Data Processing

Version 0.3 (draft) · Last updated 31 October 2026

Draft — pending legal review — wording marked for the owner's lawyer to review before real-client use.

Draft description only — not a signed Data Processing Agreement. Practices direct use of their client records; the portal is operated by MindSpring Innovations Inc.; the allocation of controller/processor responsibilities between the practice and the operator is an owner decision pending legal review.

Processing currently includes account access, practice intake, scope and caseload permissions, verified guardian links, purpose-based consent, session and home-practice records, reviewed reports and messages, reminders, protected documents, de-identified AI draft generation and auditing.

Safeguards include tenant and client isolation, mandatory staff two-step sign-in, default-deny record access, checked audited writes, private file access and short-lived links. Only authorized, scoped context is used for AI drafting. No school or family-app record connection is provided.

Retention and deletion instructions, backup restoration, incident-response duties, subprocessor list, processing locations, transfer mechanisms, assistance with rights requests and required agreements must be reviewed before use with real clients. Backup restoration has not been independently demonstrated.

Owner decisions pending legal review: whether a signed processing agreement or sector-specific agreement is offered in each market, and the jurisdictions it covers. This page makes no compliance claim.