2. DATA WE COLLECT
2.1. Data provided directly by you
Name, nickname, or identifier;
Email and phone number (if provided);
Login information and password;
Information submitted through support or feedback.
2.2. Data collected automatically
Device model, operating system, language;
IP address, error logs, performance, and other necessary technical information.
2.3. Device permissions
Collected only with your authorization:
Location (for pairing and features);
Camera (for QR Code scanning);
Gallery/files (for uploading photos);
Microphone (if required by a feature);
Bluetooth (for device pairing).
2.4. Data from connected smart devices
Device identification (ID, MAC, name);
Firmware version and status;
Device operation and usage data.
Sensitive Data
If the device collects health information (e.g., weight, BMI, etc.), processing will occur only:
(a) with your consent; or
(b) under the conditions specified in Article 11 of the LGPD.
3. PURPOSES AND LEGAL BASES
We process data for the following purposes:
Providing the Application and its features – (Contract Performance);
Pairing and using smart devices – (Contract Performance);
Customer support and service – (Legitimate Interest and Contract Performance);
Security, fraud prevention, and auditing – (Legitimate Interest);
Compliance with legal obligations – (Legal Obligation);
Service and performance improvements – (Legitimate Interest);
Sending essential communications – (Contract Performance).
4. RECORDS AND IMPACT ASSESSMENTS
Grupo Relaxmedic maintains records of processing activities and conducts Data Protection Impact Assessments when applicable, in accordance with Article 37 of the LGPD.
5. DATA SHARING
We only share your data with:
Essential service providers (hosting, support, security, etc.);
Technical partners involved in operating the Application;
Public authorities, when required by law;
In the event of a merger, acquisition, or corporate restructuring.
We do not sell your personal data.
6. INTERNATIONAL TRANSFERS
If international data transfer occurs, it will comply with Article 33 of the LGPD through:
Standard contractual clauses;
Adequate protection safeguards;
Information provided to the data subject upon request.
7. DATA RETENTION AND DELETION
We will retain your data:
For the time necessary to fulfill the intended purposes;
While your account remains active;
For the legal period required for regulatory obligations.
After these periods, data will be deleted or anonymized.
8. RIGHTS OF THE DATA SUBJECT
You may request:
Confirmation and access to your data;
Correction of incomplete or outdated data;
Anonymization, blocking, or deletion of data;
Portability;
Withdrawal of consent;
Objection to processing.
Right to Review Automated Decisions
You may request a review of decisions made solely on the basis of automated processing (Article 20 of the LGPD).
If necessary:
If you do not receive an adequate response from the controller, you may file a complaint with the ANPD.
9. CHILDREN’S AND TEENAGERS’ PRIVACY
The Application is not intended for children under 13 years of age.
Any processing involving children or teenagers requires specific consent from their parents or legal guardians, in accordance with Article 14 of the LGPD.
10. INFORMATION SECURITY
We adopt technical and administrative measures, including:
Security Incidents
If an incident occurs that may cause risk or relevant damage, we will notify ANPD and the affected data subjects, as required by Article 48 of the LGPD.
11. CHANGES TO THIS POLICY
This policy may be updated. We will notify users via the Application or through official channels.
12. PRIVACY CONTACT
Grupo Relaxmedic
Address: Rua Amália de Noronha, 151 – Pinheiros – São Paulo/SP