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Privacy Policy

A privacy policy is a statement that discloses some or all of the ways in which a website collects, uses, discloses and manages the data of its visitors and customers. It meets a legal requirement to protect the privacy of a visitor or customer.

Countries have their own laws with different requirements by jurisdiction regarding the use of privacy policies. Make sure you are following the legislation relevant to your activities and location.

What will I find in the privacy policy?

  1. Introduction

  2. What is this Policy for?

  3. Definitions used throughout this Policy

  4. Minors' data

  5. Personal Data collected

  6. Registration data

  7. Information generated by the use of our Services

  8. Marketing Communications

  9. Retention period

  10. Security

  11. Our recommendations for protecting your data

  12. Sharing with third parties

  13. Service providers

  14. Third party links

Privacy Policy


Last updated February 21, 2022.


Please read this policy carefully before using our





International Transfer


Rights of Holders

Modifications to this Policy

Questions and clarifications



For us, at MIRAX PHOTO APP (“MIRAX”), protecting your Personal Data is a priority.

When you share your Personal Data with us, or when we collect Personal Data

about you, we use them only to the extent and in accordance with this Privacy Policy.

Privacy (“Policy”) and the Terms of Use. Therefore, read them carefully, as when accessing and

using our Platform, you trust us with your information and declare that you have carefully read the

provisions of this Policy, being fully aware of the terms stipulated here.

Our goal is to accompany you on this health journey. For this reason, we want you

rest assured regarding the collection and use of your Personal Data, especially your data


We will notify you of any significant updates to this Policy and would like to invite you to

consult this page periodically, regardless of the sending of notifications about

changes. We will also keep previous versions of this Privacy Policy on file

so you can order whenever you want.

If you have any doubts regarding the provisions of this Policy or have any concerns

regarding your Personal Data, please contact us via email


We are always available to listen to you, whether on this health journey or for your health.





What is this Policy for?

This Policy describes what types of Personal Data we may receive from you directly

or through your interaction with us, how we may use them, who we may

sharing them, how we protect them and keep them safe, and their rights in relation to their

Personal data. This Policy provides an overview of all situations through which

we can interact.


We know the great responsibility we have in relation to safeguarding your Data

Personal, mainly your health data. It is our commitment to be as clear and

as transparent as possible, so you can understand what we do with your data

and for this we seek the highest standards of privacy and security, all in accordance with

the Applicable Legislation, referring to the Processing we carry out. The more you interact

with us, the more it informs us and the more we are able to offer our services. When is

Policy mentions “MIRAX”, “we” or “our”, as well as the grammatical variations of the first

plural person, it refers to the company JB Cursos Ltda, registered with the CNPJ under no.

44.957.236/0001-96, with headquarters at Rua Groenlândia 135/801- Sion, CEP 30320-060, Belo

Horizonte / MG and email address


Definitions used throughout this Policy

● Personal Data means any information relating to an identified natural person or

identifiable, directly or indirectly, in particular by reference to an identification number or

to one or more factors specific to it, such as name, surname, date of birth,

identification document, address, telephone number, e-mail, photos, behavioral profile, etc., which

is disclosed, provided or accessed by MIRAX for the purposes of providing the Services and

operation of the MIRAX Platform.


● Sensitive Personal Data: Personal Data about racial or ethnic origin, religious conviction, opinion

politics, membership of a union or organization of a religious, philosophical or political nature, given

relating to health or sexual life, genetic or biometric data, when linked to a person



● Anonymized Data means any data relating to a Holder who cannot be identified,

considering the use of reasonable technical means available at the time of processing.

These are, for example, the data we collect when you visit our website, such as clicks, movement movements,

mouse, location, browser name and version, device name, brand and version, preferences




of languages configured in the browser, screen size, page visibility, date and time,

amount of time spent on specific pages, which features of our website you visit.

None of this information can tell us who you really are.


● MIRAX Platform means the MIRAX PHOTO APP software program that receives, processes and

stores patient data in the cloud, generating results in oculoplastic photography for

Clients Users of the MIRAX PHOTO APP and making it easier for Doctors to carry out diagnoses


● Services mean the services provided by MIRAX to Users when using the Platform,

as defined in the Terms of Use.


● Controller means the Person Responsible for the Processing of Personal Data, who is responsible for

decisions regarding Treatment.


● Operator means any natural or legal person, under public or private law, who carries out the

Processing of Personal Data on behalf of the Data Controller.


● Patient means the beneficiary of our Services provided by the MIRAX Platform.


● User/Partner Customers mean all those who subscribe to the subscription service of the

MIRAX PHOTO APP software, including Doctors, medical or laboratory institutions such as Clinics

and Hospitals, and that use MIRAX Services to carry out practical recording of photographs

separated by diagnosis in oculoplastics, through linear or circular measurements of

any injury marked in a photo.


● User means all individuals who access and use our Services.


● Holder means the natural person to whom the Personal Data that is the subject of



● Processing: any operation or set of operations carried out with Personal Data or

sets of Personal Data, whether by automated means or not, such as, but not limited to

the, collection, use, access, organization, consultation, production, alteration, reception, classification, use,

reproduction, communication, transmission, distribution, processing, archiving, recording,

structuring, storage, adaptation, retrieval, transfer, availability,

combination, restriction, elimination, evaluation or control, modification, elimination or extraction.


● Applicable Legislation means Brazilian legislation, in particular, while it remains in force, the




General Personal Data Protection Law (Law No. 13,709/2018 or “LGPD”), the Civil Rights Framework for the Internet

(Law No. 12,965/2014 and Decree No. 8,771/2016), the Federal Constitution, Brazilian Civil Code,

Penal Code, Consumer Protection Code (Law No. 8,078/1990 and Decree No. 7,963/2013), their

subsequent amendments, and any other laws and regulations in relation to the Processing,

privacy, confidentiality and protection of Personal Data that are applicable and, if applicable, all

guidelines, standards, rules, ordinances, regulations and codes of practice and conduct issued by

National Data Protection Authority (“ANPD”), National Health Surveillance Agency

(“ANVISA”) or other relevant government entity.

Minors' data

The MIRAX Platform is not intended for or directed to children, and we do not collect data from

Patients under 12 (twelve) years of age knowingly or intentionally.

If you are under 18 years of age, you must not use the MIRAX Platform without written authorization

of at least one of your parents or legal guardian, which must be sent to

If you suspect that a minor under 18 (eighteen) is using our Services without

Due authorization, do not hesitate to contact us at

If we become aware that information has been collected from minors under the age of 18 (eighteen)

without the prior authorization of a parent or legal guardian, we will not disclose this data and

We reserve the right to immediately delete the User account, as well as all

information related to the minor User, including from our servers.

Personal Data collected

We access your Personal Data through our MIRAX Platform.

Sometimes you provide this data to us directly (e.g. when you create an account, when

report symptoms, physical activities, feelings, when you contact us via chat or

‘talk to us’, or when you give us a testimonial), sometimes we collect them (e.g. using

cookies to understand how you use our Platforms) or sometimes we receive

information about you that is available on the internet, or through third parties such as

Facebook, Instagram, YouTube, LinkedIn and Google, Google Drive. The more you interact

With us, the more you inform us and the more capable we are of offering you personalized services.

All Personal Data that MIRAX holds about you is confidential and must remain

therefore, unless you actively choose to share them, for example, with other medical staff




that is serving you.

Veracity and quality of Personal Data. Users are solely responsible for ensuring

the accuracy, clarity, relevance and timely updating of the Personal Data provided, in accordance

as necessary, MIRAX having no obligation to investigate the veracity of the

information sent. Without prejudice to the above, from time to time, MIRAX may request the

you to update your Personal Data.

Registration data

When you create your User Account at MIRAX, we will need to receive certain data from you

necessary to identify you, contact you and provide our Services. We will collect your email and

name of patients (collectively the “Registration Data”). The Registration Data is

essential for us to provide our Services to you. If you do not provide the Data

Registration, we will not be able to provide you with the Services.

The Registration Data entered by the User to create their User Account must be

accurate, current and truthful.

The main reason we collect your Personal Data is to provide our Services to


Upon receiving your Registration Data, they are entered into the MIRAX database,

masked and securely encrypted, only for the purposes stated in this


You should never share personal information and data with us

third parties, or confidential data.

Information generated by the use of our Services

The processing of data generated by the use of our Services has the main purpose of

allow the practical recording of photographs separated by diagnosis in

oculoplastic, through linear or circular measurements of any lesion marked in a photo.

data may also eventually generate statistical and anonymized analyzes on how

you interact with and use the MIRAX Platform and help us understand your use of our

products, fix issues and bugs, and improve your experience.

Location data. Depending on your device settings and permissions, MIRAX

may collect information about your precise or approximate location based on data from



GPS, IP address and Wi-Fi. MIRAX collects this information about your location when the

system is running on your device in the foreground (application open and displayed in the

screen) or in the background (application open but not displayed on the screen).

Usage and transaction data. We collect Anonymized Data about how you interact and use the

our services, including the type of service requested or provided, features of the

MIRAX Platform used or pages viewed, software failures, and other

system, type of browser used, and third-party sites or services you used before using

our services, order details, benefits information, time and date of delivery of the

service and access to the platform and duration of the intervention.

Device information. Due to this Privacy Policy, we may collect

information about the devices you use to access our services, including models

hardware, device IP addresses, operating systems and versions, software,

files and their respective operating system versions and their credentials in the

MIRAX software subscription, if applicable; unique device identifiers (or

“UDID”); advertising identifiers; serial numbers; information about movement of

devices; mobile network information; and the location of your city.

Log file information. We may collect in addition to hardware and

software mentioned above, other information such as domain names, service providers

(ISP), files viewed on our website (e.g. HTML pages, graphics, etc.),

operating system and clickstream data.

Marketing Communications

In addition to acting as an authentication and validation mechanism for your login,

account at MIRAX, and as a main and secondary means of communication with the User in order to

enable the provision of our Services (“Essential Communications”), and for the purpose of

security of the User, the email may eventually be used by MIRAX to send

of “push” notifications containing information, reminders, news, content, news,

partnerships and other relevant events about MIRAX products and services for maintenance

of our relationship with you (“Marketing Communications”). We will request your

prior consent to send you Marketing Communications.

We pay attention to what we communicate and how often we do it. MIRAX never

will send Marketing Communications without your consent. You can change the settings

on your device at any time in the body of the email sent, in the email settings



MIRAX Platform, sending a chat message or an email to

with the subject “Revocation of Consent”.

If you do not grant your consent to the sending of Marketing Communications, the

MIRAX services and features will continue to be made available regularly.

Retention period

We only keep your Personal Data for as long as necessary to achieve the

purpose for which we carry out the Processing, to meet your needs, or to

comply with our legal or regulatory obligations. When we no longer need to use your

Personal Data, or when required by law, will be removed from our systems and records or

anonymized, so that you can no longer be identified from this data.

We may retain some Personal Data to comply with our legal or regulatory obligations, as well as

and to allow and guarantee the regular exercise of our rights (for example, in legal proceedings

judicial, administrative or arbitration).


MIRAX takes the security of your Personal Data very seriously. In this sense, we will apply

always comply with technical and organizational security measures established in Applicable Legislation

considering the nature of the Personal Data processed and the circumstances of the processing, as well as

as those that are advisable given the state of technology, ensuring integrity,

security and confidentiality of Personal Data on the MIRAX Platform.

The User is co-responsible for the confidentiality of their Personal Data. Password sharing,

login, and other Personal Data that enable access to the User Account violate this Privacy Policy

Privacy and Terms of Use.

Despite taking all appropriate technical and organizational measures to ensure safety

of your Personal Data, no method of transmitting or retaining electronic data is

fully secure and may be subject to external attacks. MIRAX will not be responsible for

losses arising from acts of third parties using improper, fraudulent or illegal means

to access information stored on servers or databases used by

MIRAX. Furthermore, MIRAX cannot be held responsible if you have caused unauthorized access

authorized to MIRAX Platforms.




Our recommendations for protecting your data

For our Customer users: your Personal Data is stored in the Software. Like this,

We understand that protecting your device is a way to also keep your data more secure.

insurance. Below we present some ways to keep the information on your device longer


● Enable code authentication, digital biometric or facial recognition for the

your device. This automatically encrypts the access data and prevents any

person uses your device without your permission.

● Set up a feature that will allow you to erase all data on your device

in case of loss or theft:

- For iOS devices


TM, enabling this functionality is a two-step process:


First, you need to activate “Find my iPhone” through iCloud


and then activate “Delete


device” (see instructions on the Apple Support pages).

- For Android devices


TM, download and configure “Find my Device” from

from the Google Play Store and, if necessary, use the linked web interface to block or

Wipe your phone remotely. (see instructions on the Google Support pages).

Sharing with third parties

MIRAX will not share your Personal Data with third parties unless: (i) this is necessary

to provide you with our Service (as technical service providers), (ii) we have

requested your explicit consent, or (iii) your data has been anonymized in

databases with aggregated information for the purpose of academic and clinical research.

This anonymized search data does not contain any information that would allow the

MIRAX researcher, partner or Customer identifies you as an individual.

We may also disclose your personal data to third parties:

● If MIRAX or part of its assets is acquired by a third party, the Personal Data it contains

maintain about its Users and Patients related to these assets will be one of the assets

transferred. If applicable, in such a case, the buyer acting in the capacity of the new

data controller must undertake to process your Data

Personal with at least the same level of protection and privacy that MIRAX employs, and




in accordance with this Privacy Policy;

● If we have the right or duty to disclose or share your Personal Data in a

to comply with a legal or regulatory obligation;

● To comply with or apply our Terms of Use that you have accepted;


● To protect your rights or for the safety of MIRAX, Users, patients or

MIRAX employees;

● If we have your express consent to do so.


Service providers

Sometimes we may make certain Personal Data available to trusted third parties to carry out

a series of activities on our behalf necessary to provide our Services, such as

third parties who assist and assist us in providing IT services, such as suppliers

platform, hosting services, maintenance and support for our databases, as well as

as well as our software and applications that may contain data about you. These services

They may sometimes involve access to your data to carry out necessary tasks.

We provide these third parties with only the information necessary to perform the service

in question and demand that they commit to the same level of protection and privacy as

your data that MIRAX would have if it had processed it directly, this includes the obligation not to

use your Personal Data for any purpose other than the purpose contracted by

MIRAX, in addition to confidentiality obligations and security standards, among others.


Third party links

The User may find third-party links on the Site to other websites controlled by third parties. A

MIRAX does not have the power to control the content provided by these other sites, nor is it

responsible for the processing of your Personal Data by those responsible for these websites.

Please remember that this Privacy Policy only applies to Personal Data processed by MIRAX

through the MIRAX Platform. Therefore, MIRAX is not responsible for any aspect

related to the processing of User Personal Data that may be carried out by

responsible for these third party websites.




If you consult the content of social networks through our Site (e.g. Google, Facebook,

Instagram, Twitter, LinkedIn, Vimeo, YouTube, etc.), a Cookie from that social network can be

stored on your device. We invite you to read the Cookies Policy of these social networks

for more information.

International Transfer

The data we collect about you may be transferred to, accessed from and/or

stored in a location outside Brazil. They may also be handled by employees outside the

Brazil, who work for one of our service providers.

We only transfer your Personal Data outside of Brazil securely and in

compliance with Applicable Data Protection Legislation. Most of the time, eventual

transfer will be made to countries or international organizations that provide a degree of

protection of personal data appropriate to the provisions of Applicable Legislation. As some countries

may not have adequate legislation regulating the processing and transfer

international Personal Data, we adopt measures to ensure that third parties

comply with the commitments established in this Policy. These measures may include analyzing

the privacy and security standards of third parties and/or the execution of contracts

appropriate, with specific clauses on the Processing of Personal Data.


Yes, we use cookies when you interact with us. These may be 'session' cookies, which

which means they are deleted when you leave our page or 'persistent' cookies,

that are not deleted and help us recognize you (even without identifying you) when you

return, so that we can provide a personalized service.

We use this data to understand and analyze trends, administer the site, track

User behavior, improve our products and services and collect information

demographic information about all of our Users. MIRAX may use this information for its

marketing and advertising services.

The main browsers used to access the web have options to refuse the

cookie storage and tools for controlling permissions and collecting data

Personal, such as private or anonymous browsing modes. If it is yours

interest, you can adjust your browser settings to decline and/or delete

Cookies. Your browser’s “Help” function should tell you how to do this.




Furthermore, there are several free extensions for browsers that allow you to block

personalized ads and tracking through cookies, MIRAX does not endorse or verify

any of these applications, your use being your sole responsibility.

Please note that by disabling cookies you may prevent some web services from working

correctly, affecting, partially or completely, your navigation.

Rights of Holders

We strive to ensure that your rights are respected and so we would like

let you know that:

● Our Services are designed to minimize the use of your Personal Data.

We only collect and use your data for the purposes that were previously informed

to you.

● The security of our servers is routinely checked by experts to

protect your data against unauthorized access.

● We do not retain your data in an identifiable format for longer than


● You, as a User of our services, can at any time:

● Request confirmation of the Processing of your Personal Data by MIRAX.

● Request access to your Personal Data at MIRAX.

● Request the portability of your Personal Data to another service provider.

● Request the correction of your Personal Data that is inaccurate, incomplete or


● Request the withdrawal of your consent to the Processing of your Personal Data

that are being processed based on your consent, or even the elimination of these

data at any time.

● Request the deletion of your Personal Data from MIRAX.

● Request information about the public and private entities with which MIRAX

shares your Personal Data.

● Request the anonymization, blocking or deletion of Personal Data considered




unnecessary, excessive or that are treated in non-compliance with Legislation


● Submit a complaint to the competent supervisory authority if you consider that MIRAX

is processing your Personal Data in violation of Applicable Legislation.

To request the exercise of any of these rights, simply send an email to the address with the name of the subject referring to the information you want more

clarifications (e.g. “access to my data”, “confirmation of the existence of treatment”, etc.),

get in touch: MIRAX LTDA, registered with the CNPJ under no. 44.957.236/0001-96, with headquarters at Rua

Groenlândia 135/801- Sion, CEP 30320-060, Belo Horizonte/MG.

We are always available to listen to you, whether on your health journey or for your health.


Modifications to this Policy

As stated at the beginning of this Policy, we may update this page periodically. In case of

significant changes, you will be notified, via the MIRAX Platform or via the email you

provided to us at the time of registration, at least 30 (thirty) days in advance. At

To the extent permitted by applicable law, use of our services after such notice amounts to

accept updates to this Policy.

We emphasize the importance of you periodically reviewing this Policy to obtain the

latest information about our data protection practices.

Questions and clarifications

If you are not satisfied with our responses to your complaints or if you feel that the

processing of your Personal Data does not comply with the Applicable Legislation of

Data Protection, send a complaint to the MIRAX PHOTO APP, belonging to JB

Cursos Ltda, qualified above, registered with the CNPJ under no. 44.957.236/0001-96, with headquarters at Rua

Groenlândia 135/801- Sion, CEP 30320-060, Belo Horizonte/MG and email address


We are glad that you have read our Privacy Policy.


If you agree with what you have read, feel free to start using our Services.

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