EU DSA / P2B Transparency Notice
Digital Services Act & Platform-to-Business compliance information
Owner & Contact
Owner/Operator: Spyface Tech Company, LLC (d/b/a "ClinicBooking") — 30 N Gould St Ste N, Sheridan, WY 82801, USA
Corporate: hello@spyface.com
Support: care@clinicbooking.com
Single point of contact (EU DSA): dsa@clinicbooking.com
Business-user support: partners@clinicbooking.com
On This Page
Scope & Roles
This notice explains how ClinicBooking communicates key transparency items under the EU Digital Services Act ("DSA") and the EU Platform-to-Business Regulation (Reg. (EU) 2019/1150, "P2B"), to the extent applicable to our service and EU business users. ClinicBooking is an online intermediary that hosts user-generated content (UGC) and connects consumers with independent clinics and healthcare providers ("Providers"). We are not a medical provider and do not practice medicine.
Main Ranking Parameters
Our search and browse results order ("ranking") primarily reflects relevance to the user's query and safety/reliability signals. The principal parameters (shown in descending weight) include:
ServiceScore™ components.| Parameter | What it is | Relative importance |
|---|---|---|
| Query Relevance | Match between user input (specialty, treatment, location) and the Provider's declared specialties, taxonomy, and service areas. | High |
| Proximity | Distance to the searched location or user-selected map point (where applicable). | High |
| License & Verification Status | Verified licensing, sanction checks, and profile verification status (where available in the jurisdiction). | Medium–High |
| Responsiveness | Response rates and timeliness to consumer inquiries via ClinicBooking tools (rolling window). | Medium |
| Consumer Signals | Volume, recency, and diversity of user feedback; integrity-screened ratings; ServiceScore™ components. | Medium |
| Profile Quality | Completeness and clarity of profile (e.g., services list, languages, hours, media that meets our guidelines). | Medium |
| Regulatory Flags | DSA-relevant safety measures (e.g., restricted visibility or downranking after repeated policy violations). | Variable (can override) |
| Paid Placement | Advertisements or sponsored modules, clearly labeled and segregated ("Ad", "Sponsored"). | Separated; does not alter organic signals |
We periodically test parameters (A/B tests) to improve user safety and relevance; material changes will be summarized on this page.
Differential Treatment & Paid Placement
- We do not sell preferential organic ranking. Sponsored inventory is displayed in distinct ad units with clear labels (e.g., "Ad", "Sponsored").
- Paid features (e.g., profile enhancements) do not override the integrity of safety signals or organic ordering.
- ClinicBooking does not offer its own competing medical services, and thus no "self-preferencing" applies.
Content Moderation & Notice–Action
We host reviews, Q&A, photos/videos, and profile content. Moderation combines automated and human review.
| Process | Overview |
|---|---|
| Detection | Automated filters and manual checks for illegality, deception, harmful health claims, privacy violations, or IP infringement. |
| Notices | Any person may submit a notice via dsa@clinicbooking.com or our web form, identifying the content, the reasons, and supporting materials. |
| Action | Actions can include label, deprioritize, geo-block, restrict features, remove content, or suspend accounts. |
| Statement of Reasons | When we remove or restrict content/user privileges, we issue a statement of reasons (DSA Art. 17) to the affected user, unless legally barred. |
| Trusted Flaggers | We give priority to notices from EU-designated trusted flaggers (DSA Art. 22) regarding illegal content. |
| Repeat Abuse | We may suspend for repeated manifestly unfounded notices (Art. 23) or systemic policy breaches. |
Internal Complaints & Out-of-Court Settlement
- Internal channel: Submit complaints or appeals within 6 months of our decision to partners@clinicbooking.com (business users) or care@clinicbooking.com (consumers). We aim to respond within 14 days.
- Out-of-court dispute settlement (DSA Art. 21): Where available, we will engage in proceedings with certified bodies.
- P2B mediation: We are willing to engage recognized mediators (e.g., ICC International Centre for ADR; CEDR). Fees borne as allocated by the mediator or equally absent allocation.
Restriction / Suspension / Termination (P2B)
We may restrict visibility, suspend, or terminate business-user accounts for, e.g., repeated policy breaches, illegal content, misleading claims, unsafe practices, fraud, scraping, or non-payment.
Notice: Unless urgent, we provide prior notice with reasons, a reference to the violated provisions, and the complaint/appeal route. In urgent cases (e.g., safety/legal risk), we may act immediately and notify afterward.
Business-User Data Access & Sharing
| Data category | Access provided to business users | Notes |
|---|---|---|
| Leads & inquiries | Provider receives consumer contact details and inquiry content submitted to that Provider. | Providers must comply with privacy laws; no resale of personal data. |
| Performance metrics | Dashboards show impressions, clicks, response metrics, and booking funnels. | Aggregate/derived analytics; no access to other providers' data. |
| Reviews | Published review content and public responses; limited notification extracts. | No access to reviewer PII beyond what the reviewer publicly shares. |
| Advertising reports | Campaign performance and billing statements. | No access to platform-level or competitor targeting logic. |
Ads & Recommender Transparency
- Ad labeling: Paid placements are labeled (e.g., "Ad"/"Sponsored").
- Main ad parameters: Query context, location, audience fit (non-sensitive), budget pacing, and quality signals. We do not enable ads targeted on sensitive health conditions.
- Recommenders: If we present "suggested" providers/content, parameters mirror Section 2 (safety may override).
EU Monthly Active Recipients (MAU)
We assess average monthly active recipients in the EU as required by DSA Art. 24(2). We have not been designated a "Very Large Online Platform (VLOP)." If our EU MAU approaches the 45M threshold, we will publish updated figures here and in our transparency reporting.
Changes to Terms (P2B)
Material changes to our business-user terms will be notified at least 15 days in advance (longer where required), except where immediate changes are needed for legal, security, or anti-abuse reasons.
Contacts & Reporting Channels
| Purpose | How to reach us |
|---|---|
| Single point of contact (DSA) | dsa@clinicbooking.com |
| Illegal content / Notice–action | dsa@clinicbooking.com |
| Business-user complaints (P2B) | partners@clinicbooking.com |
| General support | care@clinicbooking.com |
| Corporate / legal | hello@spyface.com |