Data Processing Agreement

Data Processing Agreement for Stenoly

Last updated · Last updated: 06.06.2026
01

Parties and Purpose

This data processing agreement ("Agreement") is entered into between:

  • Data Controller: The legal entity using Stenoly for processing personal data.
  • Data Processor: Stenoly AS ("Stenoly"), which provides the Stenoly service.

The purpose of the Agreement is to regulate the processing of personal data in accordance with GDPR, where Stenoly acts as a data processor and the Data Controller is responsible for the basis for processing.

02

Definitions

  • Personal Data: Information that can identify a natural person, directly or indirectly.
  • Processing: Any operation performed on personal data.
  • Data Processor: Stenoly, which processes personal data on behalf of the Data Controller.
03

Scope and Instructions for Processing

Instructions

Stenoly shall only process personal data according to instructions from the Data Controller. The responsibility for establishing a legal basis for processing rests with the Data Controller.

Scope and Categories

  • Purpose: Documentation of medical records during consultations.
  • Categories of data subjects: Patients, clients, customers, or others consulted by the Data Controller.
  • Types of personal data: Will depend on what the Data Controller shares with Stenoly. Stenoly encourages the Data Controller to minimize the amount of data Stenoly receives. The service can be used entirely without sharing personal data with Stenoly.
04

Confidentiality

Stenoly commits to confidentiality, and all employees and subprocessors who process data are bound by confidentiality. The information shall not be shared with third parties without express permission from the Data Controller.

05

Security Measures

Technical Measures

Stenoly shall implement appropriate technical and organizational measures to protect personal data, including:

  • Encryption of data during storage and transfer.
  • Secure servers in the EU/EEA (European cloud platforms).
  • Access controls to limit access to authorized persons.

Processing and Storage

Stenoly processes personal data only in accordance with the Data Controller s instructions, and data is stored on secure servers in compliance with GDPR.

06

Use of Subprocessors

Stenoly may engage subprocessors to process personal data. Any subprocessor is bound by the same data protection obligations set out in this data processing agreement. A current list of Stenoly's subprocessors is published in our Privacy Policy and is also available upon request. Stenoly will inform the Data Controller before adding or replacing a subprocessor and will give the Data Controller a reasonable opportunity to object.

Infrastructure & hosting

NeonEU · Frankfurt

Database hosting.

Accounts, consultations, notes, billing.

VercelEU · Stockholm

Application hosting and file uploads.

Website traffic; uploaded documents.

AI processing of clinical data

Google Cloud (Vertex AI)EU (multi-region)

AI note generation.

Consultation transcripts and notes.

Microsoft AzureEU · Sweden

AI dictation and note processing.

Clinical text.

SpeechmaticsEU/EEA

Speech-to-text transcription.

Consultation audio, transcribed and not stored.

Mistral AIEU · France

Document text extraction.

Uploaded documents.

Authentication

SignicatEU/EEA

Authentication (BankID, Buypass, email).

Identity and login verification.

EHR integration

PridokNorway

Delivery of finished notes to the EHR.

Notes sent to the EHR.

Business & billing

HubSpotEU · Ireland

Customer relationship management.

Account contact details. No clinical data.

StripeEU / global

Subscription billing.

Billing details. No clinical data.

Google WorkspaceEU/EEA

Business email.

Email correspondence.

Customer support

ChatwootEU (self-hosted)

Customer support chat.

Support messages and contact details.

Website analytics

These run on our marketing website only and never receive patient or clinical data.

Google Analytics & Tag ManagerWebsite traffic analytics and tag management.
Meta PixelMarketing campaign measurement.

All sub-processors that handle personal or clinical data process it within the EU/EEA under signed data processing agreements.

07

Access, Rectification and Erasure

Stenoly shall assist the Data Controller in fulfilling the rights of data subjects. The responsibility for responding to such requests rests with the Data Controller.

08

Handling Security Breaches

Notification

Stenoly shall notify the Data Controller without undue delay, and in any event within 72 hours of becoming aware of a personal data breach, in line with GDPR Article 33.

Notification Content

The notification shall contain:

  • Description of the breach
  • Potential consequences
  • Stenoly s measures to handle the breach
  • Recommendations for notifying affected parties and relevant data protection authorities
09

Data Transfer Outside EU/EEA

Stenoly shall not transfer personal data outside the EU/EEA without written consent from the Data Controller. Any transfers shall occur in accordance with GDPR.

10

Availability and Uptime

Stenoly shall strive for high availability but does not guarantee uninterrupted uptime. Stenoly is not responsible for losses resulting from unavailability, and maintenance may be performed without prior notice.

11

Return and Deletion of Data

Upon termination of the Agreement, Stenoly shall delete or return personal data according to the Data Controller s wishes. Confirmation of deletion can be provided upon request.

12

Data Controller Obligations

The Data Controller shall:

  • Ensure that there is a legal basis for processing.
  • Inform data subjects about how their data is processed.
  • Provide Stenoly with instructions regarding processing.
  • Execute any instructions regarding access, rectification, and deletion.
13

Liability and Compensation

Stenoly is not responsible for the Data Controller s obligations under GDPR. In all cases, Stenoly is only liable for damages resulting from breach of the agreement or GDPR; and limited upward to the amount the Data Controller has paid for the Service in the last 12 months. The parties commit to cooperate in case of claims for compensation.

14

Termination

The Agreement applies as long as Stenoly processes personal data for the Data Controller. Upon termination, all data shall be returned or deleted.

15

Governing Law and Dispute Resolution

This agreement is governed by Norwegian law, and disputes shall be resolved by Oslo District Court.