Legal
Data Processing Addendum
Before you publish this: a working draft describing how Sensa actually processes data. It is not a substitute for a DPA reviewed against the law that applies to you, and it should be checked by a lawyer before it forms part of a contract.
1. Roles
Your spa is the controller. Sensa is the processor. You decide what guest data is collected and why; we process it to provide the service.
2. Scope of processing
| Item | Detail |
|---|---|
| Subject matter | Provision of the Sensa spa operations platform. |
| Duration | The term of your agreement, plus the agreed deletion window. |
| Nature and purpose | Storing and processing bookings, visits, transactions and guest records so a spa can operate. |
| Categories of data subject | Your guests, your staff, and your corporate contacts. |
| Categories of personal data | Identity and contact details, appointment and visit history, preferences, transactions, and — where you record them — clinical and consultation records. |
| Special category data | Health data, where your property records it. Held separately at the permission level. |
3. Our obligations
- Process only on your documented instructions.
- Ensure that personnel with access are bound by confidentiality.
- Apply the technical and organisational measures described on our Security page.
- Not engage a new subprocessor without notifying you and allowing you to object.
- Assist you with data-subject requests, impact assessments and consultations.
- Delete or return personal data at the end of the agreement, at your choice.
- Make available the information reasonably needed to demonstrate compliance.
4. Breach notification
We will notify you without undue delay after becoming aware of a personal data breach affecting your data, with what we know at the time — including the parts that are unflattering to us — and will keep you updated as we learn more.
5. Subprocessors
The current list is provided on request and depends on your deployment. A self-hosted deployment on your own infrastructure may involve none at all.
6. International transfers
Where data would be transferred outside its region of origin, we agree the location with you in advance so your residency obligations can be met.
7. Audit
You may audit our compliance with this addendum on reasonable notice. We do not currently hold a third-party certification that could stand in for such an audit, and we say so on our Security page rather than implying otherwise.