International Data Transfers
SCOPE
This notice concerns personal data processed in connection with CXR App. CXR App is offered and operated by Visual Memory Works GmbH (“VMW”). VMW is your point of contact for sales, billing, payment processing and support.
TRANSFERS TO THIRD COUNTRIES
Depending on the service provider used, personal data may be processed outside the European Union and the European Economic Area (EU/EEA). This may in particular affect the web server of the information website in Turkey and the AI providers OpenAI, Anthropic and Google; the payment service provider Stripe is also used, which, depending on the transaction, may also process data outside the EU/EEA. Processing locations and transfer bases depend on the service actually used; for the applications, a migration to servers in Germany is planned. Any transfer only takes place if the purpose, recipient, destination country and legal basis comply with the requirements of the GDPR.
A transfer to a third country only takes place if the requirements of Art. 44 et seq. GDPR are met. The following may in particular be considered:
- an adequacy decision of the European Commission (Art. 45 GDPR), such as the decision on the EU-US Data Privacy Framework for recipients in the USA that are certified under it;
- appropriate safeguards, in particular standard contractual clauses of the European Commission, supplemented where necessary by additional measures (Art. 46 GDPR);
- in exceptional cases, the conditions set out in Art. 49 GDPR, such as the explicit consent of the data subject after being informed of the risks.
For countries for which there is no adequacy decision of the European Commission, a transfer of personal data requires appropriate safeguards under Art. 46 GDPR or a derogation under Art. 49 GDPR.
As there is no adequacy decision of the European Commission under Art. 45 GDPR for Turkey, the processing of access data on the web server in Turkey is governed by Art. 46 or Art. 49 GDPR. Upon request, we will inform you which safeguard exists for this transfer.
CONSENT
Acceptance of the Terms of Use does not replace a blanket consent covering all transfers. Where a transfer is to be based on consent, that consent will be obtained separately, explicitly and after prior information; it can be withdrawn at any time with effect for the future.
CUSTOMER CONTENT
For content that businesses enter into their apps (for example customer photos, guest and visitor data, orders or inquiries), those businesses are controllers. VMW processes this data as a technical service provider and processor under Art. 28 GDPR. Where VMW uses sub-processors that process data in third countries, this only takes place under the conditions stated above and in accordance with the provisions of the data processing agreement.
INQUIRIES
Information about the recipients and countries used and, where applicable, about the safeguards under Art. 46 GDPR is available upon request:
Visual Memory Works GmbH · Elbestraße 10, 45768 Marl, Germany
E-mail: erguen.kalayci@visualmemoryworks.de · Phone: +49 2365 5033557
Further information can be found in the “Privacy Policy”, the “GDPR / DSGVO Data Protection Notice” and the document “Third-Party Services, Data Processors and Sub-processors”.