Privacy Policy
and Data Protection

Last updated: March 12, 2025

Data Health Flow (DHF) presents its Privacy and Data Protection Policy, reflecting our commitment to transparency, security and legal compliance in the handling of personal information. This document sets out the principles and practices that govern the collection, use, storage and sharing of data in our operations, especially considering our integration with Meta's APIs for healthcare solutions.

Introduction and Our Commitment

DHF is a startup dedicated to transforming healthcare through innovative technology solutions focused on accessibility and social impact. Our mission is to democratize access to quality healthcare, using artificial intelligence in an ethical and effective way to optimize public health processes, reduce appointment no-shows, shorten waiting lines and provide transparency through structured data for public managers. In drafting this Privacy Policy, we recognize the critical importance of protecting personal information, especially in a sector as sensitive as healthcare. We understand that trust is fundamental to the relationships we build with patients, healthcare professionals, public managers and institutional partners. This policy demonstrates our commitment to protecting personal data, processed in compliance with the LGPD (Brazil's General Data Protection Law - Law No. 13,709/2018) and other applicable regulations.

Key Definitions

Personal Data
Any information relating to an identified or identifiable natural person, such as name, CPF (Brazilian taxpayer ID), address, email, phone number, among others.
Sensitive Personal Data
A special category of data that includes information on racial or ethnic origin, religious belief, political opinion, trade union membership, data concerning health or sex life, and genetic or biometric data.
Data Processing
Any operation performed on personal data, including collection, storage, use, sharing, modification and deletion.
Data Subject
The natural person to whom the processed personal data relates.
Controller
The entity that determines the purposes and means of processing personal data - in this case, DHF.
Processor
A natural or legal person that processes personal data on behalf of the controller.
Consent
A free, informed and unambiguous expression by which the data subject agrees to the processing of their personal data for a specific purpose.

Our Data Collection

Types of Data We Collect

Identification Data
Full name, identification documents (CPF, RG), date of birth, address, contact information (phone, email), professional role.
Health Data
Medical history, information about appointments and procedures, scheduling, medications, exam results and other information relevant to healthcare management.
Usage and Interaction Data
Information about how you use our services, including access logs, interactions with platforms and communications carried out through our technology solutions.
Technical Data
IP address, device type, operating system, browser, language settings, cookie data and similar technologies.

How We Collect Your Data

Directly From You
When you register on our platforms, fill out forms, send messages or take part in surveys and health programs.
Automatically
When you use our technology solutions, we collect data about your device and your interactions with our services.
Through Authorized Third Parties
We may receive data from healthcare partners, such as hospitals, clinics, laboratories, healthcare professionals and public agencies.
Via WhatsApp Business API
When you interact with our services via WhatsApp, we collect data related to those interactions, as permitted by Meta's policies and with your consent.

Purposes of Processing

Provision of Healthcare Services
Appointment management, patient follow-up, no-show reduction, waiting-list optimization and easier communication between patients, professionals and institutions.
Development and Improvement
Continuous improvement of our technology platforms, pattern analysis and development of new features.
Public Management
Creation of dashboards and reports with structured data to help public managers make decisions about health policy.
Communication with Users
Sending notifications, appointment reminders, information about medical procedures and other relevant communications.
Research and Statistical Analysis
Use of aggregated or anonymized data for research and statistical analysis in the field of public health.
Compliance with Legal Obligations
Meeting regulatory requirements of the healthcare sector, tax obligations and responding to requests from competent authorities.

Data Sharing

Healthcare Professionals and Institutions
We share the information necessary for the provision of healthcare services, care coordination and continuity of care.
Public Bodies and Regulators
When required by law, we share data with government agencies, health authorities and other regulatory entities.
Technology Partners
Service providers that help us develop, maintain and operate our platforms, including hosting, data analysis and security.
Meta Platform (WhatsApp Business API)
We share the data necessary to use the WhatsApp Business API, in accordance with the policies and guidelines set by Meta.
Research Partners
In some cases, we share anonymized or aggregated data with research institutions and universities for scientific and statistical purposes.

Your Rights as a Data Subject

Confirmation and Access
Request confirmation that processing exists and access your personal data.
Correction
Correct incomplete, inaccurate or outdated data.
Anonymization, Blocking or Deletion
Request the anonymization or deletion of unnecessary data or data processed in violation of the LGPD.
Portability
Transfer your data to another service or product provider.
Withdrawal of Consent
Withdraw your consent at any time, without affecting the lawfulness of processing carried out previously.
Information on Sharing
Know which public and private entities we share your data with.
Non-Discrimination
We guarantee that you will not be discriminated against for exercising your rights under the LGPD.

Data Security and Protection

Encryption
We apply encryption to data in transit and at rest, protecting information against interception and unauthorized access.
Access Controls
We restrict access to personal data to authorized staff and systems only, based on the principle of least privilege.
Continuous Monitoring
We identify and respond to security incidents quickly and effectively.
Regular Audits
We periodically assess our security measures to identify and fix vulnerabilities.
Staff Training
All employees are trained in data protection and information security best practices.

Data Retention

Health Data
Kept for 20 years or more, as required by applicable health and sanitary legislation.
Registration Data
Kept for the period the services are used and for an additional period as required by legal obligations.
Usage and Technical Data
Kept for between 6 months and 2 years, depending on the purpose and legal requirements.
After the Retention Period
Data is securely and irretrievably deleted, anonymized or archived under restricted access, as applicable.

Use of the WhatsApp Business API

DHF uses Meta's WhatsApp Business API to communicate with patients and managers, in compliance with the platform's policies. All message sending requires the recipient's prior consent (opt-in), and we only use templates approved by Meta. Types of messages sent: appointment confirmations, appointment reminders, care results, health guidance, replies to requests and administrative notices. DHF does NOT send intimidating messages, prohibited content, spam or unsolicited messages. Users may request removal from the communication channel at any time.

How to Exercise Your Rights

You can exercise your rights through the following channels. We will respond within 15 days, as provided by the LGPD.

Email: datahealthflow@gmail.com

Form: datahealthflow.com/en#contato

Address: Av. José Bernardino, 97, Vila Cabral, Campina Grande, PB, Brazil

Our Ongoing Commitment

Privacy protection is a pillar of DHF. We recognize the sensitivity of health information and take responsibility for protecting it as we transform public health with technology. Our approach is based on transparency, security and empowerment of the data subject, going beyond legal requirements to reflect our ethical commitment.