1. Introduction
This Privacy Policy (“Privacy Policy”) applies to Institute Neumair (“Institute Neumair,” “we,” “us,” or “our”) and explains our privacy practices when you access or use Assistente Clínico, our websites, applications, and related services (collectively, the “Service”).
By using the Service, you acknowledge that you have read this Privacy Policy.
2. Definitions
“Personal Data” means information relating to an identified or identifiable individual, or other information treated as personal information under applicable privacy law.
“Processing” means an operation performed on Personal Data, such as collection, storage, organization, use, disclosure, transmission, or deletion.
“User Content” means information, text, prompts, files, notes, session material, messages, and other content submitted to the Service by or on behalf of a user.
3. Scope
This Privacy Policy applies to Personal Data processed by Institute Neumair in connection with the Service.
Third-party services may process Personal Data under their own terms and privacy policies. Where relevant, this policy identifies important third-party relationships, including FastSpring's role in paid subscription transactions.
4. Personal Data We May Collect
Depending on how you interact with the Service, we may collect or process the following categories of information:
- Account and Profile Data: email address, account identifiers, preferred name, role, personalization preferences, language, and other information used to create or configure your account.
- User Content: information you submit to Assistente Clínico, including prompts, messages, session material, notes, titles, files, text, and related inputs.
- Service and Usage Data: feature usage, page or screen activity, timestamps, actions taken within the Service, and information used to understand and operate the product.
- Device, Technical, and Log Data: IP address, browser type, device type, operating system, session identifiers, authentication events, error logs, diagnostic information, performance data, and security or audit events.
- Preferences: language selection, appearance settings, assistant configuration, and other settings saved for your account.
- Communications: information contained in support requests, emails, feedback, account inquiries, or other communications with Institute Neumair.
- Subscription and Transaction Metadata: where you use a paid subscription, Institute Neumair may receive information from FastSpring that is necessary to recognize and administer the subscription, such as plan, subscription status, transaction status, currency, order or subscription identifiers, timestamps, trial status, renewal information, and related billing metadata.
5. Professional and Clinical Information
You should not submit directly identifying patient or client information unless you have an appropriate lawful basis, authorization where required, and a professional basis to process that information through the Service.
Users are responsible for complying with applicable confidentiality, privacy, consent, record-management, and professional obligations.
6. How We Use Personal Data
We may process Personal Data for purposes including:
- Providing the Service: authentication, account management, feature operation, personalization, continuity, storage, and delivery of requested functionality.
- Processing User Content: analyzing, organizing, summarizing, retrieving, transforming, or otherwise processing User Content as necessary to provide requested Service functionality.
- Security and Abuse Prevention: protecting accounts, detecting unauthorized use, investigating suspicious activity, maintaining audit records, preventing abuse, and responding to security incidents.
- Service Reliability and Improvement: diagnosing errors, monitoring performance, understanding feature usage, improving reliability, and developing or refining Service functionality.
- Support and Communications: responding to requests, providing account support, sending operational notices, and communicating important changes.
- Subscription Administration: recognizing plan status, trial status, billing status, entitlement information, renewals, cancellations, and related account access.
- Legal and Compliance Purposes: complying with applicable law, responding to lawful requests, preserving records where legally required, and protecting legal rights.
7. Legal Bases Where Applicable
Where applicable privacy law requires a legal basis for Processing, that basis may include:
- performance of a contract or steps requested before entering a contract;
- our legitimate interests in operating, securing, supporting, and improving the Service;
- your consent where consent is required;
- compliance with legal obligations; and
- other lawful bases available under applicable law.
8. AI-Assisted Processing and Human Access
Assistente Clínico uses automated and AI-assisted systems to provide functionality requested by users. User Content may therefore be processed by automated systems in order to generate, organize, retrieve, analyze, or present Service outputs.
8.1 General-Purpose Model Training
Institute Neumair does not use User Content to train general-purpose AI models by default.
If Institute Neumair introduces an optional program that would use User Content for a materially different training or research purpose, participation would be subject to appropriate notice and any consent required by applicable law.
8.2 Human Access
Human access to User Content is restricted and may occur where reasonably necessary for security, abuse investigation, technical support requested by the user, troubleshooting, legal compliance, or other legitimate operational needs consistent with this Privacy Policy.
9. FastSpring and Paid Subscription Transactions
FastSpring acts as Merchant of Record for paid Assistente Clínico subscription transactions processed through FastSpring.
When you begin a FastSpring subscription trial or complete a paid transaction, FastSpring may collect and process information necessary for checkout, customer account creation, payment processing, subscription administration, taxation, invoicing, fraud prevention, compliance, and customer support.
FastSpring customer-account information may include information such as your name, email address, country, language, telephone number where provided, and billing address information where collected during checkout.
For recurring subscriptions, FastSpring may maintain a tokenized payment reference for future billing. Institute Neumair does not receive or store the complete raw payment card number submitted through FastSpring checkout.
Institute Neumair may receive limited subscription and transaction information from FastSpring as needed to activate, maintain, support, cancel, or otherwise administer your access to the Service.
10. Other Disclosures of Personal Data
We may disclose Personal Data in the following circumstances:
- Service Providers: vendors and infrastructure providers that assist with hosting, databases, security, monitoring, communications, analytics, customer support, AI processing, and other functions necessary to operate the Service.
- FastSpring: information necessary to establish, identify, administer, or support subscription and transaction relationships processed through FastSpring.
- Legal and Safety Matters: where reasonably necessary to comply with law, legal process, valid governmental requests, enforce agreements, investigate fraud or security incidents, or protect rights, property, or safety.
- Business Transactions: where Personal Data is involved in a merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction, subject to appropriate confidentiality and legal safeguards.
We do not sell Personal Data.
11. International Data Transfers
Institute Neumair and the providers used to operate the Service may process information in more than one country.
Where Personal Data is transferred internationally, we take reasonable steps designed to use safeguards appropriate to the information and applicable law.
FastSpring separately maintains its own international privacy and data protection framework for information it processes through its services.
12. Data Retention and Deletion
12.1 Session or Conversation Deletion
When you delete a session or conversation, the associated content is removed from the Service's primary user-facing systems so that it is no longer available to you through the ordinary Service interface.
12.2 Account Deletion
When you delete your Institute Neumair account, we delete or de-identify Personal Data and User Content associated with the account from the Service's primary systems, subject to legitimate retention requirements described below.
12.3 Information That May Be Retained
Limited information may be retained where reasonably necessary for:
- security and audit logging;
- fraud and abuse prevention;
- legal or regulatory compliance;
- billing, tax, accounting, and transaction records;
- establishing, exercising, or defending legal rights; and
- aggregated or de-identified analytics that cannot reasonably identify an individual.
We do not retain deleted conversation content for the purpose of restoring it to your account through a user-accessible restoration feature.
12.4 FastSpring Records
Deleting your Institute Neumair account does not necessarily delete records that FastSpring is independently required or permitted to retain in connection with purchase transactions, tax, invoicing, fraud prevention, payment processing, subscription history, or other legal and compliance obligations.
Requests concerning Personal Data maintained by FastSpring may also need to be directed to FastSpring according to its Privacy Statement.
14. Security
Institute Neumair uses administrative, technical, and organizational measures designed to protect Personal Data against unauthorized access, loss, misuse, alteration, or disclosure.
No technical system can provide an absolute guarantee of security.
Users are responsible for maintaining the confidentiality of their credentials and should notify us promptly if they suspect unauthorized account access.
15. Privacy Rights
Depending on your jurisdiction and the circumstances, you may have rights concerning your Personal Data, including rights to:
- request access to Personal Data;
- request correction of inaccurate information;
- request deletion where applicable;
- request restriction of certain Processing;
- object to certain Processing;
- receive certain information in a portable format;
- withdraw consent where Processing is based on consent; and
- submit a complaint to an applicable data-protection authority.
These rights vary by jurisdiction and may be subject to lawful exceptions.
We may request reasonable information to verify identity and account ownership before fulfilling a privacy request.
16. Children
The Service is intended for adults and professional users and is not directed to children.
We do not knowingly invite children to create accounts for or independently use Assistente Clínico.
17. Third-Party Links and Services
The Service may contain links to or integrations with third-party websites, products, or services.
Their privacy practices are governed by their own policies, and this Privacy Policy does not replace those third-party policies.
18. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in the Service, legal requirements, technology, providers, or our privacy practices.
The “Last updated” date identifies the current published version. Where required by law, material changes will be communicated through an appropriate notice.
19. Contact and Privacy Requests
For privacy questions or requests concerning Personal Data processed by Institute Neumair: