Steinberg

Software End User License Agreement (EULA)

with Account Terms and Conditions of Use

 

General

 

Steinberg Media Technologies GmbH (hereinafter: "Steinberg") permits you as end-user to copy, download, install and use the software in accordance with the terms and conditions of this Agreement. These contractual provisions (EULA) shall also apply to other Steinberg software products that you acquire, install and/or use in the future, unless other Steinberg terms of use apply to this software. 

 

Download, Installation, use of the Product as well as product registration and product activation may require the creation of an online account with Steinberg. Unless stated otherwise, the software can only be used together with the license management technology Steinberg currently uses (e.g. account or USB-eLicenser and/or the Soft-eLicenser); products issued free of charge (free products) and OEM software may only be used following registration and Trial Version Software can be used only for a limited running time (e.g. 30 or 60 days). In general, you are only entitled to support, updates and upgrades following a personal product registration. Certain software may require for installation and use one or more software downloads. Software can download, install and update components in the background from the Internet. Internet access is required for the creation of an account with Steinberg, software download, the activation process, personal product registration and other functions including data exchange with Steinberg.

 

You may accept these contractual provisions at the time of purchase or download, or by installing the software on your computer, you agree to these terms and conditions. Please read the following text completely and carefully. If you do not approve these terms and conditions, you must not accept these contractual provisions and you must not install this software. In this case, you may return the product (incl. all written materials, the complete undamaged packing as well as the enclosed hardware) immediately, but at the latest within 14 days to the place where you have purchased the product for a refund of the purchase price.

 

1        Steinberg Software Products

1.1      This Software End-User License Agreement (EULA) shall apply for Steinberg software products and also apply to other Steinberg software products including online services that you acquire, install and/or use in the future, unless other Steinberg terms of use apply to this software.

1.2      „Software“ includes (i) software files and other computer information of Steinberg and third parties, (ii) demo songs and audio and video files contained therein, (iii) written and electronic documentation (manual) belonging thereto and (iv) all modified versions and copies, which are provided by Steinberg in the form of updates, upgrades, patches and enhancements of Steinberg provided that these are not regulated by another agreement.

1.3      The software may require one or more software downloads via internet for installation and use. Software can download, install and update components in the background from the Internet (e.g. adjustment to updates of the operating system).

1.4      The software and all authorized copies of this software which you make are the intellectual property of Steinberg Media Technologies GmbH (hereinafter: "Steinberg") and their suppliers. The software is legally protected in particular by the copyright law of the Federal Republic of Germany and other countries as well as by international treaties.

1.5      If you do not accept the terms and conditions of this Agreement, the software will not work. In such a case the product including the software may only be returned within 14 days following acquisition of the product. After your acceptance of this Agreement, the activation of the software or transfer to third parties a return is excluded.

2        Grant of License 

2.1      Steinberg grants you a non-exclusive license for the use of the software according to the terms and conditions of this Agreement. You may not lease, loan or sublicense the software; unless the granting of such right is specified as a supplement to this EULA on a license document, and/or on the invoice. Please keep these documents as proof of licensing.

2.2      The samples of so-called Loops remain the property of the respective rights holder and are licensed by Steinberg to you only for use in the creation of a live or recorded performance that includes the licensed samples as part of a derivative musical work created by the licensed end user. This license includes the use of the samples, the modification of the samples and the marketing of the derivative musical work without infringing any rights of copyright collecting societies and/or the owners of copyrights in any samples. The samples may not be included, whether unmodified or as part of a derivative work, in any sample library product.

2.3      If the software is protected by account-based license management, you may install the license of a software on any number of computers which are in your possession, activate the software only on a limited number of computers (see the FAQ on the Steinberg website for the number), but the software must only be used by a single user (single user license).  If more than one user will be using the Software at any one time, you must obtain from Steinberg an additional license (or licenses, if applicable) for each additional user of the Software. If the software is protected by a hardware-based license management device (hereinafter the USB-eLicenser) alone, you may install a license for the software on one or at most 3 computers which are in your possession. The software may be used only on one of the computers at the same time by using the license management device. If the software (i) is protected by software-based license management technology (hereinafter the Soft eLicenser, alone or together with the USB-eLicenser) or (ii) has been sold to the first end user together with other software and/or hardware (hereinafter: "OEM software") or (iii) the software can be used only for a limited running time (e.g. 30 or 60 days) (hereinafter: "Trial Version Software"), you may install and use a license for the software only on one computer which is in your possession.

2.4      Every lecturer and student of an educational establishment may receive software according to a special licensing for educational purposes; this software may not be used for commercial purposes. Software with licensing for an educational establishment can be installed and used on a server and arbitrary workstations within the educational establishment as well as once for every lecturer and student on a computer at home for the processing of teaching related tasks of the educational establishment. Software with licensing in connection with music and schoolbooks of authorized publishing houses may be installed and used up to the maximum specified number of installations. The granting of a license for lecturer and student, an educational establishment and the maximum number of permissible installations of the software in connection with music and schoolbooks will be specified as a supplement to this EULA on a license document and/or on the invoice. Please keep these media and documents as proof of licensing. 

2.5      To share a single user license among multiple users via e.g. a network is expressly prohibited.

2.6      You are entitled to prepare a backup copy of the software which will not be used for purposes other than storage purposes.

2.7      All intellectual property rights in the software belong to Steinberg and its suppliers. You shall have no further right or interest to use the software other than the limited rights as specified in this Agreement. Steinberg and their suppliers reserve all rights not expressly granted.

2.8      Steinberg trusts that you honor this license agreement (EULA) and that you are the only user if you have obtained a single user license. If Steinberg discovers that the Software has been fraudulently purchased or illegal obtained, Steinberg reserves the right and will disable the license irrespective that it has been verified once by Support as legitimate or has already been transferred. If Steinberg detects that you are sharing your single user license with multiple users, Steinberg reserves the right to charge you for the additionally required licenses or to disable the license.

2.9      The software may contain functions for which Steinberg offers additional services, without charge or subject to fees, possibly according to separate terms of use. Steinberg reserves the right to modify or terminate such services without prior notice.

3        Steinberg Account and Data Protection

3.1      You may need a Steinberg Account for download, installation, use of product as well as activation and product registration of the Steinberg products and services, and in addition, for license management to protect these against unlawful copying.

3.2      The opening of the Steinberg Account, the personal product registration and product activation (see Section 5 Licence module) may be necessary to permanently use the product and service as well as to receive support, updates and upgrades. In the course of creation of the account, you will receive a Steinberg ID, which is a unique identifier of the account holder. Steinberg operates the Steinberg Account with an availability of at least 97.5% on an annual average, excluding standard market maintenance windows.

 

3.3      Note on Data Protection: Steinberg located in Germany will comply with the EU General Data Protection Regulation (EU GDPR) and the German Data Protection Act. At the creation of an account with Steinberg you are asked to provide your personal data (like name, address, email address, date of birth, country) and at the product registration within your account the license data for the purposes specified above. The creation of a Steinberg Account with wrong information like regarding your name is not permitted and a violation of the Agreement. You must be at least 16 years old or provide us with proof of parental consent. Sharing your Steinberg Account is prohibited. Steinberg may communicate with you regarding the fulfillment of the Agreement, inform about changes to the account, licensed products, updates, scheduled maintenance, or security-relevant incidents to the email address provided.  

In the case of products supplied free of charge and trial version software, information on your usage behaviour can also be exchanged, whereby at least with trial version software it is possible to object to the collection or to deactivate it. In the case of products purchased, it may be possible to expressly consent to the exchange of usage data or to switch this on or, if problems occur, to have the software installation checked for errors, to create error and usage logs and to transmit these error and usage logs to Steinberg.

Information on data protection is specified in the Annex Information on Data Protection to this Agreement, which is not part of this Agreement, and is also displayed in the Steinberg Account. Steinberg reserves the right to modify and update the Information on Data Protection at any time, which will be displayed in the Steinberg Account. Steinberg may also inform you about relevant changes in the Steinberg Account and/or to the email-address provided.  

3.4      To protect your Steinberg Account, keep your password confidential. You must not share your password with third parties and are responsible for the activity that happens on your Steinberg Account. Try to use a unique password for your Steinberg Account and not to reuse the password on or from third-party applications. Securing access and/or restoring access to your account may require another email address and/or another mobile device with e.g. Android or iOS operating system.  

3.5       The user may terminate the Steinberg Account together with the Agreement at any time. After termination of the Steinberg Account, the registered products and services, support, update and upgrades may not work. Upon termination of the Steinberg Account, you may be offered a means to recover your usage rights to an Account again later within 36 months, provided the product is still available then. After this time, Steinberg reserves the right to withdraw this option.

3.6       Steinberg may terminate the Steinberg Account and Agreement for important reasons. An important reason may be, for example, if you provide a wrong name, are younger than minimum age, share your Steinberg Account with other users, register illegal products or misuse the Steinberg Account for illegal or unethical behavior.

4        Support, Updates and Upgrades after Product Registration

4.1      You as licensee can only receive support, updates and upgrades following the personal product registration in your Steinberg Account. Support is provided only for the current version and for the previous version during one year after publication of the new version. Steinberg can modify, regulate separately for special and multiple licenses and partly or completely adjust the extent of the support (hotline, on the website etc.), updates and upgrades at any time. In case of software with licensing for an educational establishment, the support may be provided according to a separate regulation, for example, with a limited number of persons with access to the usual support for a product, and the rest of users without personal registration but limited to a knowledge base with frequently asked questions and answers (FAQ). You also get support for OEM software without product registration provided that this is specified in the enclosed product documentation and on the packing, if any. In case of Trial Version Software or free products, there exists no support, updates or upgrades.

4.2       Your eligibility for an update, upgrade or crossgrade to the Software will be verified. For details of these processes, please refer to the Steinberg website. Failure to complete the verification process may render the software unusable.   

4.3      You must have a valid license for the previous or more inferior version of the software in order to be allowed to use an update, upgrade or crossgrade for the software; however, the Trial Version Software, NFR products, or free products do not entitle you to the update, upgrade or crossgrade. Upon transferring this previous or more inferior version of the software to third parties the right to use the update, upgrade or crossgrade of the software shall expire. The acquisition of an update, upgrade or crossgrade does not in itself confer any right to use the software. The right of support for the previous or inferior version of the software expires upon the installation and activation of an update or upgrade. At an upgrade the later version can have a modified functional range, for example, functions may be added, modified or dropped.

4.4      The software may contain functions, which exchange information with Steinberg servers via internet connection (separate costs may incur) to offer you e.g. updates and upgrades (e.g. a free update to a later version, if this version appears within 6 weeks after purchase and installation of your product), to download and install such updates.

4.5      The software may also include functions to determine the most appropriate product version for the computer you are using when downloading. The data will be used also for general statistical surveys, to improve our services and for support as well as license management. The exchanged information may include the following details of the used computer: e.g. hardware platform, used downloader and installer programs, operating system version and set language, which product will be installed from which source, free space, comparison of Windows, Mac OS and product version (32 or 64 bit), geolocation (truncated IP-based) and time stamp.

5        Licence module (e.g. Account or eLicenser)

5.1      Steinberg uses for license control an account-based license management or a hardware device connected through the USB connection of a computer (hereinafter "USB-eLicenser") and/or a protection scheme (hereinafter "Soft eLicenser") in the case of many products. In case of account-based license management, certain operations such as transferring your license will require you to log in to your Steinberg account and may require additional verification steps to protect your licenses.Hardware and/or software-based License management technology such as the USB-eLicenser and/or Soft eLicenser permanently saves the license information and regulates access to the software. If a USB-eLicenser is required for the use of the software, then the USB-eLicenser must be connected physically to the computer through the USB interface.

5.2      For the activation of the software, updates or upgrades of the software the computer must be connected to the server of Steinberg through the Internet, in case of the USB-eLicenser by using the device. . If the product was delivered with the USB-eLicenser, the license information can already be transferred to the USB-eLicenser. If the product was delivered with a product card, or online via e.g. email, the enclosed activation codes must be entered manually by the user upon installation and the license information must be exchanged online with the server of Steinberg.

5.3      In the event of OEM software, for which an activation is required for use, the activation codes may be sent to an email-address submitted by you during a registration or otherwise communicated to you. Further, the activation codes must be entered manually by the user upon installation and the license information must be exchanged online with the server of Steinberg.

5.4      The reinstallation of the software - on the same or another computer - is permitted only in case the already installed software cannot be used any more (e.g. following deinstallation). If the software does not use a USB-eLicenser, but requires activation codes, the new activation codes may be obtained from the user's Steinberg account. Possibly, the activation codes must be entered manually by the user upon installation and the license information must be exchanged with the server of Steinberg. Steinberg may require for the provision of further activation codes e.g. your proof of purchase (invoice, receipt) and a validated assurance (e.g. by fax or signed letter) stating your name, address and that the already installed software cannot be used any more. Trial Version Software can be used on a computer also at reinstallation only altogether e.g. 30 or 60 days (or as indicated).

5.5      You can also use another computer other than the one on which the software is to be installed for the activation and transfer of license data to the USB-eLicenser, if the software is using a USB-eLicenser. However, in such a case a corresponding access software (e.g. eLicenser Control Centre, "eLCC") must be installed on the computer connected to the Internet, which may be subject to a separate licensing agreement.

5.6      Steinberg may replace the license management technology used in the future with a new license management technology. In doing so, it may be necessary that for the further use of the software, for example for claiming warranty, changing licenses on the USB-eLicenser, support, updates and upgrades, you must download and install an update regarding the new license management technology and carry out a new activation of the software with the server of Steinberg via the Internet, whereby you will receive the activation codes for this, for example, in your account with Steinberg. You will be informed of the necessary steps if required, for example, via the email address stored in your account with Steinberg.

6        Defect and loss of the USB-eLicenser

6.1      In the case of a defect or damage to the USB-eLicenser Steinberg or a third party engaged by Steinberg will check the USB-eLicenser. In the case of a legitimate claim the USB-eLicenser and the licenses included shall be replaced in return for a handling fee. The licenses will only be replaced provided that they are licenses issued by Steinberg.

6.2      If the USB-eLicenser is mislaid as a result of loss, theft or otherwise, Steinberg will replace upon notification of the registered user the USB-eLicenser and the licenses against a handling fee. Steinberg reserves the right to block the licenses saved on the USB-eLicenser upon being notified by the registered user of the loss.

6.3      In case of defect, loss or damage to the USB-eLicenser, the registered user can obtain via the Steinberg online customer portal a short temporary license for all Steinberg products (25h All Application License) to allow an uninterrupted use of the software (Steinberg Zero Down Time - SZDT). Steinberg may refuse the temporary license and the replacement of the USB-eLicenser according to subsection 6.1, 6.2 and 6.3 at repetition or suspicion of abuse. Further claims against Steinberg are excluded.

7        Modification of the software

7.1      A modification of the software is permitted only insofar as far as the software is capable of such modification in accordance with its intended function. You may not decompile, disassemble, carry out reverse engineering or try in another manner to determine the source code of the software, unless this is permitted by law. Furthermore, you must not modify the binary code of the software to bypass in any manner the activation function or the use of the license module (Account or USB-eLicenser and/or Soft eLicenser).  

8        No Unbundling

8.1      The software usually contains a variety of different files which in its configuration ensure the complete functionality of the software. The software may be used as one product only. It is not required that you use or install all components of the software. You must not arrange components of the software in a new way and develop a modified version of the software or a new product as a result. The configuration of the software may not be modified for the purpose of distribution, assignment or resale.

9        Assignment of Rights

9.1      You may assign all your rights to use the software to another person subject to the conditions that (a) you assign to this other person (i) the Agreement for the software, (ii) the license connected to your Steinberg account, and (iii) the software or hardware provided with the software, packed or preinstalled thereon, including all components, copies, updates, upgrades, backup copies and previous versions, which granted a right to an update or upgrade on this software, (b) you do not retain updates, upgrades, backup copies und previous versions of this software and (c) the recipient accepts the terms and conditions of this Agreement as well as other regulations pursuant to which you acquired a valid software license. Any products issued free of charge, Trial Version Software and software referred to as not-for-resale (NFR) may not be assigned to another person. 

9.2      Any return of the Product due to a failure to accept the terms and conditions of this Agreement shall be excluded after product activation or assignment of rights.  

10     Limited Warranty ("Gewährleistung")

10.1   The warranty ("Gewährleistung") for you as first buyer of the software located within the European Union (EU) is specified in Subsection 10.2 and the warranty for you as first buyer of the software located outside the EU is specified in Subsection 10.3 of this Agreement.

10.2   Limited Warranty within the EU: In the event that you as a first buyer of the software are located within the EU, the following limitation of liability shall apply.

10.2.1   If Steinberg has sold the software directly to you as an end user, Steinberg warrants ("gewährleistet") that the software essentially executes the functions described in the enclosed documentation upon receipt, provided that the software is employed in accordance with the minimum requirements for the operating system and the computer hardware. Insignificant divergences from the functions described in the documentation do not give rise to any warranty claim. Other documents and statements are unremarkable for the composition of the product.

10.2.2   If the user is consumer within the EU, the statutory warranty ("Gewährleistung") to defects of the product shall apply. If the user is a businessman, Steinberg provides warranty for defects of the product at its discretion by further fulfillment (improvement or substitute delivery) within one year. However, there exists no warranty for Trial Version Software or products issued free of charge.

10.3   Limited Warranty outside the EU: In the event that you as a first buyer of the software are located outside the EU, the following limitation of liability shall apply.

10.3.1   Steinberg ensures ("gewährleistet") to the person who acquires first-time the license for the use of the software according to this Agreement, for the duration of ninety (90) days as of receipt of the software, that the software executes essentially the functions described in the enclosed documentation at receipt, provided that the software is employed according to the minimum requirements for the operating system and the computer hardware. Insignificant differences of the functions described in the documentation do not justify any warranty claim. Other documents and statements are insignificant in terms of the quality of the product.

10.3.2   If the software does not essentially fulfill the functions described in the documentation, your only warranty claim against Steinberg and Steinberg's only obligation consists in an exchange of the software or a refund of the selling price at the discretion of Steinberg.

10.3.3   Further warranty obligations according to the laws of your country remain unaffected. However, there exists no warranty for Trial Version Software or products issued free of charge.

11     Limitation of Liability

11.1   The limitation of liability for you as first buyer of the software located within the EU is specified in Subsection 11.2 and the limitation of liability for you as first buyer of the software located outside the EU is specified in Subsection 11.3 of this Agreement.

11.2   Limitation of Liability within the EU: In the event that you as a first buyer of the software are located within the EU, the following limitation of liability shall apply.

11.2.1   Irrespective of the legal grounds Steinberg shall only be liable to compensate or replace futile expenses in accordance with the following stipulations.

11.2.2   Steinberg shall be liable for damages caused by the intentional or grossly negligent conduct of Steinberg, its legal representatives, managerial employees or any other vicarious agents and damages arising from death, bodily damage and damage to health from the assumption of a guarantee or from a procurement risk as well as Steinberg's liability for damages pursuant to the Product Liability Act (Produkthaftungsgesetz). In the case of damage caused by the grossly negligent conduct of any other vicarious agents, the liability shall be limited to those damages which are typically to be expected within the scope of an agreement such as the present one. Any further liability under this Agreement shall be excluded.

11.2.3   In the case of damage caused neither by intentional nor by the grossly negligent conduct of Steinberg, Steinberg shall only be liable where an obligation is violated, the fulfillment of which is of particular significance to the achievement of the contractual purpose (cardinal obligation). In this case, the restrictions of liability pursuant to the foregoing subsection 11.2.2 sentences 2 and 3 shall apply. In case of Trial Version Software and software or services without charge, the liability for damages according to this subsection shall be excluded.

11.2.4   The liability for loss of data shall be limited to the typical cost and effort of retrieving the data which would have occurred, if the data had been stored properly and in a risk-adequate manner.

12.2.5  This limitation of liability for Steinberg shall also apply for the benefit of Steinberg's employees in the event that any claims are filed directly against them.

11.3   Limitation of Liability outside the EU: In the event that you as a first buyer of the software are located outside the EU, the following limitation of liability shall apply.

11.3.1   Except for the aforementioned rights Steinberg or Steinberg's authorized distributors assume no liability for loss, damages, claims or costs of any type, direct or indirect damages including consequential damages arising from business interruptions, injuries to persons, or lack of due care or claims of third parties, even if a representative of Steinberg was informed about the possibility of such losses, damages, costs or claims. This limitation shall apply also in the event of a fundamental breach of this Agreement.

11.3.2   The total liability of Steinberg and its distributors in the context of this Agreement shall be limited to the amount which was paid for the software, if any.

11.3.3   The aforementioned restrictions shall not apply in countries where a limitation of liability is inadmissible.

12     Infringement

12.1    You should inform Steinberg promptly in writing if a third party raises any claim against your use of the software. Steinberg may defend you, if you reasonably support Steinberg. 

13     Further Provisions  

13.1   Steinberg is entitled to send you a modified version of the Agreement replacing the existing version which you may accept or which will be deemed to be accepted unless you object in written form within two weeks. Steinberg will inform you about this in the notification of the modified version of the Agreement.

13.2   This Agreement constitutes the entire understanding of the subject matter between the parties. Subsidiary agreements have not been concluded. Supplements and amendments of this Agreement must be made in writing; a waiver of the requirement of the written form must also be made in writing.

13.3   If any provision of this Agreement should be or become invalid, in whole or in part, this shall not affect the validity of the remaining provisions. The invalid provision shall be deemed to be replaced by the parties with a valid regulation which comes as close as possible to the commercially desired purpose originally intended for the ineffective provision; the same shall apply in the case of a contractual gap.

13.4   This Agreement shall be governed and construed by the laws of the Federal Republic of Germany excluding the UN Convention on the International Sale of Goods (CISG) and the EU conflicts of law (Rome I), which shall not apply.

13.5   The exclusive place of jurisdiction with respect to all disputes based on or in connection with this Agreement shall be Hamburg. Steinberg can bring an action against you at your general place of jurisdiction.

 

 

 

Information on Data Protection

 

1.      Steinberg located in Germany will comply with the EU General Data Protection Regulation (EU GDPR) and the German Data Protection Act. At the creation of an account with Steinberg you are asked to provide your personal data (like name, address, email-address, date of birth, country) and at the product registration within your account the license data for the purposes specified.

2.      The controller of the personal data is Steinberg Media Technologies GmbH (Steinberg) located at Beim Strohhause 31, 20097 Hamburg, Germany with contact at info@steinberg.de. The Steinberg data protection officer is available at dpo@steinberg.de.

3.      The purpose of processing is the contract fulfilment, in particular creation and use of the Steinberg Account, license control, download, installation, use of registered products and services, receipt of support, updates and upgrades. The legal basis for processing is the Agreement according to Art. 6 para. 1 b) EU GDPR. In the case of products supplied free of charge, exchange and processing of usage data serves product improvement and is based on the fulfilment of the Agreement according to Art. 6 para. 1 b) EU GDPR. In the case of Trial Version Software, the exchange and processing of usage data serves product improvement and is based on a legitimate interest according to Art. 6 para. 1 f) EU GDPR for software improvement with the possibility of objection, for example, in the product or Steinberg account. In the case of products purchased, there may be an option to give one-time or permanent consent to the exchange and processing of usage data serving product improvement and support according to Art. 6 para. 1a) EU GDPR, with the possibility to withdraw the consent at any time for the future, for example, in the product or Steinberg account. The period of storage will be for the use of the account and registered products and services until deleted by the user, objection or withdrawal against usage data, which are stored for a maximum up to 2 years, or without a registered product and service after one year or after 48 hours following the creation of the Steinberg Account, if the user does not confirm the Steinberg Account upon request by the email provided.

4.      Recipients of the data may be Steinberg’s employees for support reasons or distribution and sales partners also outside the EU/EEA. The regional distribution or sales partner in whose area you specify your country of residence in the account can view the data for requested support. The regional distribution or sales partner are listed in the account. Further categories of recipients as suppliers even outside the EU/EEA with safeguards of an adequate data protection like an EU model clause agreement, which Steinberg will provide upon request as copy

- Identity and Access Management:  ForgeRock Ltd., UK,
safe third country according to the adequacy decision of the EU Commission 

- License Management: 10Duke Software Limited, UK, safe third country according to the adequacy decision of the EU Commission

          - Hosting:  Amazon Web Services LLC, USA, AWS GDPR Data Processing Addendum which also includes the EU model clauses; Corpex Internet GmbH, Germany, Commissioned Data Processing Agreement

          - Ticket System:  Zendesk Inc., USA, EU model clauses

5.      The user has the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject as well as the right to data portability and to lodge a complaint with a supervisory authority. If you do not provide or restrict mandatory data, the software or the service, support, update and upgrades may not work.

6.      Steinberg reserves the right to modify and update this information on data protection at any time. For example, Steinberg is entitled to replace or involve any contract processor as supplier even located outside the EU/EEA. Steinberg may inform you about relevant changes.