Privacy Policy

1. Purpose

1.1 Purpose. The purpose of this Policy is to regulate and inform, in a clear and concise manner, the practices and operations of processing personal data of data subjects, including but not limited to privacy, anonymity, confidentiality, security, purpose, among other principles in accordance with applicable legislation, including the Brazilian General Data Protection Law — LGPD (Law No. 13.709/2018).

1.2 Acceptance and amendments. By using the Platform, the data subject agrees to this Policy ("Acceptance"). Doctor Wise, in turn, may update it at any time. Any amendments and updates will take effect from the date of publication on the app or website.

If the data subject does not express opposition, their tacit consent will be presumed.

2. Controller and Contact

2.1 Controller. Doctor Wise is the controller of the personal data subject to processing operations on the Platform.

2.2 Data Protection Officer/DPO Contact. To exercise rights, make requests, or clarify doubts, please contact: support@doctorwise.com.br.

2.3 Doctor Wise is framed under the terms of ANPD Resolution CD/ANPD No. 2, of January 27, 2022. Nevertheless, it designates Mr. Helder Galvão as its Data Protection Officer, according to the aforementioned channel.

3. Personal Data Collected

We collect only the minimum necessary to operate, improve, and train the Platform, namely:

3.1 Account and identification data. Name, email, specialty/area, and other information provided during registration.

3.2 Usage and interaction data. Queries and messages exchanged in chat, conversation history, date and time of access, event logs, IP address, operating system, device identifiers, and language.

3.3 Payment data. Transactional information (subscribed plan — PLUS or PRO, periodicity monthly or annual, amounts, billing status, dates). We do not store complete credit card data. Processing is done by payment providers who act as processors.

3.4 Cookies and similar technologies. We use cookies and similar technologies for functionality, security, audience measurement, and experience improvement. See Section 8.

3.5 Support and communications data. Content of contacts made with our support (email and in-app channel), including attachments you choose to send.

3.6 Third-party data. We may receive data from partners (e.g., anti-fraud and payment) for transaction validation and security improvement.

4. Legal Bases and Purposes

We process data based on the legal bases of the LGPD, including contract execution, compliance with legal/regulatory obligations, legitimate interest, consent, credit protection, and regular exercise of rights. In particular, we use the data to:

• Provide and operate the Platform (account creation, authentication, delivery of PLUS/PRO plan functionalities, monthly or annual billing via credit card, and automatic renewal according to the Terms of Use);
• Personalize and improve the service (usage analytics, machine learning, testing, fixes, new features);
• Security, fraud prevention, and reliability (monitoring abuse, violation attempts, and incidents);
• Essential communications (operational notices, transactional messages, and changes to terms/policies);
• Support (assistance with requests and questions);
• Research and statistics with de-identified and/or anonymized data for continuous improvement of models and Platform performance;
• Compliance with legal obligations (billing, accounting, responses to authorities, limitation periods) and protection of rights.

When necessary, we will request consent (for example, for marketing communications and non-essential cookies). You may revoke it at any time (Section 9).

5. Data Sharing

Occasionally, data may be shared when necessary, and with adequate contractual guarantees, namely:

• Processors: cloud providers, payments (credit card), anti-fraud, email/transactional, analytics, support, and monitoring tools;
• Public authorities: when there is a legal/regulatory obligation or valid order;
• Corporate operations: in case of merger, acquisition, or reorganization, with continuity of the protections of this Policy;

We do not sell personal data.

6. International Transfers

Doctor Wise may transfer data to countries with different levels of protection. We adopt mechanisms provided for in the LGPD (such as contractual clauses and security standards) to ensure an adequate level of protection.

7. Retention and Deletion

Doctor Wise retains personal data for the necessary time to fulfill the described purposes and legal obligations (e.g., tax and limitation periods), fraud prevention, and exercise of rights.

• Account/subscription: data is retained while the account is active and for the additional period required by law after cancellation.
• Conversation history: maintained for service continuity and audit; you may request deletion (subject to legal and technical limitations).
• Security logs: retained for a period compatible with prevention and investigation of incidents.

When there is no legal basis for retention, we will delete or anonymize the personal data in our database.

8. Cookies and Similar Technologies

8.1 Types of cookies.

• Strictly necessary: essential for authentication and website/app functionality;
• Analytics/measurement: help understand usage and performance to improve the experience;
• Preferences: remember user choices (e.g., language).

8.2 Cookie management. The data subject can manage cookies in browser settings and, when available, in app/website preferences. Disabling essential cookies may affect functionalities.

9. Data Subject Rights (LGPD)

The data subject may exercise, at any time, the rights provided for in the LGPD, including: confirmation of processing, access, correction, anonymization, blocking, or deletion, portability, information about sharing, revocation of consent, and review of automated decisions, when applicable.

• How to exercise: send a request to support@doctorwise.com.br or use the support channel in the app;
• Deadlines: we confirm receipt and respond within 15 days, subject to legal requirements and request complexity;
• Identity: we may request additional information to verify your identity and protect your account.

10. Information Security

We adopt reasonable technical and organizational measures to protect personal data (encryption in transit, access controls, audit logs, and secure development practices).

10.1 Incidents. In the event of a security incident that may result in significant risk or damage, Doctor Wise will take all measures to remedy them quickly and efficiently, as well as mitigate their effects in a short period of time and, when required, notify the ANPD and affected data subjects.

10.2 User best practices. Doctor Wise advises data subjects to adopt "strong passwords", enable available security features, and avoid use on untrusted networks and devices.

10.3 Disclaimer. Under the applicable legislation, Doctor Wise is not responsible for any security incidents caused by factors beyond its control, systemic failures, and third-party chain failures.

11. Communications and Preferences

11.1 Essential communications. We will send essential transactional communications (e.g., monthly/annual subscription confirmation, credit card billing, automatic renewal, and contractual changes).

11.2 Marketing. Receipt of promotional communications will depend on the data subject's consent. The data subject, in turn, may unsubscribe, request deletion, and/or exercise their informational self-determination at any time through email links or support.

12. Children and Adolescents

The Platform is not directed to minors under 18 (eighteen) years of age. Doctor Wise does not intentionally collect data from minors. If you believe a minor has provided us with data, please contact us for appropriate removal.

13. Relationship with the Terms of Use

This Policy ratifies and is an integral part of the Platform's Terms of Use. In case of conflict regarding privacy, personal data protection, and contractual conditions, this Policy will prevail on the matter.

For information about plans (PLUS/PRO), monthly/annual billing, cancellation, 7-day free trial, and refunds, please refer to the Terms of Use.

14. Applicable Law and Jurisdiction

This Policy is governed by Brazilian law. The Court of Rio de Janeiro/RJ is elected, except for legal provisions to the contrary.