Privacy Policy
This policy describes how FRC Consultores Associados LTDA (FRC), user institutions, and the Precepte product process personal data of users (residents, preceptors, coordinators, and other institutional roles) in the app and on the web, including the public institution signup. Precepte is a free educational and administrative management tool for medical residency programs and does not process patient clinical data.
1. Data-processing roles
- FRC as controller: FRC controls the data required for institution signup, account creation and security, abuse prevention, support, and compliance with its own legal obligations.
- User institution as controller: the institution defines the purposes and governance of academic and administrative data, including schedules, attendance, evaluations, policies, and program communications.
- FRC as processor: FRC processes academic and administrative data on behalf of the user institution, under the Terms of Use, institutional instructions, and applicable access controls.
2. Categories of data collected
- Identity and contact: name, email, phone, profile photo (optional), account identifiers.
- Academic/professional data: medical license ID (CRM), enrollment, specialty, program, unit, role (RBAC).
- Product usage: schedules, attendance/time clock (including location when the user checks in), pedagogical evaluations, messages, and technical metadata required to operate the service.
- Device and notifications: push tokens (FCM), session data, and security audit trails.
3. Institution signup
When a person signs up an institution through the website or the app, we collect:
- About the institution: name, city and state (UF), institution type (optional), approximate number of residents (optional), and unit names.
- About the person responsible for the signup: name and email. No password is entered in the form; it is set through the link sent to the email address.
- Acceptance record: date and time, version of the Terms of Use and of this policy, and the language in which they were presented.
- The chosen language, also used for the signup emails.
The signup does not ask for a phone number or job title. The phone number is requested later, in the app, for SMS code verification of accounts with administrative privileges.
Abuse prevention: to limit repeated attempts, we use cryptographic digests (SHA-256 hashes) of the email address provided and of the IP address the request comes from. In Precepte’s rate-limiting records, the email address and the IP address appear only as hashes; the signup audit event keeps the email hash and does not keep the IP address. We also verify the integrity of the website or app (Firebase App Check) and reject email addresses from known disposable domains. Technical logs of the hosting infrastructure may contain the IP address of requests, as with any web service.
4. Purposes
- Sign up the institution and create the first administrator account.
- Authenticate users and enforce multi-institution isolation (multi-tenancy).
- Operate schedules, attendance, evaluations, and communications for the residency program.
- Prevent abuse, fraud, and automated signups.
- Meet institutional, security, and audit obligations.
- Improve product stability and technical support.
5. Legal basis (LGPD)
FRC processes data under its responsibility based on the performance of the Terms of Use accepted at signup (performance of a contract, LGPD art. 7, V) to create and maintain the account and the institution’s signup, provide support, and keep the service secure; on legitimate interest (art. 7, IX) to prevent abuse and fraud in the public signup, using email and IP hashes, disposable-domain blocking, and app integrity checks; and on compliance with its own legal obligations (art. 7, II). The user institution defines the legal bases applicable to academic and administrative data under its governance. Data minimization and role-based access controls (RBAC) apply in all cases.
6. Sharing
- With the institution the user is linked to (coordination and authorized roles).
- With infrastructure providers (e.g. Google Firebase/Auth/Firestore/Hosting/Cloud Functions) under data-processing terms.
- We do not sell personal data. We do not share data with advertisers for third-party marketing.
7. Retention
- Active profile data: while the account remains linked to the program.
- Signup requests: the processing queue is deleted right after processing; unprocessed requests expire after 24 hours and are deleted automatically.
- Institution signup record (institution name, city/state, type, approximate number of residents, units, name and email of the person responsible, email hash, terms version, and language) and acceptance record (with the name and email of the person who accepted): kept while the institution remains registered, to evidence the signup and the acceptance.
- Abandoned signups: when the administrator account created through the public signup never sets its password, the person responsible may ask support to delete the signup and the personal profile data. Audit records are kept.
- Operational audit logs: typically 2 years.
- Critical institutional audit events (e.g. account deletion, role changes): up to 10 years, for accountability.
- Educational artifacts (schedules, evaluations, attendance) may remain with the institution under program policy, without profile PII after account deletion.
8. Account deletion
You may request deletion of your own account by emailing suporte@precepte.com.br (include the account email and institution). When self-service is available in your app version, also use Perfil → Excluir minha conta (current in-app label; product UI is Portuguese). After confirmation, FRC closes access, revokes tokens, and removes or anonymizes personal profile data. Records the controller institution must retain remain under its governance, without personal profile data where possible, for the purposes and periods described in this policy.
9. Data subject rights
For signup, account, security, and support data controlled by FRC, request access, correction, portability (where applicable), information about sharing, or deletion via suporte@precepte.com.br or the in-app flow. For academic and administrative data, also contact the controller institution. If the responsible party is unclear, FRC will route the request to the appropriate channel.
10. Security
We apply Firebase authentication, institution/role access rules, backend input validation, and audit trails. No system is risk-free; we report relevant incidents as required by law.
11. Controller and processor contacts
FRC Consultores Associados LTDA — Brazilian Tax ID (CNPJ) 22.052.463/0001-30 — Recife-PE, Brazil
Product: Precepte — precepte.com.br
FRC email for account, security, support, and rights: suporte@precepte.com.br
Legal notice: frcconsultores.com.br/en/impressum
Academic/administrative data: the user institution linked to the user.
Support page: precepte.com.br/en/support/
12. Changes
We may update this policy. The effective date at the top indicates the current version. Material changes will be communicated in the product or by email when appropriate.