Data Processing Agreement
Version 2.1 · effective 2026-11-06
Language. This Agreement was drawn up in French, and the French version was made available to you first at synchromd.com/entente-traitement-renseignements-personnels. By accepting this English version you confirm that you have examined the French version and expressly wish to be bound by the English one. In case of discrepancy, the French version prevails.
This agreement (the "Agreement") forms an integral part of the Terms of Service between Studio KaFe S.E.N.C. ("Synchro") and the Clinic. It is the written contract required by section 18.3 of Quebec's Act respecting the protection of personal information in the private sector (the "Act") and, for a Clinic that is a public body, by section 67.2 of the Act respecting Access to documents held by public bodies and the Protection of personal information. Terms defined in the Terms of Service have the same meaning here.
1. Roles
For Client Data, the Clinic is the enterprise or body responsible for the personal information, and Synchro is its service provider. Synchro processes Client Data on the Clinic's behalf, under its documented instructions, which are the Terms of Service, this Agreement and the way the Clinic configures the Service.
2. Purposes
Synchro processes Client Data only to provide the Service (building, publishing and changing the Clinic's team schedule, informing the team, enabling exports), to support the Clinic and to keep the Service secure. Synchro may produce statistics from de-identified, aggregated data that identify neither a person nor the Clinic. Synchro uses Client Data for no other purpose, does not sell it, and does not use it to train artificial intelligence models.
If Synchro believes an instruction from the Clinic breaks the law, it tells the Clinic.
3. People and information covered
| People | Information |
|---|---|
| Users (physicians, nurses, professionals, managers, staff) | Name, email, role, professional type, team, work site, schedule, availability, absences and absence reasons, preferences, constraints written in plain language, survey answers, conversations with the assistant, notifications, administrative logs |
| Team members without an account | Name, role and schedule entered by the Clinic |
An absence reason can reveal health or family information, which makes it sensitive information. The Clinic obtains the person's express consent before entering it, limits its visibility to the roles that need it, and favours the type of absence over its cause. The Service must contain no information about a patient (section 13 of the Terms of Service).
4. Security measures
Synchro maintains security measures proportionate to the sensitivity of Client Data, including:
- encryption in transit (TLS) and encryption of data at rest;
- authentication handled by a specialized provider, with two-factor authentication available to every User;
- separation of each Clinic's Client Data, and roles that limit what each User sees and changes;
- logging of administrative actions (generating, publishing or changing a schedule);
- daily backups kept for 30 days, and periodic restore tests;
- Synchro team access to Client Data limited to support, security and fixing errors.
5. Confidentiality
Synchro team members and subprocessors who have access to Client Data are bound by a confidentiality obligation and access it only to the extent their duties require.
6. Subprocessors
The Clinic authorizes Synchro to use the subprocessors listed on the Subprocessors and hosting page. Synchro enters into a written agreement with each that imposes protection obligations at least equivalent to this Agreement's, and remains responsible to the Clinic for their performance.
Synchro notifies the Administrator by email at least 30 days before adding or replacing a subprocessor that processes Client Data. If the Clinic objects on reasonable data protection grounds, the parties look for a solution in good faith. Failing one, the Clinic may terminate before the subprocessor starts, and prepaid fees for the unused period are refunded.
7. Communication outside Quebec
Client Data is hosted and processed in the United States by the subprocessors listed on the Subprocessors and hosting page, except sign-in data, which the authentication provider keeps in Canada. Synchro assessed the privacy factors of these communications (section 17 of the Act) and entered into a written agreement with each subprocessor. The Clinic takes this communication into account in its own assessment. Hosting in a Canadian region can be discussed with a Clinic whose framework requires it.
8. Confidentiality incidents
Synchro notifies the person the Clinic designated of any confidentiality incident affecting Client Data without delay, and no later than 72 hours after confirming it. The notice describes, to the extent Synchro knows them: the nature of the incident, the information and approximate number of people affected, the measures taken or planned to reduce the risk of injury, and a contact person. Synchro supplements the notice as information becomes available, records the incident in its register and cooperates with the Clinic.
The Clinic, as the responsible party, assesses the risk of serious injury and decides which notices to send to the Commission d'accès à l'information and to the people concerned. Synchro gives it the information needed to do so.
9. Requests from the people concerned
If Synchro receives a request for access, correction, portability, withdrawal of consent or cessation of dissemination concerning Client Data directly, it forwards it to the Clinic within 5 business days and does not answer it itself unless the Clinic instructs it to. The Service's CSV and iCal exports let the Clinic answer most requests itself. Synchro assists it as needed.
10. Verification
Once a year, on request, Synchro answers a reasonable security questionnaire from the Clinic and provides a written report on the measures in section 4. The Clinic may also, once a year and with 30 days' notice, have compliance with this Agreement verified, at its own cost, during business hours, by a person bound by confidentiality and with no access to other clients' data. An additional verification is allowed after a confidentiality incident or at an authority's request.
11. Term, return and deletion
This Agreement applies for as long as Synchro processes Client Data. The Clinic may export its Client Data at any time during the subscription and for 30 days after it ends. Synchro then deletes Client Data, and backups are purged within a further 30 days. Synchro confirms deletion in writing on request. Synchro keeps no Client Data beyond these periods unless the law requires it.
12. Public bodies
When the Clinic is a public body within the meaning of the Act respecting Access to documents held by public bodies and the Protection of personal information, Synchro also undertakes to:
- use the information only to carry out the mandate entrusted to it;
- not keep the information after the mandate ends, subject to section 11;
- take the measures in section 4 to ensure its confidentiality, and have every team member who has access to it sign a confidentiality undertaking;
- notify the body and its person in charge of the protection of personal information without delay of any breach or attempted breach of the confidentiality obligations;
- allow the body and the Commission d'accès à l'information to carry out any verification of that confidentiality.
The body confirms that it holds the authorizations its framework requires, including for hosting the information outside Quebec, and that it has carried out the assessment required by the law that governs it.
13. Liability
Each party's liability under this Agreement is subject to section 22 of the Terms of Service.
14. Precedence
For anything concerning personal information, this Agreement prevails over the Terms of Service.
15. Contact us
Questions about this Agreement: [email protected]. To report a vulnerability: [email protected]. A signed copy can be provided on request.
Version history
- 2.1 (2026-11-06): version number aligned with the Terms of Service. The content of this agreement is unchanged.
- 2.0 (2026-10-18): first publication, alongside version 2.0 of the Terms of Service and the Privacy Policy.