This Policy explains how MUPI SYSTEMS LTDA., CNPJ 26.882.608/0001-80, headquartered in Montes Claros/MG, Brazil (“MUPI”, “we”), processes personal data within the eAgenda platform, the websites eagenda.com.br, eagendas.com and minhaagendavirtual.com.br and the eAgenda mobile app (“PLATFORM”). It was prepared in compliance with the Brazilian General Data Protection Law (Law 13,709/2018 — LGPD), the Brazilian Internet Framework (Law 12,965/2014) and, where applicable to data subjects abroad, Regulation (EU) 2016/679 (GDPR). Capitalised terms have the meaning defined in the Terms of Use.

1. Who is responsible and how to reach us

MUPI has a Data Protection Officer (DPO), who can be reached through the channels indicated in this section.

Data Subject Channel: requests regarding personal data — exercise of rights, questions and complaints — may be submitted by email to contato@mupisystems.com.br. Each request receives a protocol number and status tracking, within the timeframe of section 10. No account is required to submit a request.

2. MUPI’s two roles: read this first

The PLATFORM involves two distinct data flows, with distinct responsible parties:

(a) MUPI as CONTROLLER. For the data of CUSTOMERS (the professional or business that subscribes to eAgenda), their AUTHORIZED USERS and the visitors of our websites, MUPI decides the purposes of the processing and is the controller. Sections 3 to 12 of this Policy deal with this flow.

(b) MUPI as PROCESSOR. For the data of END USERS — the people who book appointments with a CUSTOMER (for example, a clinic’s patient or a salon’s client) — the controller is the CUSTOMER, who decides how that data is used. MUPI acts as processor, handling it exclusively to enable the service, as set out in the Terms of Use (clause 17) and the Data Processing Agreement.

If you are an END USER (you booked an appointment with a business that uses eAgenda): your appointment data belongs to the relationship between you and that business. To exercise your data protection rights over it — access, correction, deletion —, contact the business first, as it is the controller. If you prefer, you may contact us through the channel in section 1: we will forward your request to the business and provide the technical support needed to handle it.

3. What data we process and why (MUPI as controller)

Data	Purpose	Legal basis (LGPD, art. 7)
CUSTOMER registration: name, email, phone, address, tax ID (CPF/CNPJ)	Create and manage the ACCOUNT; identify the customer; contractual communications (billing, suspension and terms-change notices)	Performance of a contract (V)
Billing data and payment history	Charging, issuing tax documents, fraud and default prevention	Performance of a contract (V); legal obligation (II); legitimate interest (IX)
Navigation data: pages accessed, IP, browser, device, date and time	Security, fraud prevention, compliance with the Internet Framework, improvement of the PLATFORM	Legal obligation (II); legitimate interest (IX)
Mobile app technical data: authentication, device, notifications	Operation of the app and delivery of notifications	Performance of a contract (V)
Email for informational and marketing communications	News, content and offers, in accordance with the Anti-Spam Policy (Part I, section 3)	Legitimate interest (IX), with free opt-out; consent (I) when collected outside the contractual relationship
Support and service-desk data	Handle requests and improve the service	Performance of a contract (V); legitimate interest (IX)

Payments: card data is collected and processed directly by certified payment intermediaries (PCI-DSS). MUPI does not collect or store full card numbers — we receive only tokenised identifiers and the transaction confirmation.

We do not: sell personal data; use contractual or appointment data for targeted advertising; make automated decisions producing legal effects on data subjects. Should any of these practices be adopted, this Policy will be updated beforehand, with prominence and, where required, collection of consent.

4. Data processed on behalf of CUSTOMERS (MUPI as processor)

To provide the service, the PLATFORM stores and processes the data that CUSTOMERS and their END USERS enter: names and contacts of participants, appointment details, client records and service history. This data: (a) is processed exclusively in accordance with the CUSTOMER’s instructions as embodied in the Terms of Use and the PLATFORM’s features; (b) is not used by MUPI for its own purposes, except for the use of anonymised data for statistics and service improvement; (c) follows the retention, export and deletion regime of clauses 6.5 and 12 of the Terms of Use. The full conditions of this processing are set out in the Data Processing Agreement.

5. Sensitive data and data of children and adolescents

eAgenda serves segments — such as healthcare (physicians, psychologists, physiotherapists, telemedicine) and education — in which appointment data may reveal sensitive personal data (art. 5, II, LGPD) or involve children and adolescents (art. 14, LGPD). In such cases:

the CUSTOMER, as controller, is responsible for ensuring the appropriate legal basis (art. 11 for sensitive data; best interest and, where required, consent of at least one parent or guardian, for minors);
MUPI, as processor, applies to that data the same technical safeguards of section 8, processing restricted to providing the service and internal access limited to operational need;
the PLATFORM does not publicly display appointment data; access is restricted to the CUSTOMER and, as to their own appointments, to the END USER.

We share personal data only with: (a) sub-processors necessary to provide the service — cloud hosting, payment intermediaries, email and messaging providers (including WhatsApp/Meta, where the channel is enabled by the CUSTOMER) —, contractually bound to security and privacy obligations compatible with this Policy; (b) public authorities, where there is a legal obligation or an order from a competent authority, notifying the CUSTOMER in advance where the law does not prohibit it (Terms of Use, clause 17.3.f); (c) successors, in the event of corporate reorganisation, maintaining the commitments of this Policy.

The categories of sub-processors, with purpose and location, are set out in Annex III of the Data Processing Agreement.

7. International data transfers

Data is stored in ISO/IEC 27001-certified data centres located in Brazil and/or abroad, notably in the United States and the European Union. International transfers are carried out on the basis of art. 33 of the LGPD and the ANPD’s International Transfer Regulation (Resolution CD/ANPD No. 19/2024), preferably through ANPD standard contractual clauses incorporated into the contracts with the providers, or another valid mechanism recognised by the ANPD.

8. Information security

We adopt technical and organisational measures suited to protecting personal data against unauthorised access and accidental or unlawful destruction, loss or alteration, including: TLS 1.2 or higher encryption in transit; storage of passwords with robust hashing algorithms (bcrypt/Argon2); role-based access control and logging; backups with controlled purge (Terms of Use, clause 6.5); binding of staff and sub-processors to confidentiality obligations.

Security incidents: incidents that may entail relevant risk or harm to data subjects will be reported to the ANPD and to the affected data subjects within 3 (three) business days of becoming aware of them (art. 48 of the LGPD and Resolution CD/ANPD No. 15/2024). Affected CUSTOMERS will be notified by email within 24 (twenty-four) hours of our becoming aware, under clause 17.3.g of the Terms of Use.

9. How long we keep the data

Category	Term	Basis
CUSTOMER DATA on the PLATFORM (appointments, client records, settings)	For the term of the contract; after termination, suspension or an unconverted trial, the regime of clauses 4.2, 6.3, 6.5 and 12 of the Terms of Use (deletion with prior notice; backups purged within 90 days)	Performance of a contract; LGPD, art. 15
CUSTOMER registration and contractual data	Up to 5 (five) years after the ACCOUNT is closed	Limitation periods (Civil Code, art. 206) and defence in proceedings (LGPD, art. 7, VI)
Tax documents and payment records	5 (five) years, at least	Legal tax obligation
Access logs	6 (six) months	Brazilian Internet Framework, art. 15
Marketing email after opt-out	Record of the unsubscribe kept in a suppression list	Legitimate interest (to demonstrate the opt-out was honoured)

Once the terms expire, data is deleted or anonymised, save for the cases in art. 16 of the LGPD.

10. Your rights and how to exercise them

Every data subject may exercise, free of charge, the rights of art. 18 of the LGPD: confirmation that processing exists; access; correction of incomplete, inaccurate or outdated data; anonymisation, blocking or deletion of unnecessary, excessive or non-compliant data; portability; deletion of data processed with consent; information about sharing; information about the possibility of withholding consent and the consequences thereof; and withdrawal of consent.

How to exercise them: through the channel indicated in section 1, which generates a protocol number and allows tracking of progress. No account is required to submit the request. To protect the data subjects themselves, we may carry out proportionate identity verification (for example, confirmation through the registered email or phone) before providing data. We will respond: (a) in simplified form, immediately; or (b) by full statement, within 15 (fifteen) days of the request (LGPD, art. 19, II). END USER requests concerning appointment data follow the flow of section 2.b, with a recorded referral to the CUSTOMER controller. The data subject may also petition the ANPD (gov.br/anpd).

Withdrawal of consent or deletion of data necessary for the performance of the contract may make provision of the service impossible, which will be explained when the request is handled.

11. Cookies and similar technologies

We use cookies according to the categories of our preferences panel, available on every page:

Necessary (always active): authentication, security and essential operation of the site — legal basis: legitimate interest / performance of a contract;
Analytics: audience measurement and site improvement (Google Analytics) — activated only with consent;
Marketing: campaign measurement and advertising (Google Ads and equivalent platforms) — activated only with consent.

Preferences may be reviewed at any time through the panel (“Customise” / “Reject all”) or through the browser settings.

12. Changes to this Policy

This Policy may be updated, with publication of the new version on this page, indication of the effective date and a version history. Changes that broaden processing or reduce safeguards will be communicated to CUSTOMERS by email at least 30 (thirty) days in advance, under clause 19 of the Terms of Use.