Data Processing Agreement — Sensitive-Category Services

This Data Processing Agreement ("Agreement") applies when you offer a service in a category Kinjie has flagged as involving sensitive personal data (for example, a service where clients may share health-related information as part of an intake or consultation). By offering such a service, you agree to the following, in addition to the Kinjie Terms and Conditions:

1. Purpose limitation

You will only use sensitive information a client shares with you through Kinjie to deliver the specific booked service, and for no other purpose (including marketing, profiling, or sharing with a third party) without the client's separate, explicit consent.

2. Your role

For sensitive data you collect or receive in connection with a booking, you act as an independent data controller under the General Data Protection Regulation and Malta's Data Protection Act (Cap. 586). You are responsible for your own lawful basis, security measures, and record-keeping for that data, the same as if a client had given it to you directly, outside Kinjie.

3. Security and confidentiality

You will keep any sensitive information you receive confidential and take reasonable technical and organisational measures to protect it against unauthorised access, loss, or disclosure.

4. Retention

You will not retain sensitive information for longer than you need it to deliver the booked service and meet any of your own legal obligations (for example, professional record-keeping requirements for your trade).

5. Data breach notification

If sensitive information you received through a Kinjie booking is lost, disclosed without authorisation, or otherwise compromised, you will notify us at [email protected] without undue delay after becoming aware, so we can assess our own notification obligations under Cap. 586.

6. Kinjie's role

Kinjie's role is limited to facilitating the booking through which this information is shared. Kinjie does not review, control, or take responsibility for how you handle sensitive information once you receive it, beyond the commitments in this Agreement.

7. Suspending this category

If we reasonably believe you have mishandled sensitive client data or breached this Agreement, we may suspend your ability to offer services in data-sensitive categories, in addition to any other rights we have under the Terms and Conditions.

8. Governing language

Where this Agreement is made available in more than one language, the English version governs if there is any conflict or inconsistency between versions.