Data processing agreement

1. Subject and duration

The processor processes personal data on behalf of the controller to provide RingUp, for the duration of the subscription and the deletion period that follows it.

2. Nature and purpose

Creating tickets, showing their status to the controller's customers, alerting them by web notification or text message, displaying numbers on screens in the controller's premises, collecting ratings, and producing statistics for the controller.

3. Data and people concerned

People concerned: the controller's customers or patients, and its staff.

Data: ticket numbers and times, language, table number, phone number (when the customer asks for a text message), push subscription, first name (clinic mode only), ratings and comments; staff first names and PIN hashes.

The controller must not enter health information or other special categories of data in the service. A first name in a clinic queue is the most the service is designed to hold.

4. Instructions

The processor acts only on the controller's documented instructions, which are these terms and the controller's settings in the service, unless the law requires otherwise; in that case the processor informs the controller unless the law forbids it.

5. Confidentiality

Everyone authorised to process the data is bound by confidentiality.

6. Security

The processor applies appropriate technical and organisational measures, including encryption in transit, encryption at rest of integration secrets, one-way hashing of PINs and sign-in links, access control and logging, automatic deletion of phone numbers and first names 24 hours after a ticket closes, and backups.

7. Sub-processors

The controller authorises the sub-processors listed on the sub-processors page. The processor will announce any new sub-processor at least 30 days in advance by email; the controller may object on reasonable grounds and, if no solution is found, cancel. The processor imposes the same data protection obligations on its sub-processors and remains responsible for them.

8. Assistance

The processor helps the controller answer requests from people exercising their rights, and with security, breach notification, impact assessments and prior consultation, as far as the nature of the processing allows.

9. Personal data breaches

The processor notifies the controller without undue delay, and within 48 hours of becoming aware of a breach, with the information available to help the controller meet its own obligations.

10. End of processing

When the subscription ends, the controller may export its data for 90 days; the processor then deletes it, including copies, except where the law requires it to be kept.

11. Audits

The processor makes available the information needed to demonstrate compliance with this agreement and allows audits by the controller or an auditor it mandates, with reasonable notice, at most once a year unless a breach justifies more, and subject to confidentiality.

12. Transfers

Transfers outside the European Economic Area take place only with the safeguards described in the privacy policy.