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[Music] theres never been a definition for international data transfer and its been the subject of discussion and commentary over many many years as to what actually constitutes an international data transfer so the adp-b has provided us with a sort of three-prong test now to identify whether there is a data transfer and the the first prong is that there is a controller or processor that is subject to the gdpr and so you know an entity caught by article 3 1 or any of the prongs under three two and then the the second limb if you will is that theres an exporter that makes data available to an importer which is important because there was always sort of this question hanging over whether any uh direct collection of data from uh individuals located in europe by uh you for example us-based entity constituted a data transfer so thats really helpful color there and then the third prong is that the importer is in a third country regardless of whether the importer is subject to the gdpr yo