Privacy notice (practice owners, staff and agency users)
Agent-reviewed draft. Not legal advice and not in force until signed. A professional legal review is recommended once revenue allows.
This notice explains how Turstone Ltd ("we"), the maker of Chairfill, as controller, uses the personal data of people who sign in to the app: practice owners, practice staff and people at agencies. Contact: privacy@turstone.com.
The account and sign-in data of owners, staff and agency users is ours as controller and is not covered by the practice's data processing agreement; the practice is the controller only of its audit-log entries about its own staff. Patients are not covered here. For patients, the practice is the controller and its own patient notice applies (a paste-ready text is in notice for patients); we act only on the practice's instructions.
What we collect and why
| Data | Why | Basis |
|---|---|---|
| Your sign-in identity (email, name) and the role you hold at a practice | To sign you in and decide what you may do | Contract |
| Sign-in events and security logs, including your IP address on the app host, kept 30 days | To keep the service secure | Legitimate interest |
A strictly necessary session cookie at auth.turstone.com set by our sign-in provider |
To keep you signed in; no tracking or advertising cookies | Strictly necessary |
| The owner's reminder email, only if the owner adds and verifies it | Used only for the reminders the owner turned on (for example, upload reminders), nothing else | Consent |
| What you type in the contact form on turstone.com (name, practice, email, phone, message) | To answer you. It is emailed to us through Amazon SES and not stored in our database | Legitimate interest |
| Billing contact and invoice details, via Stripe | To charge and invoice the practice. We never see card numbers | Contract and tax law |
Where agency users' data comes from (Article 14). For people at an agency, we receive the name and email from the practice's owner, who invites them, and from the agency user's own sign-in. Agencies act for the practice. An agency user's access exists only while the practice's owner has approved it, and we log what they do.
Our legitimate interest in security logs is keeping the service and every practice's data safe: detecting misuse and investigating incidents. The logs are short-lived, and you may object.
Providing the data. Your sign-in identity and role are needed to give you an account, so without them we cannot provide the service. The owner's reminder email and the notices are optional. We make no automated decisions about you, and we do no profiling.
Data protection officer. We have not appointed one; write to privacy@turstone.com.
Who we share it with
Our sub-processors listed on the public sub-processor page: Amazon Web Services (hosting, email), Auth0 (sign-in), Stripe (billing). Twilio and, only if a practice you work for uses it, WhatsApp Ireland Limited (which passes data to WhatsApp LLC and Meta Platforms, Inc. in the United States) handle patients' messages for the practice, not your account data. Patients' data is the practice's, not ours. We do not sell your data.
Where it is stored
In the EU (Ireland, with backups in Frankfurt). Where a provider has a US parent, we use Standard Contractual Clauses and transfer assessments.
How long
Account data while the account exists; sessions 12 hours at most; logs 30 days; notices 90 days; billing records as long as tax law requires.
Your rights
Access, rectification, erasure, restriction, portability and objection, and withdrawing consent at any time. Write to privacy@turstone.com. You can complain to the Data Protection Commission (dataprotection.ie) in Ireland.