Being compliant with the GDPR
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Answer:
From the description you provided it looks like the data is directly collected in the US so basically they are not transferred from a EU entity to a US entity. The only thing you need to do is to mention in your Privacy Notice that the data processed in the US and may be stored in the US or other locations around the world.
To find out more about privacy notices check out our webinar “Privacy Notices Under the EU GDPR” https://advisera.com/eugdpracademy/webinar/privacy-notices-under-the-eu-gdpr-free-webinar-on-demand/
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May 10, 2018

