Legal document
Privacy Policy
Courtesy translation. This is an English translation of the Brazilian Portuguese Política de Privacidade, provided for convenience. If there is any difference between the versions, the Portuguese version prevails. MinhaDoula is operated from Brazil and processes personal data under the Brazilian General Data Protection Law (LGPD — Law No. 13,709/2018).
1. Who we are and who the controller is
MinhaDoula is a software-as-a-service (SaaS) platform for doulas and, when invited by the doula, for pregnant clients, to organize care, schedule, communication, content, documents and financial routines related to the doula's professional practice.
For the purposes of the LGPD, MinhaDoula acts as the controller of the personal data processed for platform sign-up, service subscription, the waitlist, support and the operation of the website and associated systems.
Privacy contact:
suporte@minhadoula.com.br
Website: minhadoula.com.br
The doula's role: when the doula enters information about clients, partners or third parties on the platform, she may act as an independent controller or joint controller of that data, depending on the purpose and context of processing. The doula is responsible for obtaining the necessary authorizations and for informing the people she supports about the use of the platform. MinhaDoula provides the technology infrastructure and processes the data according to contractual instructions and this Policy.
2. Scope and acceptance
This Policy applies to:
- visitors to the public website and public pages;
- people who join the waitlist or request contact;
- doulas who create an account, subscribe to plans and use the professional dashboard;
- clients invited to access the client portal;
- interactions by email, forms, APIs and support channels linked to MinhaDoula.
By using our services, you declare that you have read this Policy and the Terms of Use. If you do not agree, do not use the platform.
3. Definitions
- Personal data: information related to an identified or identifiable natural person.
- Sensitive data: data on racial or ethnic origin, religious belief, political opinion, union membership, data concerning health or sex life, genetic or biometric data, when linked to a natural person.
- Data subject: the natural person to whom the personal data refers.
- Processing: any operation with personal data, such as collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation, control, modification, communication, transfer, dissemination or extraction.
- Controller: the natural or legal person responsible for decisions about the processing of personal data.
- Processor: the natural or legal person who processes personal data on behalf of the controller.
- Data protection officer (DPO): the person appointed by the controller to act as the communication channel between the controller, data subjects and Brazil's National Data Protection Authority (ANPD).
4. Data we process
Depending on your relationship with MinhaDoula, we may process the categories below:
4.1. Sign-up and identification data
- full name or display name;
- email address;
- password (stored encrypted — never in plain text);
- user type (doula or client);
- Brazilian tax ID (CPF), when provided;
- phone;
- date of birth;
- address (postal code, state, city, street and number), when provided.
4.2. Authentication and security data
- email verification tokens;
- session identifiers and authentication cookies;
- login records, access attempts and security events, including failed attempts (without storing the email typed or the password);
- sessions open in the browser or app (start, last activity, end and reason), identified by a derived code (never the session identifier itself);
- identifiers and metadata of social login via Google OAuth, when you choose that method.
4.3. Platform usage data
- account preferences, plan and subscription status;
- browsing records, clicks, screens accessed and interactions with features;
- access trail (audit): for each screen opened, personal data query, download, print, export or change made on the website, portal or app, we keep who accessed (the account), when, which screen or feature (by an internal code, without the typed address), the internal identifier of the record accessed (for example, the pregnancy), the result (allowed, denied or error), the IP address, the browser or device and the app version. The trail does not keep the content of screens, messages, records or typed values, and does not record passwords, verification codes or access keys;
- technical device and browser data (IP address, operating system, language, time zone);
- API logs, errors and diagnostics for service stability;
- on the Premium plan and the free trial, the content the doula chooses to publish in the Community (@, description, text, images, comments, likes, saved items, who she follows and reports made or received) and on the Blog (title, text, cover and category of posts). The Community is visible to the platform's doulas; the Blog, when on, is public on the doula's directory page. This data is deleted when the account is deleted and is included in your data export.
4.4. Care and health data (entered by the doula or the client)
- pregnancy information (LMP, due date, weeks, history);
- intake form, birth plan, care notes and non-medical clinical records;
- checklists, shared content, attachments and documents;
- chat messages between doula and client;
- contraction records, monitoring and configured alerts;
- data about meetings, sessions, attachments and support materials.
4.5. Financial data
- the doula's subscription history with MinhaDoula;
- billing identifiers, invoices and payment status processed by payment providers;
- for those who pay by Pix or boleto (Brazil): name, email and the payer's CPF or CNPJ (required by the provider to issue the charge) and the charge data (amount, due date and payment status). The document typed on the payment screen is sent to the provider and is not stored by MinhaDoula: we keep only an irreversible cryptographic fingerprint of it, used to prevent fraud (for example, self-referral in “Refer and earn”). If you have already provided the same document in your profile or contract details, it remains in those records;
- on the Premium plan, client → doula billing data through a payment integration (e.g. Stripe Connect), as enabled;
- payment keys and manual entries provided by the doula on plans without integrated checkout.
4.5.1. Doula directory profile
On plans that include the doula directory (Showcase, Premium and during the trial), the doula chooses to publish her profile in the directory. The following become public, by her choice: name, photo, city and state, WhatsApp and Instagram provided, introduction, services and blog articles. The doula can change or remove this data at any time (by turning off “I want to appear” or editing the profile); when she stops appearing, the page leaves the search. Clients who contact the doula via WhatsApp or Instagram do so directly with her.
4.6. “Refer and earn” program
An optional program, currently available in Brazil, in which a doula refers MinhaDoula to other doulas and, from the announced start date, may receive a commission on the referrals' subscriptions (Rules, in Portuguese). To operate it we process:
- from the referring doula: her own code and link, whether the partnership is on, off or suspended, the date and version of the accepted rules and, when commissions and payments are enabled, payout data (person type, document and Pix key) and the history of commissions and payouts, with the Pix receipt when there is one;
- from the referred doula: who referred her, through which channel (link, typed code or app) and when, and the sign-up's anti-fraud security signals: the IP address stored only as an irreversible code (HMAC), never in plain text, whether the email is similar to the referring doula's, CPF or phone identical to hers and, on the first payment, a card fingerprint stored only as an irreversible code (HMAC), never the card number, used to prevent the doula from earning a commission on her own payment;
- what the referring doula sees about each referral: the first name and initial of the last name, the partially hidden email, the sign-up date, the plan, the subscription status (on trial, paying, late, canceled) and the dates and amounts of payments that generate commission. She does not see payment method, CPF, phone, address or any client data. The referral is told about this on the sign-up screen.
4.7. Waitlist and communications
- name and email provided on the waitlist;
- communication preferences and history of transactional or marketing messages, when authorized.
Data we do not require: unnecessary documents, full bank details outside the payment flow, or clinical information not relevant to the care offered by the doula.
5. Purposes and legal bases
We process personal data for specific purposes, based on the legal grounds of the LGPD:
| Purpose | Examples of data | Legal basis (LGPD) |
|---|---|---|
| Create and manage accounts | name, email, password, user type | Performance of contract and preliminary procedures (art. 7, V) |
| Authenticate and protect access | session, tokens, login records | Performance of contract; legitimate interest in security (art. 7, IX), with balancing |
| Keep the access trail (audit): record who accessed what, when and from where | account, screen or feature accessed, internal record identifier, result, IP address, browser or device, app version | Compliance with legal obligations on access records (art. 7, II of the LGPD and art. 15 of Brazil's Internet Civil Framework); legitimate interest in security, fraud prevention and accountability (art. 7, IX), with documented balancing; regular exercise of rights in proceedings (art. 7, VI); and, when the record shows access to health data, fraud prevention and the data subject's security (art. 11, II, “g”) and regular exercise of rights (art. 11, II, “d”) |
| Operate dashboard and portal features | clients, schedule, chat, attachments | Performance of contract; consent of the data subject or client, when applicable |
| Process subscriptions and payments, including card, Pix and boleto | plan, invoices, transaction IDs and charge data (amount, due date and status) | Performance of contract; compliance with legal/tax obligations (art. 7, II and VI); legitimate interest in fraud prevention (art. 7, IX) |
| Operate the “Refer and earn” program: record who referred whom, follow the referrals' status, calculate and pay commissions and prevent fraud (self-referral, fake accounts) | code, referral and date, subscription status and amounts paid by the referral, payout data of the referring doula, IP address as an irreversible code (HMAC) | Performance of contract and of the program's procedures, which the doula joins by free choice (art. 7, V); legitimate interest in preventing fraud and informing the referring doula about the referral's progress, with minimization of the data shown (art. 7, IX); compliance with legal and tax obligations on payments (art. 7, II) |
| Send transactional communications | verification email, billing notices, alerts | Performance of contract; legitimate interest (art. 7, IX) |
| Waitlist and product news | name, email | Consent (art. 7, I) or legitimate interest, depending on context |
| Prevent fraud and abuse | IP, logs, usage patterns | Legitimate interest (art. 7, IX) and credit protection, when applicable |
| Comply with legal obligations | records required by law | Legal/regulatory obligation (art. 7, II) |
| Improve the product and support | aggregated metrics, tickets | Legitimate interest (art. 7, IX), with minimization |
When the basis is consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before, subject to the technical and legal limitations for ending the service.
6. Sensitive health data
Intake forms, birth plans, care notes, monitoring and pregnancy-related attachments may constitute sensitive personal data in the health category, under art. 5, II, and art. 11 of the LGPD.
For this data, we adopt reinforced measures:
- per-account isolation (
ContaId) applied to every database query; - sharing with the client only when the doula enables connected mode or the invited portal;
- recording of consent and acceptance date, when applicable;
- file storage outside the server's public folder, served only through an application route and with a file name we generate;
- logging of authentication and account events, and the rule of never writing clinical content or message bodies to logs;
- deletion upon request, analyzed case by case according to section 9 and the Terms of Use (§9).
Important: MinhaDoula does not replace a clinical record, hospital system or official medical record. The platform supports the organization of doula care and communication between professional and client.
The grounds for processing sensitive data include, as applicable: specific and highlighted consent (art. 11, I), performance of a contract between data subject and controller (art. 11, II, when applicable) and protection of life or physical safety in emergencies (art. 11, V), always in compliance with the law and good practices.
7. Sharing and processors
We may share personal data in the situations below, always with a contractual basis and security measures:
7.1. Service providers (processors)
- Hostinger — website hosting and infrastructure;
- Google — OAuth authentication and, when enabled, calendar integrations;
- Stripe — processing of SaaS subscription card payments and, on Premium, client → doula charges through Connect;
- Asaas (Asaas Gestão Financeira S.A.) — a Brazilian partner Payment Institution that provides the financial services MinhaDoula uses: issuing and reconciling subscription charges by Pix and boleto. It receives the payer's name, email and CPF or CNPJ, the amount and due date, and processes this data according to its own privacy policy and the Central Bank of Brazil regulations applicable to payment institutions;
- Email providers — sending transactional messages (SMTP or email API);
- Public address and city lookups (ViaCEP and IBGE in Brazil; the U.S. Census Bureau's public data for the United States) — address lookup from the postal code and, in the doula directory, the list of cities in each state — done in the browser or from public files, when you enter the postal code or choose the state.
7.2. Other cases
- in the “Refer and earn” program, the referring doula sees about each referral only what is described in section 4.6 (first name, partial email, plan, subscription status and amounts paid);
- compliance with a court order, request from a competent authority or legal obligation;
- protection of the rights of MinhaDoula, users or third parties, in legal or administrative proceedings;
- corporate transactions (merger, acquisition, reorganization), with prior notice when required by law;
- with your express authorization or the doula's authorization, within the invited portal.
We do not sell personal data. We do not share client data with other doulas or accounts without express authorization in the product.
8. International transfer
Some providers used by MinhaDoula may process data on servers located outside Brazil (for example, the United States or the European Union), especially for cloud, authentication and payment services. For users in the United States, data is processed in Brazil and with these providers.
When there is an international transfer, we adopt safeguards provided for in the LGPD, such as standard contractual clauses, verification of an adequate level of protection, specific consent or other applicable legal grounds, seeking to ensure a level of protection compatible with Brazilian law.
9. Retention and deletion
We keep personal data only as long as necessary for the purposes described in this Policy, observing:
- Active account: for as long as the contractual relationship and use of the service last;
- After subscription cancellation: a retention period for backup, disputes, tax obligations and defense in proceedings, generally up to 5 (five) years, unless a longer legal obligation applies;
- Security and audit logs (access trail): periods proportional to the purpose, which are the maximum retention limit: 180 days for opening common screens and for write actions; 2 (two) years for denied access and failed login attempts; up to 5 (five) years for records of access to financial and clinical screens, which keep only metadata (never the content), to allow defense in a possible dispute and proof of who accessed what; and 1 (one) year for the session record itself. The full IP address is kept for 180 days; after that it is anonymized (IPv4 without the last number; IPv6 only the prefix) and the record continues until the end of its category's period. When the account is deleted, the IP, browser and device name are removed from the trail; the rest (who, when, which screen) remains for the period, as security evidence;
- “Refer and earn” program: the referral and the records of commissions and payouts (with Pix receipts) stay for the account's retention period (generally up to 5 (five) years, for tax obligations and defense in proceedings); the IP address and the card from sign-up and payment exist only as an irreversible code, payout data (document and Pix key) is encrypted and deleted when the doula requests account deletion, except what the law requires to keep;
- Pix and boleto payments: account deletion cancels the recurring charge and removes your customer record at Asaas; tax and payment records stay for the legal period. Your data export includes the Pix or boleto subscription, the plan status history and due-date notices, without the document number;
- Waitlist: until the product launch or until a removal request.
9.1. Ending the doula ↔ client connection
When connected care (invited portal) ends, the client's access to the doula's portal stops immediately. The care record, the history of the closed chat and the financial entries linked to the client in the doula's account may be kept for up to 5 (five) years, counted from the end of the connection or from the last record or message related to that client, whichever is later, for documenting the care and exercising rights, unless deleted earlier when applicable or a longer legal period applies.
Metadata of completed invitations and connection requests may be kept for up to 2 (two) years after the request is concluded. If doula and client connect again and there are new records, the period restarts for that care.
After the periods, data will be deleted or anonymized when technically possible. The contractual details are in section 9 of the Terms of Use.
9.2. Data subject requests
You may request access, correction, portability or deletion of data under art. 18 of the LGPD. Deletion may be limited when there is a legal obligation to keep data, ongoing litigation or a technical need for anonymization instead of immediate deletion. The doula can download, at any time, a copy of her data and work records in Settings → Export my data (a ZIP file with JSON and spreadsheets). MinhaDoula does not yet offer an automatic download for the client when the connection ends; the client should save what she needs before confirming, or ask the responsible doula or support (suporte@minhadoula.com.br) for a copy.
10. Data subjects' rights
Under the LGPD, you may request from the controller:
- confirmation that processing exists;
- access to the data;
- correction of incomplete, inaccurate or outdated data;
- anonymization, blocking or deletion of unnecessary or excessive data or data processed in non-compliance;
- portability of the data to another service or product provider, subject to commercial and industrial secrets;
- deletion of personal data processed based on consent;
- information about public and private entities with which we share data;
- information about the possibility of not giving consent and the consequences of refusal;
- withdrawal of consent.
To exercise your rights, email suporte@minhadoula.com.br with the subject “LGPD — data subject request”, stating your name, registered email and a description of the request. We may ask for additional information to confirm your identity.
Clients whose data was entered by a doula may also contact the responsible doula and, in parallel, MinhaDoula for technical support in locating and handling the request within the platform.
You have the right to file a complaint with Brazil's National Data Protection Authority (ANPD) if you believe your rights were not properly addressed. People in the United States may also contact the authorities of their state.
12. Information security
We adopt technical and administrative measures to protect personal data against unauthorized access, destruction, loss, alteration, communication or improper dissemination. Additional details are on the Security page.
Who sees the access trail: only MinhaDoula's administration team, through a restricted screen, with a limited period and pagination. Each query and each export of the trail is recorded, and exporting requires a justification. Doulas and clients have no access to other people's trails. Access records are kept confidential, in a controlled and secure environment, and are only provided to third parties or authorities by court order or legal obligation.
No system is 100% immune to risk. In case of a security incident with relevant risk or harm to data subjects, we will notify those affected and the ANPD as required by law.
13. Children and adolescents
MinhaDoula is intended for people over 18 (doulas) and pregnant clients who are of legal age or emancipated. We do not knowingly collect children's data to create their own accounts.
Information about newborns or children may be recorded by the doula in the context of pregnancy care, based on the professional relationship and the applicable authorizations.
14. Changes to this policy
We may update this Policy to reflect legal, regulatory or product changes. The current version will always be published on this page, with the update date at the top.
Relevant changes may be communicated by email or a highlighted notice on the platform. Continued use after publication constitutes awareness of the new version, unless the law requires new consent.
15. Contact and data protection officer
For questions, data subject requests or privacy matters:
- Email: suporte@minhadoula.com.br
- Data protection officer (DPO): the same channel above, with the subject “LGPD Officer”
- Website: https://minhadoula.com.br
We will respond within a reasonable time, observing the applicable legal deadlines and the complexity of the request.