Version 2026-10-27-health-privacy-v5 · 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.
Optional Google Ads measurement
With separate permission in Advertising preferences, Google Ads measures newly confirmed demo requests and free trial starts. Declining or withdrawing does not prevent a request, a response or a subscription. Email marketing consent is separate. No Google Analytics, Meta Pixel, remarketing or enhanced conversions are enabled.
Before permission, Google advertising tags remain blocked. After permission, the tag runs only on the demo page, on a public page opened from an ad click (to keep that click identifier) and on the confirmation page once a free trial is active. Google can receive the IP address and browser technical data, the page URL without free-form query text, a click identifier when present and an opaque identifier for deduplication (the demo request UUID or a one-way hash of the checkout reference). We do not send names, emails, telephone numbers, business names, messages or health data. A trial is not reported as a purchase and carries no value.
The choice is stored in atg:ads-consent:v2 in localStorage for 180 days. Google Ads click cookies (_gcl_*) are configured for 90 days without renewal on visits. We do not retain campaign UTM data in demo records or browser storage. Withdrawal clears accessible advertising cookies and reloads the page; it does not delete data already received by Google. Advertising requests remain subject to browser blocking and consent, so reporting is partial.
Provider: Google Ireland Limited; international processing may occur. Google Privacy · Google Ads data terms
1. Who processes data
The company is responsible for the operations described in this version from publication. Earlier records are not retroactively attributed to the LTD; any transfer of earlier operations will be communicated separately. The privacy contact is not the appointment of a Data Protection Officer.
2. Controller and processor
A Tua Gestão is the controller for visitor, demo request, account, billing, security and commercial relationship data. For data a business customer enters about its clients, staff and contacts, that customer is the controller and A Tua Gestão is the processor under the Data Processing Addendum.
3. Data processed
We may process identification and contact details, entity and professional role, credentials and authentication identifiers, plan and billing data, tax details, support requests, security records, communication preferences and technical information necessary for operations. New requests do not retain campaign attribution.
Customer workspaces may contain contacts, appointments, services, communications, payments and health data: anamnesis, allergies, medication, notes, photographs and treatment plans. The business sets purposes and collects separate explicit consent under Articles 6(1)(a) and 9(2)(a). Consent can be withdrawn in the authenticated record, stopping new processing that depends on it. These data are not sent to AI, WhatsApp, email or telemetry.
4. Purposes and legal bases
Providing accounts, subscriptions and support relies on the contract or requested pre-contractual steps where the individual is a party; for company representatives, balanced legitimate interests in managing the relationship apply. Invoicing, tax and legally required responses to authorities rely on applicable legal obligations. Security, fraud prevention and defence of rights rely on balanced legitimate interests with minimisation. Demo responses rely on requested steps or legitimate business contact management as applicable. Optional marketing relies on withdrawable consent without preventing service or a response.
Subscription country, name, address, VAT number where supplied and professional-use declaration are used to check eligibility and prepare correct invoicing. The declaration is recorded with date and policy version, and is not presented as documentary evidence. Portuguese VAT details may be checked through the European Commission's VIES system. The result, date, policy version and any manual decision or evidence are recorded separately from commercial leads. Absence of a VAT number does not itself require manual review; missing mandatory details, inconsistencies or tax exceptions may prevent automatic checkout and allow human review.
5. Demo request form
Acknowledging the Privacy Policy is separate from optional email marketing consent. Declining marketing does not prevent a response. The record includes the server-defined notice version, acknowledgement date and communications choice. Optional Google Ads measurement is described above. Requests are stored without UTM attribution. When enabled, the internal alert contains only a reference and a link to the authenticated dashboard.
6. Retention
Accounts, support and requests without a contract are retained while needed to manage the relationship, respond or resolve an incident. Necessity review and deletion are operational, not an already implemented automatic expiry period. Invoices and accounting records follow the company's applicable tax retention period, normally six years after the relevant UK financial year, extended where law or litigation requires. OSS transaction records are retained for ten years from the end of the transaction's calendar year; this does not justify retaining all personal or health documents for that period. Acceptances, professional evidence and audit records are limited to what is needed to demonstrate the contract, tax review and security or defend rights. Expiry of an approval does not automatically delete evidence; supporting documents need separate minimisation.
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.
7. Recipients and subprocessors
Operations use Clerk (authentication), Stripe (subscription payments and documents), Vercel (hosting and execution), Neon (databases), Resend (email) and Cloudflare (DNS, network services as configured and private storage of encrypted backups). The company uses Starling for banking and Xero for accounting without sending a second invoice for the same transaction. The European Commission receives data necessary for VIES checks. Accountants, advisers and authorities receive data where necessary under an applicable basis.
Roles vary: some recipients are independent controllers and others are processors. The inventory below describes purposes, data and processing contracts. Additional account and transfer information can be requested through the privacy contact. Cookiebot, Google Analytics and Meta Pixel are not loaded. Google Ads requires separate permission as described above.
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.
8. International transfers
The service is managed in the UK and may use providers and support in other countries. EU-to-UK transfers and onward transfers are assessed separately. Adequacy is used only where it covers the recipient and purpose; otherwise applicable safeguards such as EU standard contractual clauses and a UK Addendum/IDTA, risk assessment and supplementary measures are required. The privacy contact provides information about applicable safeguards. This publication does not claim all data remain in the EU or UK or certify providers.
9. Rights
Under applicable rules, individuals may request access, rectification, erasure, restriction, portability, objection and withdrawal of consent without affecting earlier lawful processing. They may complain to the UK's Information Commissioner's Office (ICO) and, where applicable, Portugal's CNPD. Requests about data in a customer's workspace should first be directed to that customer as controller.
10. Automated checks and security
Subscription uses the professional-use declaration and technical checks of country, VAT where supplied, matching details and tax policy. The normal flow does not require prior documentary evidence. Exceptions or inconsistencies may require clarification and manual review without charging; individuals may request human assessment, challenge a result and correct details through the privacy contact. Proportionate access control, segregation, logging and incident response measures apply; no system is risk-free.
11. Changes
Version, date and material changes are shown on this page. Changes of purpose or legal basis are assessed before taking effect, and renewed consent is sought where required. The review includes UK GDPR, the Data Protection Act 2018 and EU GDPR where applicable to offers directed at Portugal. Transfer mechanisms must be assessed for actual processing.
ICO registration reference: ZC265577. Payment of the fee does not certify compliance.
European Union representative
The Article 27 GDPR representative of MINOVATE TECHNOLOGY LTD is Yuri de Meirelles Motta, established in Portugal. Individuals and authorities can contact yuri.motta@minovate.io. Request a suitable postal channel by email; the residential address is not published.
The appointment does not transfer the company’s obligations or liability and does not appoint a Data Protection Officer.
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.