Privacy Policy

1. Introduction

This Privacy Policy describes how Dopu, a brand operated by DOPU TECNOLOGIA LTDA, a Brazilian limited liability company registered under tax ID (CNPJ) 54.995.846/0001-38, hereinafter referred to as "Dopu", "we" or "our", collects, uses, stores and protects the personal data of the users of our platform.

Because Dopu is operated from Brazil, this policy is drafted in compliance with Brazilian law, in particular:

• Brazilian General Data Protection Law (LGPD) — Law No. 13.709/2018
• Brazilian Internet Civil Framework — Law No. 12.965/2014
• Brazilian Consumer Defense Code — Law No. 8.078/1990

2. Data Controller

For the purposes of the LGPD, Dopu acts as:

• Controller of the data of the professionals who are users of the platform
• Processor of the data of patients entered by those professionals

3. Data Collected

3.1. Professional (User) Data

We collect the following data to provide the service:

3.2. Patient Data

Patient data is entered and managed exclusively by the professionals using the platform. Dopu acts as processor of such data, processing it on behalf of and under the instructions of the professionals (controllers).

Patient data may include:

• Identification data (name, tax ID, date of birth, contact)
• Health data (medical records, clinical notes, diagnostic hypotheses)
• Clinical documents (declarations, certificates, reports)

3.3. Browsing Data

We automatically collect:

• IP address
• Browser and device type
• Pages accessed and session duration
• Date and time of access
• Cookies (see specific section)

3.4. Free Resource Forms

When you request a free resource on the website (for example, the LGPD Checklist or the LGPD Templates), we collect:

It is not a newsletter or an e-mail sequence: it is the resource and one message. To stop receiving anything, reply “sair” to the e-mail or write to dpo@dopuapp.com. The request is honored within 2 business days and your address is added to the list of people who no longer receive our messages. This data is kept in Dopu's database, on the same infrastructure described in item 6.1, and is never sold or shared with third parties. Retention is in item 6.3.

4. Purposes of Processing

We use the data collected to:

• Provide and maintain the platform
• Process registration and authentication
• Manage subscriptions and payments
• Send service-related communications
• Send the free resource you request and one message from the founder (item 3.4)
• Provide technical support
• Comply with legal and regulatory obligations
• Improve user experience
• Prevent fraud and ensure security
• Generate anonymized statistics

5. Data Sharing

We may share personal data with:

Sharing with infrastructure providers operates under a data processing agreement signed with each of them, setting out their obligations as processors. The full categories, with what each one receives, are listed under Sub-processors.

We do not sell, rent or trade personal data.

6. Storage and Security

6.1. Storage Location

Data is stored in datacenters located in the United States, operated by global-scale cloud infrastructure providers. This storage constitutes international data transfer under art. 33 of the Brazilian LGPD, based on standard contractual clauses entered into with each provider, and supplemented by the technical safeguards described in section 6.2.

The named list of providers is given to the professional inside the platform and, to data subjects, on request to the Data Protection Officer. We do not publish it on an open page as a matter of security prudence, exercising the trade-secret proviso in arts. 6, VI and 9, II of the LGPD. See Sub-processors.

6.2. Security Measures

We implement technical and organizational measures to protect data:

• Encryption in transit (TLS/SSL) and at rest (AES-256)
• Additional field-level encryption over free-text clinical fields
• Per-professional isolation: each user reaches only the records under their own responsibility
• Role-based access control (RBAC)
• Continuous security monitoring
• Automatic backups and data redundancy
• Immutable access audit trail, verified periodically
• Internal information security policies

6.3. Retention Period

7. Data Subject Rights

Under the LGPD, you have the right to:

• Confirmation and access: know whether we process your data and obtain a copy
• Rectification: request correction of incomplete or inaccurate data
• Anonymization, blocking or deletion: of unnecessary or excessive data
• Portability: receive your data in a structured format
• Deletion: request removal of data processed under consent
• Information: know with whom we share your data
• Withdrawal of consent: at any time
• Objection: to processing in certain circumstances

To exercise your rights, contact us via email at dpo@dopuapp.com. We will respond within 15 days of receipt, under art. 19 of the LGPD.

Data deletion requests: full instructions — including for data originating from Meta platforms (Instagram and WhatsApp) — are on the Data Deletion page, which sets out what is deleted, what is retained by legal requirement, and how to contest a refusal.

8. Cookies and Similar Technologies

8.1. What Cookies Are

Cookies are small text files stored on your device that allow us to improve your browsing experience.

8.2. Types of Cookies Used

8.3. Cookie Management

You can manage cookies through your browser settings. Note that disabling essential cookies may affect platform functionality.

9. International Transfer

Some of our service providers may be located outside Brazil. In such cases, we ensure international transfers occur only to countries with an adequate level of protection or under appropriate safeguards, in accordance with art. 33 of the LGPD.

10. Integration with Google Services (Optional)

Dopu offers optional integration with Google services. This functionality is not mandatory — each professional can use the platform without connecting any Google account. The provisions of this section apply only to users who choose to enable such integrations.

10.1. Available features

When the user opts to connect their Google account, the following integrations become available:

• Google Sign-In (OAuth): authentication on the platform using a Google account, without the need for a separate password
• Google Calendar: creation and management of appointment events directly in the professional's calendar, with the option to include patients and contacts as guests (only when enabled by the professional for each patient)

10.2. Data accessed via Google

When the integration is active, Dopu may access the following data:

10.3. Limited use of Google data

In compliance with the Google API Services User Data Policy, data obtained via Google APIs is used exclusively for:

• Authenticating the user on the Dopu platform
• Creating, updating and managing appointment events on the professional's Google Calendar

Dopu does not perform and expressly prohibits the use of Google data for:

• Targeted, personalized, retargeting or interest-based advertising
• Sale or transfer to data brokers or information resellers
• Determining credit eligibility or any financial purposes
• Training artificial intelligence models
• Building data sets for use outside the platform
• Any purpose not directly related to the operation of the contracted service

10.4. Revoking access

The user may revoke Dopu's access to their Google account at any time via:

• Dopu platform settings (Settings > Integrations)
• Directly at myaccount.google.com/permissions

After revocation, no new Google data will be accessed. Data already stored follows the retention periods defined in section 6.3.

11. Transcription and Artificial Intelligence

DOPU offers AI-assisted transcription of clinical sessions (DOPU Transcribe). This feature is optional and is only activated at the professional's discretion, subject to a recording consent registered for the patient.

11.1. Processing exclusively on our own infrastructure

Transcription and note generation are performed by AI models hosted on DOPU's own infrastructure (within the cloud environment covered by a data processing agreement). The audio and clinical content are never sent to external AI providers (such as OpenAI, Anthropic, Google or similar). Clinical content does not leave DOPU's secure environment.

11.2. No use for model training

DOPU does not perform and expressly prohibits the use of client recordings, transcripts or clinical notes to:

• Train, fine-tune or improve AI models — our own or third parties'
• Build datasets for any use external to providing the service
• Any secondary purpose unrelated to the professional's own session

Improvements to DOPU's models use exclusively synthetic, public or licensed data — never client content.

11.3. Minimization and retention

• Audio: retained with the transcription record until the professional explicitly requests deletion of that transcription
• Verbatim transcript: preserved as part of the session record; it is not automatically removed after a time window or when an evolution is saved
• Generated notes: once saved, they become part of the clinical record under the professional's responsibility; clinical fields are stored with field-level encryption

The patient may, at any time, ask the professional to revoke the recording consent, which stops further transcriptions.

12. Minors

Platform accounts: Dopu is intended for psychology professionals over 18 years of age. We do not open accounts for minors.

Minor patients: as a data processor, Dopu processes data of children and adolescents treated and registered by the professionals who use the platform. That processing follows art. 14 of Lei nº 13.709/2018, which requires data of children and adolescents to be processed in their best interest, and depends on specific, prominent consent from at least one legal guardian — obtained by the professional, who is the controller of that data.

Retention of a minor patient's record follows its own period, described in item 6.3.

13. Controls Being Rolled Out

This section exists so you know, without having to ask, what is already in operation and what is not yet. The controls below have been decided and are not yet in production. No statement made elsewhere in this policy depends on them: everything described in the present tense works today.

The dates are planning estimates, not contractual commitments. Until each item ships, the measures described in item 6.2 and the periods in item 6.3 apply.

14. Changes to this Policy

We may update this Policy periodically. Significant changes will be communicated via:

• Email to registered users
• Notification on the platform
• Update of the revision date at the top of this document

We recommend reviewing this page periodically.

15. Contact and DPO

For matters related to privacy and data protection:

You may also file a complaint with the Brazilian National Data Protection Authority (ANPD) at www.gov.br/anpd.

16. LGPD Glossary

• Personal data: information relating to an identified or identifiable natural person
• Sensitive personal data: data on racial origin, religious belief, political opinion, health, sexual life, genetic or biometric data
• Data subject: natural person to whom the personal data refers
• Controller: party that makes decisions about the processing of personal data
• Processor: party that processes data on behalf of the controller
• DPO: person appointed to act as a communication channel between the controller, data subjects and the ANPD
• Processing: any operation performed with personal data
• Consent: free, informed and unambiguous expression of the data subject