Comprehensive data protection framework for controllers and processors
Owner/Operator: Spyface Tech Company, LLC (d/b/a "ClinicBooking")
Address: 30 N Gould St Ste N, Sheridan, WY 82801, USA
Subject matter
Provision of ClinicBooking platform (lead capture, messaging, appointment scheduling, payments facilitation), and related support.
Duration
For the term of the underlying service agreement and any data retention period required by law or explicitly instructed by Customer.
Nature & purpose
Hosting, storage, transmission, display and processing of Personal Data strictly as needed to provide the services; security monitoring; fraud prevention; troubleshooting; service analytics as Processor to Customer.
Data subjects
Patients/consumers; prospective patients/leads; Customer's staff and providers; Customer's administrators; ClinicBooking support contacts.
Personal data categories
Identification & contact data; account/profile data; appointment & inquiry details; communications metadata and content sent via platform; device/usage identifiers (IP, user agent); location approximations; limited payment identifiers (token/last4; no full PAN stored by ClinicBooking); optional health-related details that Customer inputs.
Special categories
Health-related information may be processed as instructed by Customer. No PHI unless a separate BAA is executed.
Processor role
ClinicBooking acts on Customer's documented instructions (see §4) and uses Subprocessors listed in this DPA (see §7 and §15).
| Item | Description |
|---|---|
| Subject matter | Provision of ClinicBooking platform (lead capture, messaging, appointment scheduling, payments facilitation), and related support. |
| Duration | For the term of the underlying service agreement and any data retention period required by law or explicitly instructed by Customer. |
| Nature & purpose | Hosting, storage, transmission, display and processing of Personal Data strictly as needed to provide the services; security monitoring; fraud prevention; troubleshooting; service analytics as Processor to Customer. |
| Data subjects | Patients/consumers; prospective patients/leads; Customer's staff and providers; Customer's administrators; ClinicBooking support contacts. |
| Personal data categories | Identification & contact data; account/profile data; appointment & inquiry details; communications metadata and content sent via platform; device/usage identifiers (IP, user agent); location approximations; limited payment identifiers (token/last4; no full PAN stored by ClinicBooking); optional health-related details that Customer inputs. |
| Special categories | Health-related information may be processed as instructed by Customer. No PHI unless a separate BAA is executed. |
| Processor role | ClinicBooking acts on Customer's documented instructions (see §4) and uses Subprocessors listed in this DPA (see §7 and §15). |
Organization & governance
Security program; risk assessments; access approvals; least privilege; background checks where permitted; vendor risk management.
Physical & infrastructure
Data centers with industry certifications (via cloud providers); redundant power/network; physical access controls.
Logical access
MFA for privileged accounts; strong auth; role-based access; session management; logging and monitoring.
Data protection
Encryption in transit (TLS 1.2+); encryption at rest for primary stores; key management by reputable cloud KMS; secure deletion routines.
Development & change
Secure SDLC; code review; dependency management; secrets management; staging segregation; CI/CD controls.
Vulnerability & incident
Automated scanning; patching SLAs; third-party testing as needed; incident response plan; breach notification (§10).
Business continuity
Backups; tested restores; documented DR procedures.
Privacy by design
Data minimization; purpose limitation; retention controls; audit logs; DSR tooling support.
| Control area | Measures |
|---|---|
| Organization & governance | Security program; risk assessments; access approvals; least privilege; background checks where permitted; vendor risk management. |
| Physical & infrastructure | Data centers with industry certifications (via cloud providers); redundant power/network; physical access controls. |
| Logical access | MFA for privileged accounts; strong auth; role-based access; session management; logging and monitoring. |
| Data protection | Encryption in transit (TLS 1.2+); encryption at rest for primary stores; key management by reputable cloud KMS; secure deletion routines. |
| Development & change | Secure SDLC; code review; dependency management; secrets management; staging segregation; CI/CD controls. |
| Vulnerability & incident | Automated scanning; patching SLAs; third-party testing as needed; incident response plan; breach notification (§10). |
| Business continuity | Backups; tested restores; documented DR procedures. |
| Privacy by design | Data minimization; purpose limitation; retention controls; audit logs; DSR tooling support. |
Amazon Web Services (AWS)
Cloud hosting, storage, databases, KMS
All data stored by platform
USA/EU (region as configured)
Cloudflare
CDN, WAF, DDoS protection
IP, request metadata, cached content
Global
Stripe
Payment processing
Payment tokens/last4, billing info (no full PAN by ClinicBooking)
USA/EU
Twilio
SMS/voice routing
Phone numbers, call/SMS metadata, recordings if enabled
USA/EU
Mailgun / SendGrid
Transactional email
Email, message metadata, limited content
USA/EU
Campaign Monitor / Iterable
Marketing communications (where permitted)
Contact data, subscription preferences
USA/EU
Trustpilot
Service feedback collection
Contact data for invitations, review metadata
EU/Global
Analytics providers (e.g., Google Analytics)
Usage analytics, performance
Device/usage data, IP (as configured)
Global
121BPO (or equivalent support vendor)
Customer support overflow/NDA-bound ops
Ticket metadata, limited contact/inquiry details
As contracted
| Subprocessor | Purpose | Data categories | Primary processing location |
|---|---|---|---|
| Amazon Web Services (AWS) | Cloud hosting, storage, databases, KMS | All data stored by platform | USA/EU (region as configured) |
| Cloudflare | CDN, WAF, DDoS protection | IP, request metadata, cached content | Global |
| Stripe | Payment processing | Payment tokens/last4, billing info (no full PAN by ClinicBooking) | USA/EU |
| Twilio | SMS/voice routing | Phone numbers, call/SMS metadata, recordings if enabled | USA/EU |
| Mailgun / SendGrid | Transactional email | Email, message metadata, limited content | USA/EU |
| Campaign Monitor / Iterable | Marketing communications (where permitted) | Contact data, subscription preferences | USA/EU |
| Trustpilot | Service feedback collection | Contact data for invitations, review metadata | EU/Global |
| Analytics providers (e.g., Google Analytics) | Usage analytics, performance | Device/usage data, IP (as configured) | Global |
| 121BPO (or equivalent support vendor) | Customer support overflow/NDA-bound ops | Ticket metadata, limited contact/inquiry details | As contracted |
We will post updates to this list prior to onboarding a new Subprocessor or changing a processing location. To receive change notices, email privacy@clinicbooking.com with subject "Subscribe — Subprocessor Updates".
Privacy/DPA: privacy@clinicbooking.com
Address: Spyface Tech Company, LLC (ClinicBooking), 30 N Gould St Ste N, Sheridan, WY 82801, USA