Subprocessors
Provider roles
A subprocessor is a provider that processes clinic personal data on FriendlyCrm’s instructions while we act as the clinic’s processor. Providers serving our website or our own business activities have a different role and are not automatically subprocessors of clinic records.
Current website and planned clinic providers
The frontend is hosted on Cloudflare Pages. The clinic service is not yet in production. The overview below distinguishes existing website hosting from planned infrastructure; planned entries do not mean that a supplier contract, region or live deployment has been verified.
Cloudflare Pages
- Purpose
- Website hosting and delivery
- Data involved
- Website request metadata, such as IP address and requested URL
- Processing location
- Global delivery network; not limited to the EU
- Status
- Frontend deployed
Fly.io
- Purpose
- Clinic application and database hosting
- Data involved
- Clinic records, staff accounts and operational data
- Processing location
- EU region planned; final locations and access arrangements unconfirmed
- Status
- Planned; final selection pending
Cloudflare R2
- Purpose
- Clinic file storage
- Data involved
- Files and attachments uploaded by clinic staff
- Processing location
- EU-jurisdiction bucket planned; configuration unconfirmed
- Status
- Planned
Scaleway Transactional Email
- Purpose
- Transactional email delivery
- Data involved
- Recipient addresses, message contents and delivery metadata
- Processing location
- EU service planned; final processing arrangements unconfirmed
- Status
- Planned in the production setup; not yet confirmed
Data processing agreements
FriendlyCrm is responsible for maintaining its provider register and arranging the required agreements with its subprocessors. Before processing live clinic data, the agreement between the clinic and FriendlyCrm must identify the relevant processing entities, services, countries and safeguards and cover security, confidentiality, assistance, retention, and return or deletion of data.
Authorization and changes
Engaging clinic subprocessors requires the clinic’s prior specific or general written authorization where GDPR applies. Under general authorization, intended additions or replacements must be actively notified to the clinic with an opportunity to object under the data processing agreement. Updating this page alone does not replace that notification.
Payments and other providers
Paddle is the planned merchant of record for subscriptions and handles buyer information under its own privacy notice. Clinic medical notes and pet-owner records are not needed for subscription billing. Optional cache or monitoring providers are not represented here as active; any provider that will process clinic personal data must be verified and added before use.