Data Processing Agreement

Last updated: January 27, 2026

This Data Processing Agreement ("DPA") forms part of the agreement between Clean Wake AB ("Processor," "we," "us") and the customer ("Controller," "you") for the use of Digital Clinic services.

This DPA applies when we process personal data on your behalf as a data processor under the EU General Data Protection Regulation (GDPR) or UK GDPR.

1. Definitions

"Personal Data" means any information relating to an identified or identifiable natural person that you submit to Digital Clinic.

"Processing" means any operation performed on Personal Data, such as collection, storage, use, disclosure, or deletion.

"Data Subject" means the individual whose Personal Data is processed.

"Sub-processor" means any third party engaged by us to process Personal Data on your behalf.

"Data Protection Laws" means GDPR, UK GDPR, and other applicable data protection legislation.

2. Roles and Responsibilities

2.1 You as Controller

When you use Digital Clinic for your veterinary practice, you are the data controller for:

  • Patient records and case data you upload

  • Pet owner personal information

  • Any other personal data you input into the platform

As controller, you are responsible for:

  • Ensuring you have a lawful basis for processing

  • Obtaining necessary consents from data subjects

  • Responding to data subject requests (we'll help where we can)

  • Complying with your obligations under Data Protection Laws

2.2 We as Processor

We process Personal Data on your behalf according to your instructions. We will:

  • Process Personal Data only for the purposes of providing the Services

  • Follow your documented instructions (this agreement and your use of our features constitute your instructions)

  • Maintain confidentiality

  • Implement appropriate security measures

  • Assist you in meeting your obligations

3. Processing Details

3.1 Subject Matter and Duration

We process Personal Data to provide the Digital Clinic platform. Processing continues for the duration of our agreement, plus any retention period specified in our Privacy Policy.

3.2 Nature and Purpose

We process Personal Data to:

  • Enable case management and specialist consultations

  • Facilitate communication between veterinary professionals

  • Store and display case information and media

  • Process payments and manage accounts

  • Provide customer support

  • Maintain platform security

3.3 Types of Personal Data

Depending on how you use the Services, we may process:

  • Pet owner data: Names, contact details, addresses

  • Patient data: Animal information, medical histories, diagnostic results

  • Professional data: Veterinarian and staff information, credentials

  • Communication data: Messages, call recordings, notes

  • Media: Images, videos, documents

3.4 Categories of Data Subjects

  • Pet owners

  • Veterinary professionals

  • Clinic staff

  • Specialists

4. Your Instructions

You instruct us to process Personal Data as necessary to:

  • Provide and maintain the Digital Clinic platform

  • Process and store data you upload

  • Enable features you choose to use

  • Provide support when requested

  • Comply with applicable law

If we believe an instruction violates Data Protection Laws, we'll let you know.

5. Confidentiality

Everyone at Clean Wake AB who handles your data is bound by confidentiality obligations. We only allow access to Personal Data on a need-to-know basis.

6. Security

We implement appropriate technical and organizational measures to protect Personal Data, including:

  • Encryption: Data encrypted in transit (TLS) and at rest

  • Access controls: Role-based access, authentication requirements

  • Infrastructure security: Secure hosting with reputable cloud providers

  • Monitoring: Security monitoring and incident detection

  • Employee measures: Background checks, training, confidentiality agreements

We regularly review and update our security measures. Details are available on our Security page.

7. Sub-processors

7.1 Authorization

You authorize us to engage sub-processors to help provide the Services. Our current sub-processors are:

7.2 Sub-processor Obligations

We ensure sub-processors are bound by data protection obligations at least as protective as this DPA.

7.3 Changes to Sub-processors

We'll notify you at least 30 days before engaging a new sub-processor or making material changes. You can object by contacting us. If we can't reasonably accommodate your objection, either party may terminate the affected Services.

8. International Transfers

Some sub-processors are located outside the EU/EEA. For these transfers, we ensure appropriate safeguards:

  • Standard Contractual Clauses (SCCs) approved by the European Commission

  • Additional measures where required

9. Assistance with Your Obligations

9.1 Data Subject Rights

If we receive a request from a data subject about their data, we'll promptly notify you. We'll assist you in responding to requests for access, rectification, erasure, restriction, portability, and objection.

9.2 Security Incidents

If we become aware of a Personal Data breach, we will:

  • Notify you without undue delay (and within 48 hours where feasible)

  • Provide information to help you assess and report the breach

  • Assist with breach response and mitigation

  • Document the breach and our response

9.3 Data Protection Impact Assessments

We'll provide reasonable assistance if you need to conduct a data protection impact assessment related to your use of Digital Clinic.

9.4 Regulatory Inquiries

We'll assist you in responding to inquiries from data protection authorities, to the extent the inquiry relates to our processing.

10. Audits

You have the right to audit our compliance with this DPA. In practice:

  • We'll provide relevant documentation and certifications on request

  • We'll answer reasonable questions about our practices

  • For on-site audits, please give us reasonable notice and we'll work together to minimize disruption

We may engage an independent auditor to conduct audits and share results with you under appropriate confidentiality terms.

11. Data Deletion

When our agreement ends, or upon your request, we will:

  • Delete your Personal Data within 90 days

  • Provide a copy of your data in a standard format (on request, before deletion)

  • Certify deletion upon request

Exceptions:

  • Data required by law to be retained

  • Data in backup systems (deleted according to normal backup cycles)

  • Anonymized data that no longer identifies individuals

12. Liability

Each party's liability under this DPA is subject to the limitations in our Terms of Service.

13. Term

This DPA is effective when you start using Digital Clinic and continues until we no longer process Personal Data on your behalf.

14. Governing Law

This DPA is governed by Swedish law. For disputes, see our Terms of Service.

15. Standard Contractual Clauses

Where transfers of Personal Data from the EU/EEA to outside the EU/EEA occur, the EU Standard Contractual Clauses (Module Two: Controller to Processor) are incorporated by reference and form part of this DPA.

For these purposes:

  • You are the "data exporter"

  • We are the "data importer"

  • The "competent supervisory authority" is the Swedish Authority for Privacy Protection (IMY)

  • The governing law is Swedish law

The Annexes to the SCCs are completed as follows:

Annex I.A (List of Parties):

  • Data exporter: You (the customer)

  • Data importer: Clean Wake AB

Annex I.B (Description of Transfer):

  • Categories of data subjects, data types, and processing purposes as described in Section 3 of this DPA

Annex II (Technical and Organizational Measures):

  • As described in Section 6 of this DPA and our Security Overview

Annex III (Sub-processors):

  • As listed in Section 7 of this DPA

Contact

Questions about this DPA?

Clean Wake AB • Sprängarvägen 27 • 184 70 Åkersberga • Sweden • Email: team@digitalclinic.vet • Phone: +46 73 089 2038

Data Protection Officer • Hannes Schippmann • Email: hannes@digitalclinic.vet • Phone: +46 73 510 62 05

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