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Andrew2022-04-19 00:05:09
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Andrew, 2022-04-19 00:05:09

Is Saas b2b a data controller?

Let's say a certain company makes CRM for massage parlors. This CRM is hosted in the cloud in Russia.
And this firm sells this CRM to massage parlors all over the country.
These salons keep a list of their clients in this program - for example, they write down the name and phone number.

The question is - is the company that owns CRM a PD operator?
On the one hand, she is engaged in the processing of PD. On the other hand, it has no way to collect consent for processing from PD subjects.

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