. However, this model must be based on: (a) strict technical desensitization and data anonymization, (b) carefully designed contractual and legal isolation mechanisms, (c) continuous dynamic compliance monitoring and internal audits, and (d) transparent notification to users and obtaining user consent. In short, the implementation threshold of this business model is high and the risk is high. Enterprises must balance commercial interests, user trust, and legal compliance. Any strategy that attempts to use legal differences to avoid regulatory risks may attract the attention of regulators and subsequent rectification, so it is important to make decisions after seeking professional compliance advice.