Privacy Policy
Last updated: October 14, 2026
1. Introduction and Scope
This Privacy Policy explains how Mamini (mamini.app) processes personal data in connection with its patient management and clinical record platform for healthcare professionals ("Platform") and its website.
It applies to Members whose account is registered in a country other than Brazil and to visitors of the international versions of our website. Members registered in Brazil are covered by the Portuguese-language Política de Privacidade available at mamini.app/privacidade.
We have written this Policy to meet the standards of the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and the UK GDPR, which we apply as our baseline. Section 15 contains additional information for residents of the United States.
2. Who We Are
The Platform is operated by Mamini Ltda., a company incorporated in Brazil, registered under CNPJ no. 68.726.254/0001-25, with its registered address at Rua Alessandro di Berardo, 1900, Jundiaí, São Paulo, Brazil ("Mamini", "we", "us" or "our"). We are the controller of the processing described in Section 3.1.
- Data protection officer: [email protected]
3. Our Roles
3.1 Mamini as Controller
We decide how and why personal data is processed, and are therefore the controller, in relation to:
- Personal data of healthcare professionals registered as Members of the Platform, whether Solo Members or Members of a Clinic
- Personal data of staff members holding a secretary profile granted by a Clinic Administrator, described in Section 4.4
- Personal data of visitors to our website
- Business and administrative contact data
3.2 Mamini as Processor
We process Patient Data (personal data of Patients, and of their parents or legal guardians) on behalf of Members. Each Member, as a healthcare professional, is the controller of the Patient Data they enter and process, and we act as their processor, following their instructions as set out in Section 10 of our Terms of Use and in the configuration of the Platform.
Members may create a Clinic, a collaborative space in which other Members can be invited to share access to Patients and clinical records. Within a Clinic, each Member remains the controller of the Patient Data they enter or process. Where the same Patient is shared by several Members of a Clinic, those Members are joint controllers of the shared data. In essence, each Member is responsible for the data they enter and for informing the Patients they treat, and a Patient may exercise their rights with any Member who treats them.
If you are a Patient, the healthcare professional who treats you is responsible for your data and should provide you with their own privacy information. Requests about your data should be addressed to them (see Section 13).
3.3 Account Closure
When a Member closes their account, their personal data as a Member is deleted within the periods in Section 11. However, Patient Data the Member entered within a Clinic remains available to the other Members of that Clinic, who continue to act as controllers. Records of authorship of progress notes and clinical documents produced by the Member remain associated with their name and professional registration, to preserve the integrity of the clinical record.
4. Personal Data We Process
4.1 Members
- Identification and professional data: full name, email address, phone number, country, professional registration number and issuing body, and tax identification number where required for invoicing
- Login credentials: your password is stored as a cryptographic hash; we never have access to it in plain text
- Usage data: login records, actions performed on the Platform, IP address and session identifiers
- Payment data: cardholder name, last 4 digits and card brand. Full card details are processed directly by Stripe and never pass through or are stored on our servers
- Clinic relationships: membership and invitations between Members who share access to Patients
- AI assistant usage: the daily number of queries made, for usage limit purposes
4.2 Website Visitors
- Browsing data: pages visited, time on page, traffic source
- Device identifiers and cookies, under the conditions of Section 8
- Data you provide in contact forms, where applicable
4.3 Patient Data (processed as Processor)
Patient Data is entered by Members and may include: identification data (name, date of birth, identity documents), contact data, data of parents or legal guardians, clinical history, progress notes, measurements and assessments, clinical images, photographs, three-dimensional head scans, attached documents and appointment data.
Patient Data includes data concerning health, a special category of personal data, and frequently relates to infants and children, given the purpose of the Platform's clinical tools.
4.4 Secretary Profiles
- Email address, provided by the Clinic Administrator when granting access
- Name, used only to send the access invitation and not stored
- Login credentials: the password is stored as a cryptographic hash; we never have access to it in plain text
- Usage data: login records, actions performed on the Platform, IP address and session identifiers
- Clinic relationship: the access profile granted and, where applicable, the professional to whom it is linked
5. Purposes and Legal Bases
5.1 Members
| Purpose | Legal basis (GDPR) |
|---|---|
| Providing the Platform and managing your account | Performance of a contract (Art. 6(1)(b)) |
| Billing, invoicing and tax obligations | Performance of a contract and legal obligation (Art. 6(1)(b) and (c)) |
| Operational communications (notices, updates, support) | Performance of a contract (Art. 6(1)(b)) |
| Security, fraud prevention, access logs and error monitoring | Legitimate interests in protecting the Platform and its users (Art. 6(1)(f)) |
| Analytics of website and Platform use through cookies | Consent (Art. 6(1)(a)) |
| Marketing communications | Consent (Art. 6(1)(a)) |
| Establishing, exercising or defending legal claims | Legitimate interests (Art. 6(1)(f)) |
5.2 Website Visitors
| Purpose | Legal basis (GDPR) |
|---|---|
| Analytics through Google Analytics | Consent (Art. 6(1)(a)) |
| Responding to contact form requests | Steps prior to a contract or legitimate interests (Art. 6(1)(b) or (f)) |
5.3 Patient Data
As processor, we process Patient Data only on the instructions of the Member. The Member, as controller, determines the legal basis. In the EEA and the UK, processing of health data by a healthcare professional is typically based on Article 9(2)(h) GDPR (provision of health care by a professional subject to an obligation of secrecy). Outside the EEA and the UK, the legal basis is the one provided by the law applicable to the Member.
Where the Patient is a child, the Member is responsible for observing the best interests of the child and the rules of their jurisdiction on the information, consent or authorization of parents or legal guardians.
Where the GDPR does not apply, we rely on the equivalent legal bases available under the law applicable to the processing.
5.4 Secretary Profiles
| Purpose | Legal basis (GDPR) |
|---|---|
| Creating, authenticating and managing the access granted by the Clinic Administrator | Legitimate interests in enabling the access requested by the Clinic Administrator (Art. 6(1)(f)) |
| Security, fraud prevention, access logs and error monitoring | Legitimate interests in protecting the Platform and its users (Art. 6(1)(f)) |
6. Appointment Confirmation and Messages to Patients
For each appointment created on the Platform, an appointment confirmation page is generated showing only the Patient's full name, so that the appointment can be identified. The page is reachable through a random URL, is not indexed by search engines, is known only to those who hold the link, and stops displaying the Patient's name 48 hours after the appointment time.
Members may also enable automated messages to Patients as appointment confirmation requests or reminders, by email or WhatsApp. Messages contain the Patient's name, the professional's name, and the date and time of the appointment, and allow the Patient to confirm or cancel. The Member decides whether to use this feature and is responsible for informing their Patients.
When WhatsApp is used, messages are sent through the infrastructure of Meta Platforms, which receives the Patient's phone number and the content of the message. This involves an international transfer under Section 10. Messages are sent from a single Mamini number used only for automated sending. If the Patient replies through this channel, the communication is also subject to Meta's privacy policy, and Mamini does not store the content sent by the Patient.
If a Patient asks to stop receiving these messages, the Member is responsible for removing the Patient's email address or phone number from their records on the Platform, or for disabling the channel in their settings.
7. Artificial Intelligence Assistant
When enabled for a Member, the Platform offers an assistant based on artificial intelligence that answers questions asked in natural language about data the Member already has access to on the Platform.
To provide this feature, the Member's question and the data needed to answer it (which may include Patient identification and clinical data, appointments, progress notes, measurements and financial information linked to the Member) are sent to Google LLC (Gemini API), a sub-processor listed in Section 9. This involves an international transfer under Section 10.
- The data sent is limited to data the Member already has access to; no data of other Members, or of Clinics the Member does not belong to, is sent
- Under our terms with Google, the content sent through the assistant is not used to train Google's models
- Mamini does not store the content of questions or answers; we keep only a daily count of queries per Member, to enforce usage limits
- The assistant does not make decisions about anyone. Its outputs are suggestions reviewed by the Member, and no decision producing legal or similarly significant effects is based solely on automated processing
8. Cookies and Similar Technologies
We use the following categories of cookies:
- Essential cookies: necessary for the Platform to work, including session authentication (HttpOnly and Secure cookies) and security measures. They do not require consent.
- Analytics cookies: used by Google Analytics to understand how our website and Platform are used. They are only set after you consent through the cookie banner.
You can change or withdraw your consent at any time through the "Cookie preferences" link in the footer of our website. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.
Because non-essential cookies are only set after your consent, we do not separately respond to browser "Do Not Track" signals.
9. Sub-processors and Disclosures
We rely on service providers that process personal data on our behalf, all bound by contract to security and confidentiality standards consistent with applicable data protection law. These providers may in turn use their own sub-processors, under equivalent obligations, whose lists are maintained and published by each of them.
| Sub-processor | Purpose | Location |
|---|---|---|
| Railway | Hosting of the application and database | United States |
| Amazon Web Services (S3) | Storage of clinical documents, photographs, 3D head scan files, attachments, avatars and logos | United States |
| Cloudflare | DNS, content delivery and protection against attacks | Global |
| Resend | Sending of transactional emails | United States |
| Meta Platforms (WhatsApp Business Platform) | Appointment confirmation and reminder messages to Patients, when enabled by the Member | United States / Ireland |
| Stripe | Payment processing | United States / Ireland |
| Sentry (Functional Software, Inc.) | Error and performance monitoring, with personal data filtered before sending | United States |
| Google LLC (Google Analytics) | Website and Platform usage analytics, with consent | United States |
| Google LLC (Gemini API) | Artificial intelligence assistant, when enabled for the Member | United States |
| Valid Certificadora (VIDaaS) and Soluti (Bird ID) | ICP-Brasil digital signatures, only for Members registered in Brazil | Brazil |
Mamini itself is established in Brazil, and our team accesses data from Brazil.
We may also disclose personal data:
- To comply with a legal obligation or an order of a competent authority
- To establish, exercise or defend legal claims
- In the event of a corporate reorganization, merger or acquisition, with the same guarantees provided in this Policy
We do not sell personal data.
10. International Data Transfers
Mamini is established in Brazil, and most of our infrastructure providers are located in the United States. We transfer personal data internationally only with appropriate safeguards:
- From the EEA to Brazil: the European Commission has recognized Brazil as providing an adequate level of protection (adequacy decision adopted in January 2026, under Article 45 GDPR).
- Onward transfers to our sub-processors outside the EEA and Brazil: Standard Contractual Clauses adopted by the European Commission and/or, where the provider is certified, the EU-U.S. Data Privacy Framework, together with the safeguards required by Brazilian law.
- From the United Kingdom: the UK International Data Transfer Addendum to the Standard Contractual Clauses, or another mechanism recognized under UK law.
- From other countries: the safeguards required by the law of the country of origin.
You may request information on the safeguards in place by contacting us (Section 17).
11. Retention
| Category of data | Retention period |
|---|---|
| Member data, while the account is active | For the duration of the account |
| Member data after account closure | Up to 90 days to allow account recovery, then deleted or anonymized, except where retention is legally required |
| Secretary profile data | While the profile exists, including if deactivated; deleted when the Clinic Administrator removes the profile, except logs, which are kept for the periods in this table |
| Patient Data entered within a Clinic | Remains in the Clinic, under the responsibility of its remaining Members |
| Patient Data entered outside a Clinic, after account closure | Deleted within 90 days, except where retention is legally required |
| Clinical records and documents | For the periods required by the law and professional rules applicable to the Member, under the Member's responsibility |
| Records of messages sent to Patients | 90 days after sending, including the email or phone number used and the delivery status |
| Application access logs | 6 months, as required by Brazilian law (Law No. 12,965/2014) |
| Audit logs of access to sensitive data | 12 months |
| Billing and contractual data | 5 years after the end of the relationship, or longer where required by law |
12. Security
We apply technical and organizational measures to protect the personal data we process, including:
- Encryption in transit (TLS) for all communications
- Encryption at rest of the database and file storage
- Session authentication with HttpOnly and Secure cookies
- Role-based access control and separation of data between Members and Clinics
- Audit logs of access to sensitive data
- Filtering of personal data before sending events to error monitoring, and no session recording
- Periodic backups
- A security incident management procedure
No system is completely immune to incidents. If a personal data breach occurs, we will notify the competent supervisory authority where required (within 72 hours under the GDPR) and the affected individuals where the breach is likely to result in a high risk to their rights. Where the breach affects Patient Data, we will notify the Members concerned under Section 10 of our Terms of Use.
13. Your Rights
Depending on the law applicable to you, and in particular under the GDPR, you have the right to:
- Access your personal data and obtain a copy
- Rectify inaccurate or incomplete data
- Erase your data, where there is no longer a legal reason to keep it
- Restrict the processing of your data in certain circumstances
- Data portability, receiving the data you provided in a structured, commonly used and machine-readable format
- Object to processing based on legitimate interests
- Withdraw your consent at any time, without affecting processing carried out before the withdrawal
- Not be subject to decisions based solely on automated processing that produce legal or similarly significant effects
To exercise your rights, contact [email protected]. We will respond within one month, which may be extended by two further months for complex requests, in which case we will inform you. We may ask for information to confirm your identity.
You also have the right to lodge a complaint with a supervisory authority, in particular in the country where you live or work. In Spain, the competent authority is the Agencia Española de Protección de Datos (aepd.es).
Patients: requests concerning Patient Data should be addressed to the healthcare professional who treats you, who is the controller. If we receive such a request, we will forward it to the competent Member without undue delay.
Limits to erasure: erasure requested by a Member applies to their personal data as a Member. As described in Sections 3.3 and 11, it does not extend to Patient Data entered within a Clinic, which remains under the responsibility of its other Members, nor to records of authorship of clinical documents. Data subject to legal retention obligations, including clinical records and billing data, is kept for the periods required by law.
14. Children
The Platform is intended for adult healthcare professionals and is not directed to children. Patient Data may include data about children, entered by Members as controllers, who are responsible for complying with the rules of their jurisdiction on children's data.
15. Additional Information for Residents of the United States
- HIPAA: Mamini does not currently enter into Business Associate Agreements. As set out in our Terms of Use, covered entities and business associates under HIPAA must not use the Platform for protected health information.
- No sale of personal information: we do not sell personal information and do not use Patient Data for advertising.
- State privacy rights: depending on your state of residence, you may have rights to access, correct or delete your personal information, or to opt out of certain processing. Where these laws apply, you can exercise these rights through [email protected], and we will not discriminate against you for doing so.
- Consumer health data: we process Patient Data as a processor on behalf of Members. Requests about this data should be addressed to the treating professional.
- Reviewing and changing your information: you can review and update your account information in your Platform settings, or by contacting us.
16. Changes to this Policy
We may update this Policy to reflect regulatory, operational or service changes. Material changes will be notified to Members by email and/or in-Platform notice before they take effect. The version in force is always the one published at mamini.app/en/privacy, with its date of last update.
17. Contact
- Data protection officer: [email protected]
- General inquiries: [email protected]
- Postal address: Mamini Ltda., Rua Alessandro di Berardo, 1900, Jundiaí, São Paulo, Brazil
18. Governing Law
This Policy is governed by the laws of the Federative Republic of Brazil, without prejudice to mandatory provisions of the data protection law applicable to you, and to your right to lodge a complaint with a supervisory authority or to bring proceedings before the courts of your country of residence.