Privacy Policy

1. Controller, processor roles and contact

Clinilo FZE LLC, registration number 4431302, Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates, is controller for Clinilo account administration, contracting, security, support, website operation and legal compliance. Contact casper@swprlabs.com. The appointed EU representative and service address are identified in section 1 of the Platform Terms.

A clinic is controller for its staff, client and booking data and must publish its own clinic privacy notice. Clinilo processes that data only as processor under the DPA and clinic instructions. If a request concerns clinic-controlled data, Clinilo normally forwards it to the clinic and assists it.

2. Ordinary-data-only launch scope

Policy ordinary-data-only-2026-08-16 applies. Clinilo does not accept health data or any other special category during Managed Launch. Clinical journals, treatment notes, diagnoses, intake answers, clinical forms, treatment photos and service or message text revealing health status are prohibited and health-data features are disabled. Clinics must use neutral service labels and collect clinical information outside Clinilo.

3. Personal data and sources

• Account and business data: name, work contact, clinic identity, role, language, agreement versions and acceptance/audit evidence.
• Ordinary clinic-service data processed for a clinic: neutral service and staff details, availability, client contact, appointment time/location, cancellation status, ordinary messages, offline invoice status and preferences.
• Security and technical data: account/session identifiers, IP address, user agent, authentication and reset events, authorization decisions, audit events, timestamps, release and bounded error categories.
• Support and legal data: correspondence, requests, agreement archive, business identity and information needed for claims or compliance.

We receive data from account users and clinic customers, from a client who books with a clinic, automatically from the browser and service, and from delivery/security providers. We do not buy health profiles or enrich clinic data for advertising.

4. Purposes and legal bases

Where Clinilo acts as processor, the clinic chooses its Article 6 basis and purpose. The clinic cannot rely on Clinilo to establish a health-data Article 9 condition because special-category processing is unavailable.

5. Required and optional data

Identity, work contact, authority, secure credentials and required clinic/account settings are needed to create and protect an account; refusing them may prevent service. A booking requires the ordinary seller, service, time and contact details shown in the flow. Remember-details and statistics choices are optional. Free text is never a route for health or other special-category data.

6. Recipients and international transfers

Recipients are authorized Clinilo personnel, the clinic controlling client data, and the providers needed for hosting, the Supabase database queue, Vercel cron processing, email, SMS, private object storage and bounded error monitoring. Stripe, PostHog and AI model providers do not receive Managed Launch Customer Data. Exact entities, purposes, locations and backup limits are in the Subprocessor List.

Clinilo is established in the UAE. EEA-to-UAE and US-provider transfers use an adequacy decision where available or appropriate safeguards, normally the European Commission Standard Contractual Clauses, plus minimization, access control, encryption where applicable, transfer review and reasonable challenge of unlawful demands. Contact us for a copy or description of the safeguards.

See the Subprocessor List

7. Retention and security

We retain controller records only while needed for the stated account, security, support, agreement, claim and compliance purposes, using applicable limitation and statutory accounting criteria rather than one universal period. Customer-controlled data follows clinic instructions, the DPA, the active term, exit/retrieval period and narrow legal holds. The owner archive preserves exact accepted agreement versions and durable receipts for accountability. Optional browser values have the durations in the Cookie Policy.

Security includes tenant isolation, role and membership checks, secure credentials, TLS, managed encryption at rest, private storage, audit and deployment controls. The Frankfurt database has daily backups with the current seven-day window; those backups exclude object-storage files. The EU-jurisdiction R2 bucket has no represented independent backup, versioning or object lock. No point-in-time or universal file-recovery promise is made.

8. Rights, requests and complaints

Where the GDPR applies, a person may request access, correction, deletion, restriction and portability, object to legitimate-interest processing, withdraw consent prospectively and complain to a competent supervisory authority. Rights depend on the context and may be limited by law. Contact casper@swprlabs.com. We verify identity proportionately and respond within the applicable period. For clinic-controlled booking data, contact the clinic first or ask us to forward the request.

A Danish person may complain to Datatilsynet, Carl Jacobsens Vej 35, 2500 Valby, Denmark, or another authority competent for the person’s residence, work or alleged infringement. Contacting us first is welcome but not required.

9. Allocation, sale, training and changes

Clinilo does not make solely automated decisions with legal or similarly significant effects about individuals. Staff allocation and availability rules support clinic scheduling and remain subject to clinic configuration and review. Clinilo does not sell personal data, use it for cross-context behavioral advertising or train general-purpose AI models on identifiable Customer Data.

We version material changes, publish the effective date and give direct notice where law or the Platform Terms require it. A new purpose, special-category processing, provider or optional browser technology requires prior assessment and, where required, a new notice or consent. Earlier legal versions remain accessible.