Privacy Notice

1. Who we are and what this notice covers

This Privacy Notice applies to all visitors and users of Ew2health's websites — including sinque.ai, www.sinque.ai, sinque.com.br, www.sinque.com.br and any other site operated by Ew2health — and to the Sinque mobile application.

The controller is Ew2health B.V., established in the Netherlands. In Brazil, Ew2health is represented by EW2Saúde Ciência e Tecnologia Ltda, registered with CNPJ no. 009.348.196/0001-84, located in Santo André/SP.

This document follows the laws of the countries in which Ew2health B.V. and its representatives operate (including the GDPR in Europe and the LGPD in Brazil) and may be updated following regulatory changes, so we invite you to consult it periodically.

2. Glossary

• Personal Data: any information relating to an identified or identifiable natural person, including name, identification document, physical or electronic address.
• Sensitive Personal Data: data on racial or ethnic origin, religious conviction, political opinion, trade-union membership, health or sexual life, genetic or biometric data, or personal data of children and adolescents.
• Data Subject: the natural person to whom the processed personal data refers.
• Data Processing: any operation involving personal data, such as collection, use, access, storage, transmission, modification or deletion.
• Controller: the party who decides on the processing of personal data. Operator/Processor: the party who processes personal data on behalf of the controller.
• Data Protection Officer (DPO): the person appointed by Ew2health to act as the channel between the company, data subjects and data protection authorities (e.g. the European DPAs and the ANPD in Brazil).
• Anonymisation: technical procedure by which personal data can no longer be associated, directly or indirectly, with an individual.
• Consent: free, informed and unambiguous agreement by the data subject to the processing of their personal data for a specific purpose.

3. How and why we collect your data

We collect personal data through our websites and the Sinque mobile application. We only ask for personal information when we genuinely need it to provide our service, through lawful means, with your knowledge and consent.

When we store data, we protect it with commercially acceptable measures against loss, theft and unauthorised access, disclosure, copying, use or modification.

4. What we collect on this site, and why

• Contact form (sinque.ai, sinque.com.br): first name, last name, email, phone number and message — to answer your request. Legal basis: consent and legitimate interest.
• Professional enquiries: name, email, occupation/clinic and message — to evaluate and support clinical partnerships. Legal basis: pre-contractual steps and legitimate interest.
• Patient start page (clinic code): the clinic code you enter and the choices you make in the guide — to show the instructions of your clinic. We do not ask for your name or health data on this page.
• Chat and voice assistants: the content of your conversation and, for voice, the audio you record — to produce a reply and improve the assistant. Audio is processed by our transcription provider and not used to identify you.
• Sinque mobile application: first name, last name, email, date of birth, gender, height, goal, group/subgroup, and weight measurements with time and date — to deliver the Sinque method and share your trend with the care team you authorise. Legal basis: consent and contract performance.
• Technical data: IP address, device name and version, operating system, language preference, access times and aggregated usage statistics.

5. Cookies

Cookies are small text files stored by your browser that let a site remember information about your visit. By using our site you accept that navigation data can be collected through cookies, and you can change your preference at any time in your browser.

• Essential cookies: strictly necessary to deliver the service you requested, including session, security and anti-fraud cookies.
• Functionality cookies: remember choices such as your language or region so we can show the right version of the site.
• Performance cookies: aggregated, non-identifying information about how the site is used, so we can improve it.
• Targeting or advertising cookies: we do not use advertising cookies on sinque.ai.

6. Data security

Ew2health approves and implements strict internal rules and technical and organisational security measures to protect personal and sensitive personal data against dissemination, loss, misuse, alteration or unauthorised access, ensuring the authenticity, confidentiality and integrity of the information. Compliance is an obligation of everyone who lawfully accesses this data.

We also encourage you to keep your device and browser up to date, with security patches, firewall and antivirus active, and to be careful with sites you do not trust.

If we become aware that security has been compromised or that personal information has been disclosed to unrelated third parties, we will take appropriate measures, including investigation, notification of the competent authorities and cooperation with them. Where there is a reasonable risk of harm to you, or where the law requires it, we will notify you by email and publish a notice in the app.

7. Data sharing

We do not share personally identifiable information publicly or with third parties, except where required by law or essential to providing our service.

The data we generate is shared with you and with whoever you authorise — such as your clinic or health professional. We work with processors for hosting, transcription and communication, bound by contract to process data only on our instructions.

We will disclose information if required or permitted by law, such as to comply with legal process, or in good faith to protect our rights, your safety or the safety of others, investigate fraud, or respond to a government request.

8. Data retention

Ew2health retains personal data in accordance with contractual, regulatory and other applicable legal bases. Where no legal period applies, we set a retention period consistent with market practice and the nature of the processing.

Ongoing investigations and administrative or judicial proceedings are valid reasons for retaining data, and storage periods may be extended in such cases, up to the end of the applicable limitation periods.

9. Your rights

You are guaranteed, among others, the right of access, update, portability, rectification, restriction, objection or deletion of your personal data, and the right to withdraw consent, by written request to our Data Protection Officer. Requests are free of charge and answered as soon as possible, always within 15 (fifteen) days.

10. International data transfers

Depending on your location, providing our service may involve transferring and storing your information in a country other than your own. You have the right to know the safeguards we apply to such transfers; contact us to learn more.

11. Children and minors

Our apps and services are designed for people aged 18 and over. We do not knowingly collect or process personal data from anyone under 18. If you are under 18, please do not submit personal information through our app or service. We encourage parents and guardians to monitor internet usage and to instruct children never to provide personal information without permission. If you believe a person under 18 has provided us with personal data, please contact us.

12. Changes to this notice

We may modify this Privacy Notice at any time, so we recommend reviewing it regularly. Changes and clarifications take effect immediately after publication on this site.

13. Applicable law

Brazilian law applies to disputes arising from services rendered in Brazil; such disputes must be filed in the City Court of Santo André, São Paulo.

Dutch law applies to disputes arising from services rendered outside Brazil; such disputes must be filed in the Courts of The Hague, the Netherlands.