Sub-processors and data recipients

Sub-processor

A provider processing clinic-controlled personal data for GLØDI to deliver the platform. GLØDI enters into an Article 28 agreement and remains responsible to the clinic for the provider's performance.

Independent controller

A recipient determining its own purposes or statutory processing, such as regulated payment verification. The recipient's privacy terms apply to that processing.

Optional integration

A service the clinic chooses to activate or connect. Data is transferred only when the clinic selects the integration and has the required agreement or legal basis.

Google Cloud

Application hosting, database, file storage, backups, and email infrastructure. The core application and database run in the Stockholm region and platform files are stored in Finland. Limited support and security access may occur from other countries under a valid transfer basis.

Cloudflare

DNS, network security, abuse protection, and delivery of public content. Processes IP address, request data, and limited technical identifiers through a global network.

Sentry

Error and performance monitoring. Processes technical events and limited account or request identifiers. GLØDI must filter clinical text and other unnecessary sensitive data.

Twilio

SMS delivery and status reporting. Processes phone number, message content, and delivery data. Processing may take place outside the EEA under a valid transfer basis.

Google Cloud Speech-to-Text

Optional transcription when the clinic activates voice-assisted clinical records. Audio and transcription may contain health data and are processed only to provide the feature.

OpenAI

Active provider for optional AI features such as clinical-record assistance and text suggestions. Inputs may contain health data. API content is not used for general model training unless the clinic expressly opts into a separate arrangement. Temporary provider retention and processing location follow the business and data-processing agreements in force.

Anthropic

Supported alternative an administrator may select for certain AI features. It is used only after configuration and under equivalent contractual, security, and transfer requirements.

Stripe and Vipps MobilePay

Payments, customer authentication, fraud controls, refunds, and settlement. They may be independent controllers for regulated payment processing and processors for limited technical services. They do not receive clinical records.

Fiken and Tripletex

Optional accounting integrations connected by the clinic. Sales, invoice, and settlement data is transferred under the clinic's choice and access authorisation.

Bring/Posten and other selected carriers

Name, contact, and delivery details are transferred where shipping is selected. The carrier also processes data under its own transport and legal obligations.

Advance notice

GLØDI notifies clinics at least 30 days before a new or replacement sub-processor receives clinic-controlled data. A shorter period is used only where required by a security, legal, or provider incident.

Reasoned objection

The clinic may object within the notice period on documented privacy or security grounds. The parties first seek risk-reducing measures or a reasonable alternative. If none is available, the clinic may terminate the affected feature without future charge.

Transfers outside the EEA

Access or processing outside the EEA takes place only under a valid GDPR Chapter V mechanism, such as an adequacy decision or Standard Contractual Clauses, plus required supplementary measures. A storage region alone is not decisive if remote access may occur from a third country.