Art. 7, V
Contract performance
Platform operation, authentication, payment processing and report structuring for physician review and signature in their own official system (PACS/RIS).
Compliance · Law 13.709/2018
LGPD, without asterisks.
We are controller for operational data and processor for clinical data. The two layers have distinct legal bases, and we document each one.
Data Protection Officer
Natan Paraíso Ribeiro
Designated Data Protection Officer · LGPD contact
Applied legal bases
Four bases, each documented in a specific impact record.
Art. 11, II, “f”
Health protection
Sensitive data processing by a professional bound by CRM confidentiality, in a medical-radiology procedure under their technical responsibility.
Art. 7, II
Legal & regulatory obligation
Compliance with CFM Res. 2,454/2026 (AI in medicine), CFM 1,821/2007 (minimum 20-year retention), CFM 2,299/2021 (electronic signature) and applicable tax obligations.
Art. 7, IX
Legitimate interest
Aggregate/anonymized telemetry for quality, security and fraud prevention, with a documented Legitimate Interest Assessment (LIA) available to the controller's DPO.
Art. 7, IV / Art. 11, II, “c”
Protection of life or physical integrity
Applicable to the critical-findings communication flow (CRIT) under Enterprise scope, with traceable notification, acknowledgement and contractual SLA.
Art. 7, I / Art. 11, II, “a”
Consent
For optional features (newsletter, additional third-party integrations, voluntary anonymous benchmarks) — granular, informed, free and revocable at any time (art. 8, § 5).
Data lifecycle.
- 01
Collection
Data arrives through PACS/RIS, API integration or direct upload by the radiologist, linked to a report in progress under the controller's instructions (institution or practice).
- 02
Processing
Transcription and structuring in Brazilian cloud region (contractual data residency), with multi-tenant isolation via Row-Level Security and organization-level enclaves.
- 03
Hand-off and retention
Structured text delivered to the radiologist's official system for review and signature. Minimum 20-year retention for reports and related clinical data (CFM Res. 1,821/2007, art. 8, sole §).
- 04
Erasure
At contract end or upon the subject's request (LGPD art. 18, VI), erasure follows the art. 16 exceptions (legal obligation, research, transfer with legal basis, anonymization). Portability available in structured format (HL7/CDA when applicable).
Your rights
Eight rights. One entry point.
We respond within 15 calendar days and ask only for the minimum documentation needed to authenticate the data subject.
- 01I — Confirm whether processing exists
- 02II — Access the data
- 03III — Correct incomplete, inaccurate or outdated data
- 04IV — Anonymize, block or delete unnecessary data
- 05V — Portability to another provider
- 06VI — Erase data processed based on consent
- 07VII — Information about entities with whom data was shared
- 08VIII — Information about the possibility of not consenting
- 09IX — Revoke consent (art. 8, § 5)
- 10Direct complaint to ANPD at any time (art. 18, § 1 c/c art. 55-J, IV)