Data processing agreement
This agreement applies between the salon as controller and Filippos Kagkiouzis, Würzburger Straße 2, 60385 Frankfurt am Main (“Bookry”) as processor for all personal data the salon processes through Bookry. It becomes part of the terms when a salon registers.
1. Subject, nature and purpose
Running an online booking service for the salon: taking and managing appointments, sending confirmations, reminders and cancellation notices, keeping the client record, and producing reports for the salon. The processor does not process the data for its own purposes. In particular, a salon’s clients are never referred to another salon and never used for advertising.
2. Duration
The agreement runs for as long as the salon uses Bookry and ends with the main contract.
3. Types of data and categories of data subjects
- Clients of the salon
- Name, email address, phone number, booked services, appointments, voluntary notes, chosen language
- Staff of the salon
- Name, working hours, absences, skills, assignment to appointments
- Salon account
- Name, email address, password as a hash, sign-in timestamps
- Technical data
- IP address for access limiting, error logs, session identifiers
4. Instructions
The processor processes the data only on the documented instructions of the salon. Instructions are given through the settings of the software or in text form. If the processor considers an instruction unlawful, it will say so and may suspend execution.
5. Confidentiality
Everyone involved in the processing is bound to confidentiality. Access to salon data is limited to what is necessary.
6. Technical and organisational measures (Article 32)
- Transmission
- Encrypted over TLS only; HSTS enforced
- Passwords
- Stored only as a hash, never in clear text, never in a log
- Tenant separation
- Every database query is automatically scoped to the salon; one salon cannot technically reach another salon's data
- Access limiting
- Counter against automated access on sign-in, booking and waiting list
- Server location
- Application and database in Frankfurt am Main (EU). The sub-processors are based in the USA; any transfer there is covered by the EU Standard Contractual Clauses and, where certified, the EU-US Data Privacy Framework
- Fonts and scripts
- Self-hosted; no third-party embeds on the public pages
- Logs
- Error logs without clear-text passwords, limited retention
7. Sub-processors
The salon agrees to the following sub-processors. Before a change or an addition the processor gives at least 30 days’ notice by email; the salon may object and, in that case, terminate.
- Vercel Inc., USA
- Running the application; Frankfurt am Main data centre
- Neon, LLC (Databricks), USA
- Storing salon and booking data; Frankfurt am Main (AWS eu-central-1)
- Resend (Plus Five Five, Inc.), USA
- Sending confirmations, reminders and cancellation notices; sending servers in the EU, processing also in the USA
8. Assisting the salon
The processor assists the salon with access, rectification, erasure, restriction, portability and objection requests, and with data protection impact assessments and notification duties. If a client contacts the processor directly, they are referred to the salon and the salon is informed.
9. Personal data breaches
The processor notifies the salon of any breach without undue delay after becoming aware of it, at the latest within 24 hours, with everything the salon needs for its notification under Article 33 GDPR.
10. Deletion and return
After the contract ends the salon has 30 days to export its data. It is then deleted unless a statutory retention duty applies.
11. Evidence and audits
The processor provides the information needed to demonstrate compliance and allows audits after prior notice, as far as operations are not impaired.
12. Contact
Questions about data processing: hello@bookry.de. We provide a signed copy on request.