Artificial Intelligence Terms of Use

v1 · 04/11/2026

Last updated: 04/11/2026

1. Who we are and acceptance

The Vem Prevenir platform is operated by [COMPANY NAME], with Portuguese corporate tax number (NIPC) [REGISTRATION NUMBER] and registered office at [ADDRESS] ("Vem Prevenir", "we"), which is the controller of your data. These Artificial Intelligence Terms of Use explain how the platform's artificial intelligence (AI) features work, what their limits are and how we process your data when you use them. They supplement the Terms of Use and the Privacy Policy.

By accepting these Terms, you confirm that you have read and agree to them. If you do not agree, do not use the AI features; the platform's other services remain available.

2. What the platform's AI is

Whenever you use these features, you are interacting with an artificial intelligence and not with a person, as required by Article 50 of Regulation (EU) 2024/1689 (the Artificial Intelligence Act). The features covered by these Terms are:

• a) Zélia, virtual health assistant: a chat available to logged-in users (patients and employees of client companies). You can type or speak. When you use your voice, the recording is sent only to be converted into text and is not stored. The text of your conversations is kept in your account history so that you can resume them; you can rename or delete conversations at any time. The number of messages depends on your plan.
• b) AI analysis for companies (HR/OSH): in the "Health and Well-being" area, the AI generates reports from questionnaire results. It receives only aggregated, already-scored results (averages and percentages per group), never individual answers, and there is a minimum number of people per group to protect anonymity. HR users can also chat with "Zélia IA" about that aggregated report.
• c) AI suggestions in the online consultation: when the patient accepts transcription of the video consultation, the health professional may receive AI suggestions based on the transcript. The suggestions are only support: the professional decides and is responsible for the consultation. The patient is asked to accept the transcription separately, on the consultation screen.
• d) Assistant in questionnaires: some questionnaires show a chat with Zélia that answers questions about filling them in, and the AI may produce an automatic summary or feedback of the results.

3. Limits: the AI does not replace a health professional

• The AI is for information and prevention purposes. It does not diagnose, does not prescribe medicines or treatment and does not replace a consultation with a health professional.
• Answers may be wrong, incomplete or out of date. Always confirm any guidance with a professional before making decisions about your health.
• Do not use the AI in emergencies. In an emergency, call 112. For non-urgent clinical advice, contact the SNS 24 line (808 24 24 24). If you are going through an emotional crisis or thinking about harming yourself, contact SOS Voz Amiga or the psychological counselling service of the SNS 24 line.

4. What data is processed and why

• Zélia and the questionnaire assistant: what you type or say (converted into text), which may include information about your health, and basic account data needed to answer and to control your plan's limit. Purpose: answering your questions, keeping your history and producing questionnaire summaries.
• Analysis for companies: only aggregated, anonymous results per group. Purpose: supporting collective occupational safety and health actions.
• Consultation suggestions: the consultation transcript, only when the patient accepts. Purpose: supporting the professional during the consultation.

No decision that produces legal effects concerning you or similarly significantly affects you is taken solely on the basis of automated processing (Article 22 of the GDPR).

5. Legal basis and consent

The health data you share with the AI belongs to the special categories of personal data. We process it on the basis of your explicit consent (Article 9(2)(a) of Regulation (EU) 2016/679, the General Data Protection Regulation, GDPR, and Portuguese Law no. 58/2019). Your acceptance is recorded with the date, the version of these Terms and your IP address. You may withdraw your consent at any time (see section 8).

6. Provider, where data is processed and international transfer

The AI models and infrastructure are provided by Google Cloud (Vertex AI / Gemini and Dialogflow), acting as processor, processing the data on our behalf and according to our instructions. Processing currently takes place on servers in Brazil (São Paulo) and in the United States, that is, outside the European Union and the European Economic Area. This international transfer is carried out with the safeguards provided for in Chapter V of the GDPR, namely standard contractual clauses approved by the European Commission and, where applicable, the EU-US Data Privacy Framework. You can request information about these safeguards using the contact details in section 8.

Google Cloud's terms provide that customer data is not used to train Google's general models without permission. Vem Prevenir does not authorise the use of your conversations to train third-party models.

7. Retention and erasure

• Conversations with Zélia are kept until you delete them or until your account is closed. Deleted conversations are erased.
• Voice recordings are never stored: they are used only for transcription and then discarded.
• Other data follows the retention periods in the Privacy Policy and the law, including the rules on keeping clinical records.

8. Your rights and how to withdraw consent

You have the right of access, rectification, erasure, restriction of processing, portability and objection, as well as the right not to be subject to decisions based solely on automated processing. To exercise them, use the "Privacy and Data" area of your account or contact our Data Protection Officer at [DATA PROTECTION E-MAIL].

To withdraw your consent, go to "Privacy and Data". From that moment, the AI assistant will no longer be available until you accept again. Withdrawal does not affect the lawfulness of processing carried out before it. You also have the right to lodge a complaint with the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD).

9. User obligations

• Do not enter other people's health data without their authorisation.
• Do not use the AI for unlawful or offensive purposes or to try to circumvent the platform's security.
• Persons under 18 may only use the AI through or together with their legal representative.

10. Changes

We may update these Terms. Each version is recorded with a number and date. When there are material changes, we will ask for your acceptance again before you continue using the AI features.

11. Governing law and contacts

These Terms are governed by Portuguese law and European Union law, without prejudice to mandatory consumer protection rules. You may file a complaint in the Electronic Complaints Book (Livro de Reclamações Eletrónico, www.livroreclamacoes.pt). In the event of a consumer dispute, you may refer it to an alternative dispute resolution entity: [DISPUTE RESOLUTION ENTITY]. Questions about your data: [DATA PROTECTION E-MAIL]. Other questions and complaints: atendimento@vemprevenir.com.br.