From: Loic Dachary loic@gnu.org
Georg C. F. Greve writes:
What you can transfer are "exclusive exploitation rights," which economically behave like the anglo-american Copyright, but it does not contain the "personality rights" of the author.
That's what we call "droits moraux" (moral rights) in France. Maybe Till can tell us if these "personality rights" are common to all countries in Europe. Are there European countries that have no such concept ? It exists in Germany (my guess), in France and ... ?
It does exist in Germany and is called "Urheberrecht" commonly falsely translated into "Copyright" - I would rather use the term "Authorship rights".