Privacy Notice

Updated on July 31, 2023

This Privacy Notice and the Terms of Use apply exclusively to the platform of Caren.

By registering and using the services, you confirm that you have read and understood the Terms of Use and Privacy Notice applicable to the service and agree to be bound by them.

You may withdraw from consenting to the provisions of this Privacy Notice at any time, simply by notifying Caren by e-mail privacidade@caren.app.

If you withdraw or do not authorize the Privacy Notice, some of the services available on the platform may be unavailable for access. Refusal under the terms related to the Privacy Notice will prevent access to the platform.

OBJECTIVE:

The priority of Caren is to ensure the privacy and security of the information of the data subjects.

Therefore, the main purpose of this Privacy Notice is to define the guidelines adopted by Caren regarding the collection, use, and disclosure of personal information. In other words, our goal is to provide transparency in the use of personal data and protect your privacy, as well as to inform about your rights or ask questions about how your information is being used.

By accepting the Privacy Notice of Caren, the user recognizes and accepts that we can process personal data in accordance with the terms established here, as provided for in Brazilian law, especially in the General Data Protection Law and related laws.

Case a Caren If you modify the terms of this Privacy Notice, you will be duly notified through our official communication channels with the User. Opportunity where you can consent to the new terms or not.

In case of questions or suggestions regarding the platform's Privacy Notice or any other information, you can contact us at privacidade@caren.app, which will be answered during business hours, from Monday to Friday, from 9 a.m. to 6 p.m.

GLOSSARY:

To better understand the document, we will explain to you some of the definitions used in the Notice. Whenever you read the terms described below, whether capitalized or lowercase, plural or singular, with or without bold letters, they should be interpreted as follows:

Personal Data: It is information that can identify a natural person, directly or indirectly. Direct identification occurs when the data itself already identifies the person who is the owner of that data (such as, for example, the C.P.F.). Indirect data, on the other hand, are those that require additional information for identification (for example, home address).

Sensitive Personal Data: They are those about racial or ethnic origin, religious conviction, political opinion, membership in a trade union or organization of a religious, philosophical or political nature, data related to health or sexual life, genetic or biometric data, when linked to a natural person.

LGPD: Acronym that refers to the General Personal Data Protection Act (Law No. 13,709/2018).

Treatment: When any operation is carried out with personal data, such as the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transparency, dissemination or extraction.

Legal Bases: Hypotheses in which LGPD authorizes Caren to use personal data.

Us or our: This term is used when referring to Caren.

You: Any person who accesses our site, as a visitor and/or User, and/or responsible for a legal entity that accesses or performs any type of interaction with the activities or functionalities available on our site.

User: Collaborators or clients who use our service.

SCIENCE AND CONSENT — FREE AND INFORMED:

The patient user declares to be aware that:

Through the platform, you will transmit personal and health information to the professional responsible for the service via videoconference;

The care of patients under 18 years of age, or other people who need representation or assistance, will take place in the form of the Terms of Use and this Privacy Notice with the participation and/or consent, as the case may be, of at least one of the legal guardians and upon the assessment of technical viability by the professional responsible for the service;

It may be necessary, at the discretion of the professional responsible for the care, to carry out complementary tests to assist in the diagnosis;

The health professional responsible for the care may request the patient's physical presence at a health service, even after the teleconsultation, due to the limits of this care support service through information technology;

With the exception of the service provided by Psychologists, the data collected during the teleconsultation will be recorded and stored in a medical record, which will be kept confidential, as required by law;

The teleconsultation may be interrupted, both by the patient and by the health professional;

PERSONAL DATA COLLECTED:

DATA: full name; country; state; city; biological sex; password; professional registration; technical specialty, profile photo, social security number.
PURPOSE: Registration and identification of users on the platform.
LEGAL BASIS: Health Professional: Contract Execution/Patient: Consent.

DATA: weight; height; date of birth; documents and exams uploaded to the platform.
PURPOSE: Provision of the platform and correct functioning of telehealth tools and electronic medical records.
LEGAL BASIS: Health Guardianship.

DATA: e-mail and cell phone.
PURPOSE: Communication.
LEGAL BASIS: Consent.

DATA: IP access log information, date and time.
PURPOSE: Audit, Platform Security.
LEGAL BASIS: Compliance with Legal Obligation.

The personal data collected by the platform has the indicated legal basis. The data subject may revoke this consent at any time. A Caren guarantees that personal data whose consent has been revoked and that are not backed by another legal basis that justifies their retention will be duly deleted.

DATA SHARING:

In order to guarantee the best offer of our products and services, we rely on the collaboration of other companies in our operations. In some circumstances, it is necessary to share data with third parties, as described below:

Suppliers and partners: We rely on the assistance of suppliers and partners who may process personal data, including payment data. Information is shared solely to fulfill the objectives of the services provided. We always carry out a rigorous assessment of our suppliers and partners, establishing contractual obligations for the protection of personal data, in order to minimize risks for the owners.

Public authorities: Your data may be shared with public authorities to comply with current legislation. If a judge or a legally competent authority requires the sharing of certain personal data, for example, for an investigation, we have an obligation to comply with that request. However, we are strongly against any abuse of authority and, if we consider that an order is abusive, we will always defend the privacy of the owners.

DATA STORAGE AND RETENTION:

A Caren stores your data on secure servers and follows its own internal policies for the retention and disposal of personal data, determining the appropriate retention period for each type of personal data collected. This takes into account the nature of the data, the need for collection and the purpose for which it will be processed. Personal data is stored only for the time necessary to fulfill the purposes for which it was collected, unless there is any other valid reason for its retention, such as compliance with legal, regulatory, contractual obligations, among others.

The primary obligation in the processing of patient data lies with the health professional to use the platform as a virtual care tool, however, as a way to collaborate with information security in their role as data operator, Caren informs that electronic medical records will be stored for a period of 20 (twenty) years in accordance with current legislation.

COOKIES:

What are Cookies. A cookie is a piece of information stored locally on the User's computer or device, and which contains information about the User's activities on the Internet.

Cookies Used. Cookies can be used in different ways and modalities. A Caren you can use:

Performance Cookies: this type of cookie collects anonymous information about the way in which Users use the platform, in order to optimize it. The information collected by these cookies never contains personal details from which it is possible to identify you.

Required/ Security Cookies: they are cookies that are absolutely essential for the proper functioning of the site. These cookies guarantee basic functionality and security features of the site, anonymously.

Statistics Cookie: Statistics cookies help platform owners understand how visitors interact with sites, collecting and reporting information anonymously.

Marketing Cookies: Marketing cookies are used to track visitors to websites. The intention is to display advertisements that are relevant and engaging for the individual user and, therefore, more valuable to third-party publishers and advertisers.

Access to Cookies. Access to cookies ends as soon as the User closes the browser. The User is given the possibility to accept or refuse cookies.

Consent for the Use of Cookies. Acceptance by the User is required, before starting the section, for Cookies to be used.

Option without Cookies. The owner may choose to refuse the use of cookies. If the User chooses not to accept them, their access to most of the information available on the platform will not be compromised. However, the owner may not be able to fully use the services offered.

RIGHTS OF THE OWNERS:

In accordance with the legislation, you have rights related to your data that is processed by us. Below, we provide a list of those rights, along with information on how to exercise them. Upon receiving your request, we may request verification of your identity before we can fulfill your request. This verification may include requesting additional data to ensure your correct identification. In addition, if you appoint a third party to make requests on your behalf, that third party must present a document that proves your authorization, such as a power of attorney signed by you.

To exercise any of these rights, you can contact us at the email provided.

Confirmation and Access: It allows you to verify that we treat your personal data and, if so, request a copy of the data we have about you.

Correction: It allows you to request the correction of any personal data of yours that is incomplete, inaccurate, or out of date.

Anonymization, blocking or deletion: It allows you to request that your data be anonymized (so that they can no longer be related to you and, therefore, cease to be personal data), temporarily blocked (suspending the processing of the data) or deleted (erasing all your data irreversibly), except in the cases provided by law.

Portability: You have the right to request, upon an express request, that your personal data be provided to you or to a third party of your choice, in a structured and interoperable format, for the purpose of transfer to another provider, provided that this does not violate the intellectual property or trade secrets of Caren.

Information about sharing: You have the right to know which public and private entities we share your data. If you have questions or would like more details, you have the right to request this information.

Information about the possibility of not consenting: It allows you to have clear and complete information about the possibility and consequences of not providing consent. Your consent, when necessary, must be free and informed. Therefore, whenever we request your consent, you will be free to deny it, although in these cases, we may need to limit our services to you.

Revocation of consent: You have the right to revoke your consent in relation to processing activities that are based on consent. However, this will not affect the legality of any treatment carried out previously. If you revoke your consent, we may not be able to provide certain communications or services, but we will let you know when this occurs.

Opposition: The law allows the processing of personal data even without your consent. However, if you disagree with this treatment, you can object to it in certain cases, requesting its interruption.

GENERAL INFORMATION:

The Platform acts in accordance with Brazilian legislation, complying, including and especially, with the terms of Law No. 12,965/2014 (the Civil Framework of the Internet), Law No. 13,709/2018 (General Data Protection Law), Law No. 13,787/2018 (Electronic Record Law, CFM Resolution No. 2,314/2022 (regulation of Telemedicine), CFM Resolution No. 2,217/2018 (Code of Medical Ethics), CFP Resolution No. 11/2018 (Provision of Psychological Services Performed by Information Technology Means), CFP Resolution No. 10/2005 (Psychologist's Code of Professional Ethics), and other laws that may be applied.

If you have any questions, comments or requests related to your personal data, we ask that you contact our Data Processor responsible for the processing of personal data, who can be contacted by e-mail: privacidade@caren.app.

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