Data Processing Agreement

The practice is the data controller and decides why and how patient data is processed. Lumina acts solely as the data processor and processes data only on the practice's documented instructions, which include use of the software's features.

Data processed includes patient identity and contact details, appointment records, clinical treatment and medication notes, invoices, payments and staff account details.

Processing is limited to providing practice-management services: scheduling, patient records, treatment plans, inventory, billing and reporting. Processing continues for as long as the practice maintains an active workspace.

Lumina applies technical and organisational measures appropriate to health data: database level workspace isolation so no practice can access another practice's records, role and permission based staff access, encryption in transit (TLS) and at rest (AES-256), authenticated access with per-user accounts, and authorship stamping on clinical and financial records.

Personnel authorised to process data are bound by confidentiality obligations. Lumina does not sell, share or use patient data for advertising or model training.

Lumina uses infrastructure sub-processors (cloud hosting, managed database and content delivery) under written terms at least as protective as this agreement. Lumina remains responsible for their performance and will give notice of material changes.

Where data is hosted or backed up outside Indonesia or Malaysia, Lumina ensures the receiving jurisdiction provides an adequate level of protection or applies equivalent contractual safeguards, consistent with Article 56 of UU PDP and Section 129 of the PDPA.

Lumina assists the practice in responding to patient requests for access, correction, deletion or portability, and in carrying out data protection impact assessments, taking into account the nature of processing and the information available to Lumina.

Lumina will notify the practice without undue delay and in any case within 72 hours of becoming aware of a personal data breach affecting the practice's data, including the nature of the breach, likely consequences and remediation steps taken.

On termination the practice may export its data. Lumina will delete or return remaining personal data within 90 days, except where retention is required by law.

Lumina maintains records of processing activities and will make available information reasonably necessary to demonstrate compliance with this agreement.

The practice remains responsible for its own regulatory duties as a healthcare provider, including medical record retention rules and, in Indonesia, any applicable electronic medical record reporting obligations. Lumina provides the software; it does not assume the practice's licensing or reporting duties.

This agreement is accepted electronically when an authorised representative of the practice ticks the acceptance box during registration. The acceptance timestamp, version and account used are recorded and form part of this agreement.