This privacy statement was last updated on 03/19/2024 and applies to citizens and legal permanent residents of Brazil.

In this privacy statement, we explain how the data we obtain about you through https://fluxmed.com.br. We recommend that you read this statement carefully. In our processing, we comply with the requirements of privacy legislation. This means, among other things, that:

• We clearly state the purposes for which we process personal data. We do this through this privacy statement;
• we aim to limit our collection of personal data to only that personal data necessary for legitimate purposes;
• We first request your explicit consent to process your personal data in cases that require your consent;
• we take appropriate security measures to protect your personal data and also require this of parties processing personal data on our behalf;
• We respect your right to access your personal data, correct it or delete it, at your request.

If you have any questions or want to know exactly what data we hold on you, please contact us.

Core Consultoria e Serviços Ltda, limited company, headquartered in Brasília – DF, registered with the CNPJ under number 05.490.544/0001-00, sole and exclusive owner of the brands and domains associated with the so-called “Fluxmed”, “fluxmed.com .br”, fluxmed.cloud and coreconsulting.com.br, establishes these conditions of use for the use of their products.

Privacy Policy and Consent establish the rules and conditions applicable to the use of Fluxmed. The following resources are covered by this Term: the application for mobile devices, web applications and service APIs and processing backends.

Fluxmed is a platform for developing digital health services, in constant technological evolution, therefore, your rights and obligations will be presented as the functionalities are evolved and made available by the platform, thus updating this privacy policy. If you have any questions, please contact us via email at hostmaster@fluxmed.com.br.

Glossary of terms used:

Personal Data: information relating to an identified or identifiable natural person, capable of being identified directly or indirectly, by reference to an identification number or to one or more specific elements of their identity. Personal Data includes, among others, your full name, CPF number, date of birth, cell phone number, email, sex at birth, electronic health record, electronic prescription, exam referrals and medical certificates. This data may concern the healthcare professional or the patient.

Individual: any Brazilian citizen registered in the individual register, CPF.

Legal Entity: any Brazilian company providing health services, registered in the National Register of Legal Entities, CNPJ with specific CNAE for the provision of health services.

Health professional: any natural person duly registered with professional councils to carry out health service provision activities.

o physical, which has an electronic health record in Fluxmed.

Electronic Prescription, Referral of Exams and Medical Certificates: means the document (s) issued by a doctor, or another legally qualified professional, to the Patient which is made available digitally and is identified by means of electronic signature type, according to CFM regulations. https://portal.cfm.org.br/crmdigital/.

Clinical information records – any information relating to the patient's health condition in a clinical encounter, including electronic prescriptions, exam referrals and medical certificates.

RES – Electronic Health Record – is a digital document generated from the recording of clinical information in Fluxmed that is shared with the Patient. This RES is basically a Clinical Care Record that can be used for continuity of health care.

Digital Certification: Digital certification is the technology that provides cryptographic computational mechanisms to guarantee the irreversibility and authenticity of a digital document. At the heart of digital certification is the digital certificate, an electronic document that contains the name, a unique public number called the public key and other data that shows who we are to people and information systems.

Professional Council: These are councils formed by professionals from each profession, with boards democratically elected by their members, who represent the interests of their profession. Its main task is to register, monitor and discipline regulated professions. They are considered “special or corporate authority”.

CNAE: National Registry of Economic Activities of the Federal Revenue of Brazil.

RES Consent: Mechanism that allows an individual user of Fluxmed to provide access to their RES to other individuals or legal entities of interest.

Patient: Any natural person registered with Fluxmed, who at some point had their EHR registered by a health professional user.

1. Purpose, data and retention period

We may collect or receive personal information for various purposes related to our business operations, which may include the following: (click to expand)

1.1 Contact – Via telephone, mail, e-mail and/or web forms

To do so, we use the following data:

• A first and last name
• An email address
• A telephone number
• Date of birth
• IP adress
• A CPF number – Individual Taxpayer Registry and, when applicable, the CNPJ – National Legal Entity Registry.
• Medical information
• Health insurance information
• Sex

The basis on which we may process this data is:

By granting consent.

Retention period

Fluxmed will keep patient data for a period longer than legal custody, in compliance with any orders from public authorities, to defend itself in legal or administrative proceedings and in cases in which Personal Data has been duly anonymized by Fluxmed's technological resources, and also, to maintain possession of their RES for continuity of care.

We determine the retention period according to fixed objective criteria: they will be maintained indefinitely, until the patient user requests removal.

1.2 Payments

To do so, we use the following data:

• A first and last name
• An email address
• A telephone number
• IP adress
• Date of birth
• A CPF number – Individual Taxpayer Registry and, when applicable, the CNPJ – National Legal Entity Registry
• Health insurance information
• Sex

The basis on which we may process this data is:

By granting consent.

Retention period

Fluxmed will keep patient data for a period longer than legal custody, in compliance with any orders from public authorities, to defend itself in legal or administrative proceedings and in cases in which Personal Data has been duly anonymized by Fluxmed's technological resources, and also, to maintain possession of their RES for continuity of care.

We determine the retention period according to fixed objective criteria: Payment data may be used to validate information

1.3 Registering an account

To do so, we use the following data:

• A first and last name
• An email address
• A telephone number
• IP adress
• Date of birth
• Geolocation data
• Sex
• Photos
• Social Media Accounts
• A CPF number – Individual Taxpayer Registry and, when applicable, the CNPJ – National Legal Entity Registry
• Medical information
• Health insurance information

The basis on which we may process this data is:

By granting consent.

Retention period

Fluxmed will keep patient data for a period longer than legal custody, in compliance with any orders from public authorities, to defend itself in legal or administrative proceedings and in cases in which Personal Data has been duly anonymized by Fluxmed's technological resources, and also, to maintain possession of their RES for continuity of care.

We determine the retention period according to fixed objective criteria: the data will be kept until the user requests deletion.

1.4 Compiling and analyzing statistics to improve the website.

To do so, we use the following data:

• IP adress
• Sex
• Date of birth
• Account name or nickname
• An email address
• A telephone number

The basis on which we may process this data is:

By granting consent.

Retention period

Fluxmed will keep patient data for a period longer than legal custody, in compliance with any orders from public authorities, to defend itself in legal or administrative proceedings and in cases in which Personal Data has been duly anonymized by Fluxmed's technological resources, and also, to maintain possession of their RES for continuity of care.

We determine the retention period according to fixed objective criteria: the data will be kept until the user requests deletion.

1.5 To be able to offer personalized products and services

To do so, we use the following data:

• A first and last name
• An email address
• A telephone number
• IP adress
• Date of birth
• Sex
• A CPF number – Individual Taxpayer Registry, and, when relevant, the CNPJ – National Legal Entity Registry
  
• Medical information
• Health insurance information

The basis on which we may process this data is:

By granting consent.

Retention period

Fluxmed will keep patient data for a period longer than legal custody, in compliance with any orders from public authorities, to defend itself in legal or administrative proceedings and in cases in which Personal Data has been duly anonymized by Fluxmed's technological resources, and also, to maintain possession of their RES for continuity of care.

We determine the retention period according to fixed objective criteria: the data will be kept until the user requests deletion.

1.6 To sell or share data with third parties

To do so, we use the following data:

• Medical information
• Health insurance information
• Date of birth
• Sex

The basis on which we may process this data is:

By granting consent.

Retention period

Fluxmed will keep patient data for a period longer than legal custody, in compliance with any orders from public authorities, to defend itself in legal or administrative proceedings and in cases in which Personal Data has been duly anonymized by Fluxmed's technological resources, and also, to maintain possession of their RES for continuity of care.

We determine the retention period according to fixed objective criteria: the data will be kept until the user requests deletion.

1.7 To support services or products that a customer wants to buy or has purchased

To do so, we use the following data:

• A first and last name
• An email address
• A telephone number
• IP adress
• Date of birth
• Sex
• Medical information
• Health insurance information

The basis on which we may process this data is:

By granting consent.

Retention period

Fluxmed will keep patient data for a period longer than legal custody, in compliance with any orders from public authorities, to defend itself in legal or administrative proceedings and in cases in which Personal Data has been duly anonymized by Fluxmed's technological resources, and also, to maintain possession of their RES for continuity of care.

We determine the retention period according to fixed objective criteria: the data will be kept until the user requests deletion.

2. What if you don't provide us with your personal information?

If you do not provide us with your personal information, we may not be able to provide the information, services, products or assistance you are seeking.

3. Sharing with other parties

We only share or disclose this data with other parties for the following purposes:

Generation of analytical information on population health: Fluxmed may contract third-party services to assist it in providing its services, such as cloud services. Information, duly anonymized, may be used to generate analytical data on population health and sold to interested third parties.

Organizational Change. In the event of a sale, merger, corporate reorganization or any other change in control of Core Consultoria e Serviços Ltda that owns Fluxmed, in this case it will ensure that the individual or legal entity that comes to access or assume control over the data treated under the terms of this Policy are also linked to it, guaranteeing the continuity of the protection of Personal Data, and communicating users in advance.

Judicial or Administrative. Fluxmed may share Personal Data in the event of a judicial or administrative request.

With the authorization of the User. In other cases, if there is a need to share the information, a notification will be sent requesting your approval.

4. Cookies

Our website uses cookies. For more information about cookies, please see our Cookies Policy. 

5. Disclosure practices

We disclose personal information if required to do so by law or court order, in response to a law enforcement agency, to the extent permitted by other provisions of law, to provide information or for an investigation into a matter relating to public safety.

If our website or organization is acquired, sold or involved in a merger or acquisition, your data may be disclosed to our advisors and any potential buyers and will be passed on to the new owners.

6. Security

We are committed to the security of personal data. We take appropriate security measures to limit abuse and unauthorized access to personal data. This ensures that only necessary people have access to your data, that access to data is protected, and that our security measures are regularly reviewed.

Fluxmed will do its best to mitigate the security risks of the personal data collected, adopting security and protection measures compatible with the best market practices. Fluxmed cannot guarantee that such security measures are error-free or that they are not subject to interference from third parties (hackers, among others). By its nature, despite Fluxmed's best efforts, any security measure can fail and any data can be made public. When using Fluxmed, users understand and assume this risk and that Fluxmed will not be responsible for this type of data leak.

Due to legal or administrative obligations, Fluxmed may be prevented from deleting certain types of personal data, such as consent information. In this case, when applicable, Fluxmed will inform you of this impossibility, proceeding to exclude the remaining information. Without prejudice, when complying with any exclusion requests, Fluxmed may be unable to provide its services in whole or in part. Furthermore, after exclusion, Fluxmed may continue to use them, in a non-individualized way and without any personal identification (anonymized), for the purposes set out in this terms of use.

All information collected will be stored with high security standards in cloud computing resources allocated to AWS – Amazon Web Services, in data centers located in Brazil.

Core Consultoria e Serviços Ltda is committed to keeping this website updated and accurate. If, however, you find something that is incorrect or out of date, we would appreciate it if you could let us know. Please indicate where you read the information on the website. Then we will look into it as soon as possible. Send your response by email to: contato@coreconsulting.com.br.

We are not responsible for losses resulting from inaccuracies or incompleteness, nor for losses caused by or inherent to the dissemination of information over the internet, such as disturbances or interruptions. When using web forms, we strive to limit the number of required fields to a minimum. For any loss suffered as a result of the use of data, advice or ideas provided by or on behalf of Core Consultoria e Serviços Ltda through this website, Core Consultoria e Serviços Ltda is not responsible.

The use of Fluxmed services and all its components (including forums) is subject to the terms of use. Simply using this website implies knowledge and acceptance of these terms of use.

Any personal data you provide to us in the context of your response or request for information will only be used in accordance with our privacy statement.

Core Consultoria e Serviços Ltda will make all reasonable efforts to protect its systems against any form of illegal use. Core Consultoria e Serviços Ltda must implement appropriate technical and organizational measures for this purpose, taking into account, among other things, the best available technologies (state of the art). However, it will not be responsible for any loss, direct and/or indirect, suffered by a user of the website that results from the illegal use of its systems by third parties.

Core Consultoria e Serviços Ltda is not responsible for the content of the websites to which or from which a hyperlink or other reference is made. Products or services offered by third parties are subject to the applicable terms and conditions of those third parties.

All intellectual property rights to the content of the website and the Fluxmed platform belong to Core Consultoria e Serviços Ltda.

Copying, disseminating and any other use of these materials is not permitted without the written permission of Core Consultoria e Serviços Ltda, except and only to the extent otherwise stipulated in mandatory law regulations (such as the right to quote), the unless the specific content dictates otherwise.

If you have questions or problems with the site's accessibility, please do not hesitate to contact us.

7. Third Party Sites

This privacy statement does not apply to third-party websites linked to on our website. We cannot guarantee that these third parties will handle your personal data reliably or securely. We recommend that you read the privacy statements of these sites before using them.

8. Changes to this privacy statement

We reserve the right to make changes to this privacy statement. It is recommended that you review this privacy statement regularly in order to be aware of any changes. Furthermore, we will actively inform you whenever possible.

9. Accessing and modifying your data

If you have any questions or want to know what personal data we have about you, please contact us. You can contact us using the information below. Your rights in relation to personal data:

• confirmation of the existence of processing;
• access to data;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or deletion of unnecessary, excessive or processed data in violation of the provisions of the General Personal Data Protection Law (LGPD);
• portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, respecting commercial and industrial secrets;
• deletion of personal data processed with the consent of the holder, except in the cases provided for in art. 16 of the General Personal Data Protection Law (LGPD);
• information about public and private entities with which the controller shared data;
• information about the possibility of non-consent and the consequences of denial.

To exercise these rights, please contact us. Please see the contact details at the bottom of this Privacy Statement.

Please make sure you always clearly state who you are so we can be sure we do not modify or delete any data for the wrong person.

10. Submitting a complaint

If you are not satisfied with the way we handle (a complaint about) the processing of your personal data, you have the right to lodge a complaint with the National Data Protection Authority (ANPD):

National Data Protection Authority

Esplanade of Ministries,
Block C,
2nd floor,
CEP 70297-400 – Brasília – DF.
Web site

11. Children

Our website is not designed to attract children and it is not our intention to collect personal data from children under the age of majority in their country of residence. Therefore, we request that minor children do not send us any personal data.

12. Contact Details

Core Consultoria e Serviços Ltda
SIG Quadra 01, Lot 385, Room 404 – Platinum Office Ed.
Brasilia DF
ZIP code: 70610-410
Brazil
Website: https://fluxmed.com.br
Email: contato@coreconsulting.com.br