Hollowmere Care Group - Data Processing Agreement (signed)
Documentexecuted Hollowmere Care Group: documents · dpa · executed · 2026-03-27
Executed Data Processing Agreement under the Master Subscription Agreement and Order Form. Hollowmere Care Group is controller and BB-Demo processor. The data stays in the customer's own Snowflake account. It states no price, availability or response-time figures.
What it says
What this says
Current to 11 Oct 26Executed Data Processing Agreement under the Master Subscription Agreement and Order Form. Hollowmere Care Group is controller and BB-Demo processor. The data stays in the customer's own Snowflake account. It states no price, availability or response-time figures.
What it is: an executed DPA, signed 27 Mar 2026, that applies "whenever BB-Demo processes personal data on behalf of the Customer". Matteo Ricci signed for BB-Demo; the customer signatory is shown only as "Authorised signatory", so the name and role are not stated.
Commits: BB-Demo processes only on documented instructions, keeps access to named staff, and will tell the Customer of a breach "without undue delay". It will not transfer data outside the United Kingdom without a lawful mechanism and written agreement.
Unusual: the records may contain health information, flagged as special category data. Sub-processors are under general authorisation with prior notice and a right to object.
Not settled: no service levels, price, fees or connector dates appear here. The breach clause sets no hour limit, and the liability cap sits in the Master Subscription Agreement, which is not in this document.
As found in this document
Current to 9 Oct 26- Date signed27 Mar 2026Source: object_read:doc_023_006
- Date start27 Mar 2026Source: object_read:doc_023_006
- Processing instructionsBB-Demo will process Customer Personal Data only on the Customer's documented instructionsBB-Demo will process Customer Personal Data only on the Customer's documented instructions · Source: object_read:doc_023_006
- Location of processingBB-Demo will not move Customer Personal Data out of the Brain Environment except as the Customer instructs in writingBB-Demo will not move Customer Personal Data out of the Brain Environment except as the Customer instructs in writing · Source: object_read:doc_023_006
- International transfersBB-Demo will not transfer Customer Personal Data outside the United Kingdom unless a lawful transfer mechanism is in place and the Customer has agreed in writingBB-Demo will not transfer Customer Personal Data outside the United Kingdom unless a lawful transfer mechanism is in place and the Customer has agreed in writing · Source: object_read:doc_023_006
- Personal data breachesBB-Demo will tell the Customer without undue delay after becoming aware of a personal data breachBB-Demo will tell the Customer without undue delay after becoming aware of a personal data breach · Source: object_read:doc_023_006
- Sub-processorsBB-Demo will keep a current list and tell the Customer before adding or replacing a sub-processorBB-Demo will keep a current list and tell the Customer before adding or replacing a sub-processor · Source: object_read:doc_023_006
- Return and deletionOn termination BB-Demo will remove its access and delete any copies of Customer Personal Data it holds outside the Brain EnvironmentOn termination BB-Demo will remove its access and delete any copies of Customer Personal Data it holds outside the Brain Environment · Source: object_read:doc_023_006
- Termtakes effect on signature and continues for as long as BB-Demo processes Customer Personal Data on the Customer's behalftakes effect on signature and continues for as long as BB-Demo processes Customer Personal Data on the Customer's behalf · Source: object_read:doc_023_006
The document
Body
Hollowmere Care Group - Data Processing Agreement (signed)
Status: Executed
Signed on: 27 Mar 2026
This Data Processing Agreement forms part of the Master Subscription Agreement and the Order Form between the parties named below, and applies whenever BB-Demo processes personal data on behalf of the Customer.
Parties
| Role | Party |
|---|---|
| Controller (the Customer) | Hollowmere Care Group, Leeds, United Kingdom |
| Processor (the Supplier) | BB-Demo, London, United Kingdom |
Definitions
- Data Protection Law means the UK GDPR, the Data Protection Act 2018 and any law that replaces or amends them.
- Customer Personal Data means personal data processed by BB-Demo on the Customer's behalf in connection with the company brain.
- Brain Environment means the Customer's own Snowflake account in which BB-Demo builds and runs the company brain.
- Connected Systems means the Customer systems connected to the brain, such as the CRM, the helpdesk, the accounting system and shared document stores.
Subject matter and purpose
Read the whole document (5,860 characters)
BB-Demo processes Customer Personal Data only to provide the company brain: to index, search and answer questions over the Customer's data from Connected Systems, including family and commissioner contact, incident records and fee invoices for each home.
Roles of the parties
The Customer is the controller and BB-Demo is the processor. The Customer is responsible for having a lawful basis for the processing and for the instructions it gives.
Categories of data and data subjects
- Data subjects: residents and their families, commissioners, staff and contractors of the Customer, and other individuals whose data sits in Connected Systems.
- Data categories: contact details, correspondence, incident and care-related records held in Connected Systems, and invoice and payment information.
- Special category data: the Customer's records may contain health information. BB-Demo treats all Customer Personal Data with the same high level of care and applies the safeguards below.
Instructions
BB-Demo will process Customer Personal Data only on the Customer's documented instructions, which are the Master Subscription Agreement, the Order Form, this Agreement and any written configuration the Customer approves. If BB-Demo believes an instruction breaches Data Protection Law, it will tell the Customer promptly.
Location of processing
The company brain runs inside the Brain Environment, which the Customer controls. BB-Demo staff access it only to deliver implementation, support and maintenance. BB-Demo will not move Customer Personal Data out of the Brain Environment except as the Customer instructs in writing.
Confidentiality
BB-Demo will make sure that everyone authorised to process Customer Personal Data is bound by a duty of confidentiality and receives appropriate data protection training.
Security
BB-Demo will keep appropriate technical and organisational measures in place, including:
- access limited to named staff with a need to know, with access reviewed regularly;
- strong authentication for all access to the Brain Environment;
- encryption of data in transit and at rest, using the controls of the Customer's Snowflake account;
- logging of administrative access, with logs available to the Customer on request;
- a documented process for security incidents and for restoring service.
Sub-processors
The Customer gives general authorisation for BB-Demo to use sub-processors that are bound by written terms no less protective than this Agreement. BB-Demo will keep a current list and tell the Customer before adding or replacing a sub-processor, so that the Customer can object on reasonable grounds. BB-Demo remains responsible for its sub-processors.
International transfers
BB-Demo will not transfer Customer Personal Data outside the United Kingdom unless a lawful transfer mechanism is in place and the Customer has agreed in writing.
Assistance to the Customer
Taking account of the nature of the processing, BB-Demo will help the Customer to:
- respond to requests from data subjects exercising their rights;
- carry out data protection impact assessments and consult the regulator where required;
- meet its security and breach notification obligations.
Personal data breaches
BB-Demo will tell the Customer without undue delay after becoming aware of a personal data breach affecting Customer Personal Data, and will give the information the Customer reasonably needs to meet its own notification duties. BB-Demo will not hide or delay an incident from the Customer's security team.
Audit
BB-Demo will make available the information needed to show compliance with this Agreement and will allow audits by the Customer or a auditor it appoints, on reasonable notice, during business hours and subject to confidentiality.
Return and deletion
Because the data stays in the Customer's Snowflake account, the Customer keeps its data at the end of the services. On termination BB-Demo will remove its access and delete any copies of Customer Personal Data it holds outside the Brain Environment, and will confirm this in writing on request.
Liability and precedence
Liability under this Agreement is subject to the limits in the Master Subscription Agreement. If this Agreement conflicts with the Master Subscription Agreement on the processing of personal data, this Agreement prevails.
Term
This Agreement takes effect on signature and continues for as long as BB-Demo processes Customer Personal Data on the Customer's behalf.
Signatures
| For Hollowmere Care Group | For BB-Demo | |
|---|---|---|
| Name | Authorised signatory | Matteo Ricci |
| Title | Authorised signatory of Hollowmere Care Group | Account Executive |
| Date | 27 Mar 2026 | 27 Mar 2026 |
Unusual terms
Current to 9 Oct 26- Special category health data may be present
- General authorisation for sub-processors with objection right
- Breach notice without a stated hour limit
- Customer signatory not named