Data processing agreement

The customer is the organization or independent professional determining clinical purposes; Karizo EOOD processes customer data supplied through MediSend. This agreement does not cover our own controller activities described in the Privacy Notice. It applies for the service term, retention and organized return or deletion.

Subject matter: secure uploads, handovers, storage, authorized receiving, archive, export and deletion. Operations: receiving, organizing, safety checks, storage, permission- and time-bound disclosure, technical recovery and removal. Data subjects: patients, recipients and authorized professionals. Data: customer-selected health files, images and documents, identifiers, contact details, clinical metadata and permitted-access history.

The customer determines purposes, recipients, permissions and specific retention and provides the lawful basis and information to individuals. Advertising, model training, global patient search or an independent new clinical purpose for the processor is not authorized.

We follow documented contractual and authorized service instructions, including for transfers. If law requires different processing, we notify the customer beforehand where permitted. We flag instructions we believe breach data-protection rules and seek clarification before executing them. Access is limited to authorized persons subject to confidentiality duties.

Safeguards include organization isolation, file-specific permissions, bounded sessions, MFA, encrypted security material, private storage, traceable issuance and revocation, safety checks and restricted administration. The Security Measures schedule describes their scope and validation. Operators must establish scanner, backup and restoration operation before real health data; code alone does not prove operational effectiveness.

General authorization covers only verified subprocessors listed in the effective activity-specific register. Equivalent contractual duties apply, and MediSend remains responsible for their performance within the applicable scope. A new supplier requires advance information and a reasonable opportunity to raise data-protection objections; the precise contractual notice period is to be approved before publication.

International transfers require an applicable mechanism and documented assessment before activation. Services with unconfirmed locations or contracting recipients are not represented as approved. If a valid objection cannot be resolved, the parties arrange an alternative or orderly termination of the affected service.

Taking account of processing and available information, we assist with data-subject requests, safeguards, impact assessments and required consultation. Customer-data requests are referred to the customer; unauthenticated applicants receive no content. We notify the customer without undue delay of a customer-data breach, supplying known facts, affected data, consequences and measures and updating the investigation.

We provide information needed to demonstrate performance of obligations and assist with authorized audits, including by an independent auditor. Audit arrangements protect other customers’ confidentiality and service security without defeating statutory accountability. Audits provide no unrestricted access to medical contents or secrets.

At termination, the customer chooses return or deletion through a verified instruction, except where law requires retention. Agreed export and removal schedules apply to primary storage and backups. Holds are limited and documented; restoration reapplies revocations and deletions. Non-payment is not a hidden instruction for immediate destruction.