Oxxy Privacy Policy
This is a translation; if it differs from the Portuguese version, the Portuguese version prevails.
Want to delete your access and your personal data? See section 7.
Last updated: October 13, 2026
Plainly put: Oxxy needs to process some data to run the system and the Orbi assistant, keep your account secure, control costs, and improve the service. We do not sell personal data, and we do not use your data for third-party advertising.
1. Who we are and in what role
Oxxy is provided by OXXYGENIUM DIGITAL TECHNOLOGIES SERVICOS E COMERCIO LTDA, CNPJ 04.104.812/0001-38, through the oxxy.ai website.
We act in two roles, and this changes whom you should contact:
- Controller: of the registration, login, billing, usage, security, and support data of the people who use Oxxy. For this data, contact us.
- Processor: of the data that the client company records in the contracted modules, such as customers, staff, finances, documents and, at clinics, patients and medical records. The client company decides about this data and is its controller. If you are a customer, patient, or employee of a company that uses Oxxy, make your requests to that company; we help it respond.
Data Protection Officer (DPO): Humberto Cardoso, by email at privacidade@oxxy.ai.
2. Data we process
- Account and profile: name, email, contact phone number, company, roles, and login data (Apple, Google, or email).
- Document for trial registration: when you provide the company's CNPJ or the CPF of a self-employed person, we validate it and check whether it has been used for another trial registration. The normalized document is stored in the account's encrypted profile. Separately, the uniqueness check stores a cryptographic code (HMAC), the document type, and its link to the account. During individual account purging, the encrypted profile is removed and the marker’s direct association with the user is cleared. The HMAC marker and its link to the company remain; deleting individual access does not close the company or delete that marker.
- Data the company records: finance, billing, scheduling, staff, documents, customers, quality, and other contracted modules.
- Health data, in clinic accounts, when the module is contracted: medical records, amendments, follow-up visits, and patients' own access to their records. This is sensitive data, processed on the clinic's behalf.
- Content sent to Orbi: messages, instructions, attachments, images, and audio you provide so the assistant can carry out your request.
- Voice: when you speak to Orbi, the audio is processed to transcribe and respond. The Starter plan does not include voice.
- Location: if the company enables location-based clock-in, location is requested only with your permission and is precise at the moment of the clock-in.
- Photos and files: when you attach them or use the camera.
- Usage and security: IP address, browser, device, times, screens accessed, audit logs, and the medical-record access trail.
- Consumption and billing: AI and voice usage, limits, plan, and payment history.
Face ID and fingerprint are checked only on your device; Oxxy does not receive this data.
Times: we record them in UTC and display them in Brasília time.
3. What we use it for and on what legal basis
| Purpose | Legal basis (LGPD, Brazil's General Data Protection Law, Law 13.709/2018) |
|---|---|
| Create the account, sign in, apply permissions, and provide the contracted modules | performance of a contract (Art. 7, V) |
| Carry out requests to Orbi, including by voice | performance of a contract |
| Bill, keep accounting records and, when the feature is active, issue invoices | compliance with a legal obligation (Art. 7, II) and performance of a contract |
| Security, fraud prevention, auditing, and fixing failures | legitimate interest (Art. 7, IX) and regular exercise of rights (Art. 7, VI) |
| Improve the product with aggregated or de-identified data | legitimate interest |
| Patients' health data | processed on behalf of the clinic, which is the controller and defines the basis under Art. 11, such as protection of health by a health professional or health service |
| Marketing communications | consent, which you may withdraw at any time |
Do not send Oxxy data that you do not have the right to share.
4. Whom we share with
We share only what is necessary to provide the service, with:
- AI providers that process requests to Orbi: Anthropic (Claude), OpenAI, and Google.
- Voice provider: ElevenLabs, for Orbi's voice.
- Hosting, storage, email, and security: providers that operate the service on our behalf.
- Payments: Asaas, when billing is active.
- Service invoices: the issuing provider, when the feature is active.
- WhatsApp: Meta, when the company activates the official channel.
- Login: Apple and Google, when you choose to sign in with them.
- Public authorities, when there is a legal obligation.
We do not sell personal data.
5. Transfers outside Brazil
Some providers process data outside Brazil. When this happens, we adopt the safeguards under article 33 of the LGPD that apply to each case.
6. How long we keep it
- Account and usage data: while the account or contract is active, and afterwards for the period needed for legal, tax, and accounting obligations, defense in legal proceedings, and security.
- Data recorded by the company: while the contract is active. After cancellation, the company may request an export of its data before deletion; the data is then deleted or anonymized, except where retention is required by law.
- Medical records: follow the retention period that the law and professional councils impose on the clinic. Deleting a person's access does not erase medical records.
- Conversations with Orbi: the history is kept with the company's data while the account is active and follows the deletion rules of this policy.
- Backups: may keep isolated copies until they are overwritten in the retention cycle. We do not restore backups to reactivate a deleted account; if a disaster restore is unavoidable, the blocking and deletion apply again.
7. Deleting your access and your data
You may delete your access and the personal data that is yours alone at any time, without giving a reason.
- Sign in again to confirm it is you.
- Open Settings › Account › Delete my account (on screen: "Configurações › Conta › Excluir minha conta"), read what will be deleted, and type EXCLUIR (the Portuguese word for DELETE, as shown on screen).
- Your logins are blocked immediately, and you receive the final date by email.
For 30 days you may change your mind by writing to privacidade@oxxy.ai. After that date, the deletion is final. An individual request does not erase data belonging to the company, other people, or third parties, nor records that the law requires us to keep; the person responsible for the company requests the closure of the organization separately.
If you signed in with Apple or Google, the link is revoked. If Apple's automatic revocation is not possible, remove Oxxy in Settings › Apple Account › Sign in with Apple (on screen: "Ajustes › Conta Apple › Entrar com a Apple"); this does not suspend the request.
8. Your rights
You may request confirmation of processing, access, correction, anonymization, blocking, deletion, portability, information about sharing, review of automated decisions, and withdrawal of consent, and you may file a complaint with the ANPD. Write to privacidade@oxxy.ai; we may ask for the minimum information needed to confirm your identity. For data recorded by a client company, we forward the request to it.
9. Security
We use authentication, with two-step verification available, role-based permissions, logical separation of each company's data, audit logs, and a medical-record access trail. Perfect security does not exist; our commitment is to take risk reduction seriously and to act when an incident occurs. In an incident that may cause significant risk or harm: for data for which we are the controller, we notify the ANPD and the affected people within the regulatory deadlines; for data for which we are the processor, we notify the client company and the company makes the notification.
10. Cookies
We use only essential cookies for login, session, and security. Details are in the Cookie Policy.
11. Audience
Oxxy is for professional use by people over 18 who are authorized by the company. Data of minor patients recorded by a clinic is processed on behalf of the clinic, which is responsible for parental or guardian consent when required.
12. Changes to this policy
The current version is on this page with its update date. Significant changes are also announced through the registered channels.
13. Contact
Privacy and data subject rights: privacidade@oxxy.ai. Support: suporte@oxxy.ai.