Version 2026-10-27-ltd-health-professional-v4 · the Portuguese source was adopted by the provider on . This English translation preserves its conditions and does not record a new approval or acceptance. Publication is the provider’s decision and is not certification by an authority or independent professional advice.
MINOVATE TECHNOLOGY LTD · Company number 17469954 · Registered office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ · Registered in England and Wales.
Translation of the existing Portuguese document. Read the Portuguese source.
1. Roles and subject matter
The customer is the controller for personal data entered in its workspace. A Tua Gestão acts as processor exclusively to host, organise, transmit, protect, support and delete those data under the contract and the customer's documented instructions.
2. Duration, nature and individuals
Processing accompanies service provision and the contracted export/deletion phase. It covers collection, recording, organisation, access, alteration, authorised transmission, retention, export and erasure of identification, contact, appointment, service, payment, communication and operational-note data about clients, prospects, staff and suppliers of the customer.
Scope includes anamnesis, allergies, medication, health notes, photographs and treatment plans in beauty and laser businesses. The business remains responsible for purposes and legal bases under GDPR Articles 6 and 9. The launch health-data flow uses explicit consent under Articles 6(1)(a) and 9(2)(a), separate from tax consent, marketing and procedure authorisation; the healthcare exception is not presumed.
3. Instructions and lawfulness
A Tua Gestão processes data only under documented instructions, including customer-configured features, unless applicable law requires otherwise. It informs the customer in advance unless law prohibits this for important public-interest reasons. It also informs the customer if it considers an instruction to infringe data protection law. Customers ensure transparency, a lawful basis, minimisation, accuracy and respect for individual rights.
4. Confidentiality and security
Access is limited to people under confidentiality duties. Measures include authentication and role-based authorisation, workspace segregation and dedicated databases, HTTPS, secret protection, administrative logs, signed-webhook verification and idempotency, vulnerability management and incident response. Support access requires an authorised purpose and is not owner impersonation.
Consent records the individual, purpose, full text and version, UTC date/time, collector and evidence of an affirmative act. Withdrawal stops new processing dependent on consent; no retroactive consents are created for existing records. Workspace administrators manage permissions; professionals access only assigned and authorised clients. Reception and management do not receive health-data access by default. MFA can be enabled for additional protection but is not mandatory at initial launch. Photographs are stored in the workspace's dedicated Neon database and accessed only through authenticated, authorised access; signing links do not bypass authentication or authorisation. Access, changes, downloads, exports and deletions are audited without copying health content into logs.
Sending health data, attachments, photographs, treatment names or sensitive free text to AI, WhatsApp, email or telemetry is prohibited. Operational communications use only permitted fields and generic messages. Minovate does not use workspace data for advertising, profiling or model training.
5. Further subprocessors
The customer grants general authorisation for the listed subprocessors, limited to contracted purposes. Additions or replacements are notified before new processing starts, with 30 days for a reasoned objection. The parties seek a solution; without a suitable alternative, the customer may terminate the affected service before the change. Urgent security or legal instructions are communicated as soon as possible. The provider imposes equivalent obligations and remains responsible to the customer for further subprocessors.
Operational provider inventory
| Service | Entity and location/transfers | Purpose | Data | Processing contract |
|---|---|---|---|---|
| Clerk | Clerk, Inc. International service; DPF where applicable and standard contractual clauses as safeguards. | Identities, sessions and organisations | User identity, contact and authentication data | Clerk DPA |
| Vercel | Vercel, Inc. Backup verification is configured for Sandbox in Frankfurt; execution of other services, support and subprocessors depend on the account and applicable safeguards. | Hosting, execution, technical logs, and verification of backups and restores | Application requests and runtime-processed data, including workspace data and authorised health data in temporary copies during backup and restore verification | Vercel DPA |
| Neon | Databricks, Inc. / Neon, LLC Dedicated database in London (aws-eu-west-2); current terms incorporate the Databricks contract. Support and subprocessors may operate in other regions. | Dedicated databases and recovery | Workspace data, including authorised health data | Neon DPA |
| Resend | Plus Five Five, Inc. International service; DPF where applicable and standard contractual clauses. | Transactional communications | Recipient, generic operational message and status; no health data | Resend DPA |
| Cloudflare | Cloudflare, Inc. Backups use R2 in the EU jurisdiction; other services, support and subprocessors may operate internationally under the safeguards applicable in the DPA. | DNS, network services and private storage of encrypted backups | Domains, technical metadata and encrypted copies of workspace databases, which may include authorised health data | Cloudflare DPA |
Stripe handles payments and commercial relationship documents; Starling and Xero handle Minovate banking and accounting. We do not send them a copy of the workspace database for those purposes. Each provider’s own role is defined in its contract.
This inventory does not claim all data remain in the EU or UK. Regions, support access and transfer mechanisms depend on the service and account. Further information is available through the privacy contact. A public DPA does not prove acceptance or coverage of every plan: the provider is responsible for maintaining the contracts and safeguards applicable to operations.
6. International transfers
EU GDPR and UK GDPR require separate assessment of relevant transfers under each regime. Applicable adequacy decisions or contractual safeguards, including EU standard contractual clauses and a UK Addendum/IDTA, are identified with risk assessments and supplementary measures where needed. Incorporating an LTD does not itself validate transfers or provider contracts.
7. Rights, assessments and authorities
Considering the nature of processing, A Tua Gestão assists customers with individual rights requests and security, notification, impact assessment and prior consultation obligations. Requests received directly are forwarded to the customer unless legally prevented.
8. Personal data breaches
Personal data breaches are reported to the customer without undue delay after awareness, without waiting for investigation to finish. Available information includes nature, known categories and scale, contact, likely consequences and taken or proposed measures, with progressive updates. The provider assists the customer in assessing notification obligations.
9. Return, deletion and audit
At service end, data including copies are returned or deleted at the customer's choice, except legally required retention. During the contract, individuals can export and request deletion through their authenticated account, including records, versions, photographs and plans. Legacy files require migration or review to prevent incomplete deletion. After termination, owners have 30 days to request assisted export through the authorised contact; operational deletion must complete by day 60 and backups expire by day 90 unless a documented legal obligation applies. Tax documents follow their own retention without justifying general health-data retention.
The provider makes information available and permits audits by customers or appointed auditors. Documentation and questionnaires are preferred; inspections are agreed with reasonable notice and confidentiality safeguards without restricting legal or regulatory requirements.
Workspace data after cancellation
During the subscription, workspace data are processed to provide the service. After effective cancellation, access is disabled and normal operational retention is 60 days. In the first 30 days after termination, owners can request data return or assisted export through admin@atuagestao.com; this does not preserve interactive access to the cancelled workspace.
At the end of retention, deletion rechecks cancellation and any legal retention obligation, disables resources and deletes the dedicated database. Failures are monitored and retried; a legal obligation may suspend deletion. Billing, acceptance and audit records follow their own legal purposes and are not deleted by this process.
The backup policy limit is 90 days after termination. The currently verified recovery window in the workspace’s Neon project is seven days, which is not a guarantee about every internal provider copy. Backups are not reused for normal operations; deletion instructions are reapplied after disaster recovery.
10. Precedence and contacts
This Addendum takes precedence over the general Terms for conflicts concerning processing on the customer's behalf. The provider is the company identified above; the customer is the professional or entity named in the subscription. Instructions and requests must come from an authorised contact to admin@atuagestao.com.
The privacy contact is not the appointment of a DPO. DPO and DPIA obligations are assessed for actual processing before launch and when material changes occur; review at ten paying workspaces or six months is not a legal exemption.
Contact and references
admin@atuagestao.com · Privacy Policy · Data Processing Addendum
EU GDPR · ICO · CNPD. UK GDPR and the Data Protection Act 2018 apply where relevant. Publication does not certify compliance or remove mandatory legal obligations. The Portuguese source contains the additional legislative and guidance references.