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Hi

I agree Tony's point. Joint controller is probably right in my scenario, but I couched it as processing for clarity on the particular point. It just shifts it from Art 28 to 26 compliance.

As it happened in the particular case, B was actually using a third party app. B had a supply and processor contract with C who provided this. No-one appreciated that A also needs an Art 28 agreement with C in that situation ... although this might perhaps be incorporated in the B-C agreement on an agency basis with good drafting

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