Privacy Notice

1. Who processes the data

Liora Health (legal name: JG CONSULTORIA EM TECNOLOGIA DA INFORMACAO LTDA; CNPJ: 48.185.770/0001-82) is the controller of the data of the healthcare professionals who sign up for the platform. For the data of patients seen with the support of the platform, the controller is the professional or the clinic responsible for the care; Liora Health acts as processor, handling this data only according to the professional's instructions and to provide the contracted service, under the data processing agreement that is part of the Terms of Use. Contact: devaocubome@gmail.com.

2. Data we collect

From the healthcare professional: name, specialty, professional registration number (CRM/CRP), email address, WhatsApp number, practice address, consultation fee, accepted health plans, office hours, the password (stored only as a bcrypt hash, never in readable text), the date these documents were accepted and the subscription data. Card details are entered directly with the payment provider and are not stored by Liora Health. From the patient, only when the professional uses the clinical documentation feature: name and phone number registered by the professional, the consultation audio, the transcript, the medical record reviewed by the professional, the record of the consent given in the Free and Informed Consent Form (TCLE) and the patient's preferences regarding the use of artificial intelligence, such as a refusal. Consultation data is sensitive personal data concerning health.

3. Purposes and legal bases

Professional data: creating and maintaining the account, providing the contracted service, charging the subscription, sending communications about the service and providing support, based on the performance of the contract (Art. 7º, V), compliance with a legal obligation (Art. 7º, II) and, for improving the platform, legitimate interest (Art. 7º, IX). Patient data: recording the consultation, transcribing it and generating a draft medical record that the professional reviews and signs, based on the patient's specific and highlighted consent recorded in the TCLE (Art. 11, I), and keeping the medical record for the period required by professional regulations (Art. 11, II, a). The AI-generated draft is not an automated decision: the professional reviews, corrects and signs the final document.

4. Who we share data with

We use the providers in the table below, which process data on our behalf (as sub-processors, in the case of patients' data) only for the purposes shown. The language models are accessed through OpenRouter and receive the consultation text with the patient's name, CPF, phone number and email replaced with placeholders when automatically recognized; audio, by its nature, is sent in full for transcription. We may also share data when required by law or by order of a competent authority. We do not sell personal data.

5. International transfer

Form, purpose and country: data is sent over the internet, in encrypted form, to the providers in section 4, which store or process it on servers in the United States, a country without an adequacy decision from the Brazilian National Data Protection Authority (ANPD). For patients, this includes the passage of the web application's requests, including the audio sent during recording (Vercel), the encrypted storage of the audio (Backblaze), the transcription of the audio (AssemblyAI), the generation of the draft and of the summary by language models from the text with placeholders (OpenRouter, which chooses on each call the provider that runs the model, such as Anthropic, Amazon, Google or Microsoft) and the storage of the patient record, the transcript and the medical record in the database (Railway). For professionals, it includes sign-up data, emails and payments.

Duration: the audio stays in the United States until it is deleted (section 6); the transcript and the medical record stay there for as long as they must be kept; with the transcription and language model providers, the transfer lasts for the time of processing. As soon as it receives each transcript, Liora Health asks AssemblyAI to delete it; if the request fails, the failure is logged for manual deletion. The copies each provider keeps on its own, such as logs and backups, and any use of the data to train models follow that provider's policies: Liora Health does not use the data to train models, but has no contractual guarantee that the providers do not.

Legal basis and responsibilities: for the patient's health data, the transfer relies on the specific and highlighted consent given in the TCLE, which discloses the international nature of the operation (Art. 33, VIII, of the LGPD). The recording item discloses that the audio, the transcript and the medical record are kept in the cloud in the United States; a separate item authorizes sending them to artificial intelligence services, and without it the audio is not sent for transcription and the text is not sent to the language models. Keeping the medical record, which includes the patient's identification, is also necessary for the professional to comply with a legal obligation (Art. 33, IX, combined with Art. 7, II). For the professional's data, the transfer is necessary to perform the contract (Art. 33, IX). Liora Health has not signed the ANPD standard contractual clauses with the providers. The professional or the clinic, as controller of the patients' data, collects the consent and answers to the patient; Liora Health, as processor, handles the data only according to their instructions and with the security measures described in the Terms of Use; the providers process the data only for the purposes in the table.

Contact and rights: the controller of patients' data is the professional or the clinic that provided the care; the controller of professionals' data is Liora Health, at devaocubome@gmail.com. Through that channel or with the professional who treated you, you can ask for information about the transfer and exercise the rights in section 7, and you can petition the ANPD.

6. Retention and deletion

Consultation audio is stored in encrypted form and deleted when the professional approves the medical record, when the patient revokes consent or when a deletion request is made; if none of this happens, or if the deletion fails, an automatic routine deletes it starting about 30 days after the upload begins. Deletion failures are logged and handled by Liora Health.

The medical record, the transcript and the consent and artificial intelligence use records are kept for the retention period required by professional rules — for physicians, Law 13.787/2018 (minimum retention of 20 years from the last entry, including for electronic medical records) and, for psychologists, CFP Resolutions No. 1/2009 and No. 6/2019 (minimum retention of 5 years, or the longer period required by law or by the health service) —, including after a deletion request. The platform can be configured to discard the transcript early once the medical record is approved, but this option is turned off; so, today, the transcript is kept together with the medical record. Database backups follow the infrastructure provider's cycle.

The professional's account data is kept for as long as the account exists and, afterwards, for the time needed to meet legal obligations. After the subscription is cancelled, patients' data remains available to the professional in read-only mode, as set out in the Terms of Use, until the professional requests its return or deletion; if the account is deactivated (expired subscription billed through RevenueCat), the export is requested at devaocubome@gmail.com.

7. Data subject rights

Under Art. 18 of the LGPD, you may request: confirmation that processing takes place; access to the data; correction of incomplete, inaccurate or outdated data; anonymization, blocking or deletion of unnecessary or excessive data or data processed in breach of the law; portability; deletion of data processed based on consent, subject to legal retention; information about the entities we share data with; information about the possibility of not consenting and its consequences; and revocation of consent. Send your request to devaocubome@gmail.com; we will respond within the deadlines of Art. 19 of the LGPD: immediately, in simplified form, or within 15 days, through a complete statement.

If you are a patient, the controller of your data is the professional or the clinic that treated you: make your request to them, as they can export your data and record on the platform the revocation of your consent and your refusal of artificial intelligence. If the request reaches Liora Health, we will forward it to the controller and support them in responding. Deletion covers the audio; the medical record, the transcript and the consent records are kept for the retention period (section 6). You can also petition the ANPD.

8. Data protection officer

Data protection officer (Art. 41 of the LGPD): João Gabriel M. Pereira. The channel for contacting the data protection officer, for data subjects and for the ANPD, is the email devaocubome@gmail.com.

9. Children and adolescents

Sign-up on the platform is only for healthcare professionals; Liora Health is not intended for use by minors. Child and adolescent patients may be seen with the support of the platform: in that case, the TCLE consent must be given by at least one parent or by the legal guardian, in a specific and highlighted way (Art. 14, § 1º, of the LGPD), and, in sessions with psychologists, with the assent of the patient (CFP Resolution No. 13/2022). The data of children and adolescents is processed in their best interest, only to document the care, and is not used for any other purpose or shared beyond the providers in section 4.

10. Cookies and local storage

We do not use analytics, advertising or tracking cookies. We only use cookies that are strictly necessary for the website to work: liora_auth (keeps the professional's dashboard session, for up to 30 days), liora_admin_auth (admin area session, for 1 day), liora_payment_login (links the payment to the sign-up in progress, for 1 hour) and NEXT_LOCALE (remembers the chosen language, for 1 year). The browser also stores the theme preference and the last email used to sign in to the dashboard locally, only to make access easier; this information is not sent to our servers.

While a consultation is being recorded, the professional's browser temporarily keeps the audio chunks (IndexedDB) until the server confirms it has received each one, so the recording is not lost if the connection drops; once receipt is confirmed, the chunk is deleted from the browser.

11. Changes to this notice

This notice may be updated to reflect changes in the service, in the providers or in the law. We will announce relevant changes at the registered email and publish the new effective date here.