Emerging technologies have long destabilized sovereignty. The age of explo­ration redefined maritime borders, paving the way for British colonialism. Aviation gave rise to the concept of airspace. Oil exploration ushered in mineral rights. The space race created a new contest for planetary explora­tion. The internet led to the concept of sovereignty over data.

In their work on data colonialism, Nick Couldry and Ulises A. Mejias refer to the United States and China as two poles of colonial power in the global internet. Couldry and Mejias use the term data colonialism to argue that extracting data relates to historical practices of colonialism. While data colonialism presents an invaluable way to reflect upon the United States and China as extractors and colonial powers with respect to other nations, it raises the question of what happens when these two global powers engage in trade with each other.

The governing systems of the United States and China have opposing views on individual rights. They are also economically enmeshed, with a trade volume exceeding US$500 billion. Understanding data trafficking empowers us to comprehend how countries relate in a digital world.

Whoever controls each nation’s data shapes international trade between global hegemons

After all, as media studies scholar Stefano Calzati notes, “Behind the scenes, these two poles of interests often find an agreement when it comes to the very basic principle of surveillance through data.” The United States and China both strip the control of personal data from citizens via unclear consent agreements, labyrinthine corporate partnerships, and government policies that privilege corporate access to data over citizens’ rights. China’s policies prioritize mass government data aggregation and control at the national level, while the United States relies heavily on corporate data management policies. As the two countries move data across the bipolar tech world, what we see happening between them is trafficking, the undermining of national sovereignty through dig­ital trade.

When paired with Chinese government data access requirements, the lack of consumer protections in the United States creates a race to the bottom for user data security. US tech firms congratulate themselves on their ability to “move fast and break things,” but by prioritizing time to market over security, companies make users vulnerable not just to non­state hackers but also to other governments. Corporations harvest videos of religious ceremonies and babies sleeping in their cribs, among countless other private moments, as data. Once collected, intimate moments transform into valuable resources that secure corporate debt. They become algorithms that support new products, including entertain­ment, weapons systems, and health care. In the Sino-U.S. case, customer data becomes an asset in both the financial and intelligence senses of the word.

Despite their political differences, both the United States and China lev­erage the combined power of government and corporate influence to alienate citizens from their data

Zoom, Apple, Alibaba, Tencent, and others that depend on both the US and Chinese markets operate as geopolitical actors moving between the U.S. and Chinese tech regulatory systems. In the U.S. tech sector, firms have every incentive to do only the minimum to meet U.S. government requirements be­cause of their power relative to the government. By contrast, China’s opaque system of cyber sovereignty encourages firms, both Chinese and interna­tional, to exceed the minimum oversight requirements out of concern about being expelled from the market.