Medical Disclaimer — MyHealth

Version (policy_version): 1.3 Last updated: June 11, 2026 Effective: as of the date of publication on the App Store. Applies to: MyHealth, an iOS personal health-record app with an educational reading powered by artificial intelligence. Controller / Developer: BAS AI — BAS ARTIFICIAL INTELLIGENCE LTDA, CNPJ 64.106.409/0001-70 — www.bas-ai.com. Privacy contact / Data Protection Officer (DPO): privacy@bas-ai.com.

Please read this disclaimer carefully before using MyHealth. By using the app, you confirm that you have understood and agree to the limits described here.

1. What MyHealth is

MyHealth is a tool for you to organize, store, and understand your health information in one place. With it you can record and review exams and markers, conditions and body systems, medications (including the daily intake log), allergies, vaccines, appointments, vital signs and body composition (weight, body fat, blood glucose, blood pressure, heart rate), symptoms, complaints, physical activity, a daily wellness check-in, documents and reports, family history, and your care team. If you connect a wearable source (Apple Health/Apple Watch, Oura, or WHOOP), sleep, continuous metrics (resting heart rate, HRV, steps, energy), provider scores, and device events are also included.

MyHealth also offers an educational reading generated by artificial intelligence (AI) about the information you yourself enter, with the goal of helping you better understand your data and prepare to talk with healthcare professionals.

2. What MyHealth is NOT (important limits)

• MyHealth is not a medical device and must not be used as one.
• MyHealth does not make diagnoses, does not prescribe medications, exams, or treatments, and does not replace a consultation, evaluation, exam, or follow-up by a qualified healthcare professional.
• The AI educational reading is educational and informational. It may contain inaccuracies, be incomplete, or not apply to your specific case. It is not a clinical decision.
• The data and alerts coming from wearables are not a diagnosis: scores (such as Oura readiness or WHOOP recovery) are calculations by the manufacturer itself, displayed as the manufacturer reports them; device events (such as ECG classification, irregular-rhythm notification, or fall detection) are notifications from your device, which must be confirmed with a physician.
• The app's content does not create a doctor-patient relationship between you and BAS AI or any professional.

3. Always confirm with your physician

The information and analyses in MyHealth are meant to support your care, never to replace it. Before starting, stopping, or changing any medication, treatment, diet, exercise, or health practice — and before making any decision based on what you saw in the app — talk with your physician or another qualified healthcare professional. The professional knows your complete history and is the one who can assess your case.

4. In case of emergency

MyHealth does not handle emergencies and does not monitor you in real time. If you or another person shows warning signs — such as chest pain, shortness of breath, fainting, heavy bleeding, signs of a stroke, thoughts of self-harm, or any serious situation — seek medical care immediately or call your local emergency service (in Brazil, SAMU 192 or Fire Department 193 [TO CONFIRM — equivalent numbers per country/language]). Do not use the app for this.

5. About artificial intelligence (AI)

The educational reading, the extraction of information from exams, and the assistant chat use an AI model provided by Anthropic (Claude), which acts as a subprocessor under Anthropic's commercial terms (with a DPA and SCCs to be signed before launch — Section 5.1). This processing involves an international transfer of your data to the United States (Anthropic's infrastructure) — see Section 5.1. You should understand that:

• The AI processes only the content you provide and only if you authorize this purpose (optional consent, which can be revoked at any time).
• In the health-record analysis, we send the clinical content identifiable only by sex and age — without your direct identifiers (name, taxpayer ID, email, and phone, which are kept encrypted in a separate vault and are not sent to the AI). This content may include: exam markers and trends, measurements and body composition, medications, vaccines, allergies, symptoms, appointments and notes, family history, physical activity, sleep data and wearable scores, events from your device (ECG classification, irregular rhythm, fall), menstrual cycle and reproductive data, lifestyle habits you report (smoking, alcohol, activity, and sleep), and the blood type and notes from your emergency card. We do not send the contacts from your emergency card (name, phone, relationship).
• In the extraction of a document, we send the raw image/PDF that you submit, which may contain a name, taxpayer ID, and other identifiers printed on the report itself. Free-text notes may contain names — for this reason we recommend not entering identifying data in text fields.
• As for ECG events, we send and store only the classification (sinus rhythm / atrial fibrillation / inconclusive) and the event metadata — never the raw trace (waveform), which remains only on your device and is not sent to the AI.
• Your data is not used to train AI models. Anthropic retains the data for a limited period and then deletes it (as a rule, within 30 days), except for retention required by law or for abuse prevention.
• The AI may make mistakes: it may generate information that is incorrect, outdated, or that appears confident but is not. Treat the result as a starting point for a conversation with your physician, not as definitive truth.
• Web search exists only in the assistant chat, for general clinical knowledge. We instruct the model to use only generic clinical terms, without your values, dates, age, names, or identifiers. This protection is enforced by instruction to the model, not by an infallible technical filter, and the search is performed by Anthropic's infrastructure. The health-record analysis and document-extraction functions do not perform web searches.
• If you have a connected wearable and the AI authorized, the analysis may consider aggregated summaries of your wearable data (sleep, resting heart rate, HRV, steps, energy, and brand-identified scores) — never the device's raw continuous series.

5.1 International data transfer for AI processing

AI processing is performed by Anthropic, with infrastructure in the United States. When you authorize the AI, the content sent is subject to an international transfer of sensitive personal data outside Brazil and the European Economic Area (EEA).

• This transfer occurs only with your specific consent (purpose intl_transfer, tied to AI Processing), revocable at any time. Without your consent, none of your data is transferred to Anthropic and the AI functions remain unavailable.
• The transfer will be supported by standard contractual clauses (SCCs) to be entered into with Anthropic and by a Data Processing Agreement (DPA) to be signed, in addition to the commitment, under Anthropic's commercial terms, that your content is not used to train models and is retained for a limited period (as a rule, within 30 days).
• The storage of your health record remains on infrastructure in Brazil (Supabase); the transfer to the United States occurs only at the moment of processing by the AI.

Legal basis for the transfer: LGPD Art. 33, IX (specific and prominent consent) and Art. 9, II; GDPR Arts. 44-46 and Art. 49(1)(a) (explicit consent), with the transparency of Art. 13(1)(f).

6. You are responsible for the data you enter

The quality of the organization and of the educational reading depends on what you record. Incorrect, incomplete, or outdated information may lead to equally inaccurate readings. Keep your data correct and up to date, and always bring the original documents (exams, reports, prescriptions) to the healthcare professional.

7. Family sharing

Sharing with family members is optional, read-only, and revocable, activated by a mutual code with expiration. The same caveats in this disclaimer apply to anyone who views the shared data: viewing does not replace a medical evaluation.

8. No clinical warranties

BAS AI makes its best efforts to keep the app useful and safe, but, to the extent permitted by applicable law, MyHealth is provided "as is," without any warranty that the analyses are accurate, complete, or suitable for a specific clinical purpose. No information in the app should be interpreted as medical advice. [TO CONFIRM — extent of the limitation of liability according to jurisdiction and legal review.]

9. Minimum age and minors

Self-registration is for persons 18 years or older (or the age of majority of the country, if higher). The protection of children and adolescents observes the Statute of the Child and Adolescent (Law 8.069/1990), Law 15.211/2025 (Digital ECA), Art. 14 of the LGPD, and Art. 8 of the GDPR (EEA).

• The minor does not have their own account or email: they exist only as a managed profile within the account of an adult guardian, who manages the profile and is responsible for the person's care.
• The profile may have more than one guardian: the primary guardian invites another adult via an invitation code with an expiration date. Each invitee receives a role — guardian (views and edits) or companion (read-only). Every authorization is verified on the server, on each operation.
• The consent relating to the minor is recorded identifying which adult granted it.
• Paid AI features require the guardian role and are charged to the guardian (see Section 10); the usage record remains linked to the minor's profile for auditing.
• Wearable data never follows a minor's profile.

In any country, we adopt the single threshold of 18 years for one's own account. This requirement refers to account ownership and must not be confused with the GDPR's age of autonomous digital consent (Art. 8, between 13 and 16 years depending on the country). Below 18, data processing only occurs through a profile managed by an adult guardian.

Users in the United States (COPPA): MyHealth does not offer accounts to minors nor collect data directly from children. Any minor's data is entered and controlled by a responsible adult, who exercises verifiable parental consent.

10. Subscriptions, credits, and payments

The AI functions in MyHealth are paid and consume credits (as a rule, 1 credit = 1 page of an analyzed document). There is a subscription and the purchase of individual credits; new users receive an initial allowance of free credits, granted only once.

• All purchases are processed by Apple (App Store In-App Purchase), which acts as the merchant of record. BAS AI does not receive or store your card data.
• When an AI function is run on a dependent's (minor's) profile, the credits are debited from the account of the responsible adult who performs the action; the minor has neither a balance nor their own payment method.
• In Brazil, your right of withdrawal is preserved (Art. 49 of the CDC (Brazilian Consumer Protection Code)), within a period of 7 days. Cancellation and refund follow the App Store rules and the applicable consumer legislation; if in doubt, contact us at privacy@bas-ai.com «FOUNDER DECISION: refund channel when Apple denies withdrawal».

The complete details on pricing, renewal, cancellation, and refund are in the Terms of Use.

11. Your rights and how to contact us

You may, at any time and directly in the app (under Privacy), exercise your rights as a data subject: access, correct, export (FHIR and PDF), revoke consents, and delete your account (permanent, cascading removal of all clinical data and of the identity vault).

For questions, requests, or to exercise rights not available in the interface, contact our Data Protection Officer (DPO) at privacy@bas-ai.com.

Legal basis: LGPD Arts. 18 and 41; GDPR Arts. 12 to 22.

12. Updates to this disclaimer

We may update this Medical Disclaimer. When that happens, we will update the version and the date above and, when the change requires it, we will ask for a new acceptance within the app.

UI Consent Texts (registration and screens)

These texts are short by design, for direct use in the interface. The purposes already existing in the app (clinical_processing and ai_processing) are kept with the same technical labels; the others are additions for full coverage of granular consent. Each consent is recorded in a versioned way in the immutable ledger (consent_events), with purpose, legal basis, and policy version.

Privacy / consent screen (registration)

Title: Your privacy Subtitle: You control how your health data is used. You can review and revoke whenever you want.

Granular purposes

Note: family sharing (family_sharing), the international transfer (intl_transfer), and the wearable syncs (wearable_sync_apple_health / wearable_sync_oura / wearable_sync_whoop) are also purposes recorded in the ledger, captured at the moment the user enables the feature (not at initial registration) — wearable consents are recorded on the Integrations screen, before any reading or sync, on the dual basis LGPD_Art11+GDPR_Art9. The purpose apple_health_import, provided in a previous version of this document, has been replaced by wearable_sync_apple_health (the name actually recorded by the app).

Acceptance of Terms and Policy (required)

Acceptance checkbox text: "I have read and accept the Terms of Use and the Privacy Policy." (With tappable links to "Terms of Use" and "Privacy Policy.")

Supporting microcopy (below the checkbox): "To create your account, you must accept the Terms of Use and the Privacy Policy. You also authorize the processing of your health data to organize your health record (LGPD Art. 11 / GDPR Art. 9)."

Button state: the "Finish" / "Create account" button remains disabled until the acceptance checkbox is checked.

RE-ACCEPTANCE banner (when the terms change)

Title: We have updated our terms Body: "Our Terms of Use and Privacy Policy have changed (version 1.3). To keep using MyHealth, please read and accept the new version." Primary button: "Read and accept" Secondary button: "See what changed" Legal note: "Your previous acceptance remains on record. This new acceptance will be kept in a versioned way and does not change the optional choices you have already made."

Revocation and control notices (reused on the Privacy/Profile screens)

• Revoke AI: "You have turned off the AI educational reading. Your data is no longer sent to the AI from now on. The analyses already performed remain in your health record."
• Revoke Apple Health: "Syncing with Apple Health has been turned off. We will not read new data from Apple Health until you authorize it again. You can keep or delete what has already been imported."
• Disconnect Oura: "Your Oura ring has been disconnected and access to your Oura account has been revoked. What do you want to do with the data already imported from Oura?" — buttons: "Keep in health record" / "Delete Oura data".
• Disconnect WHOOP: "When you disconnect WHOOP, all data imported from WHOOP will be deleted from MyHealth — this deletion is required by WHOOP and cannot be undone. Your data remains in your WHOOP account." — button: "Disconnect and delete".
• Control reminder: "You can review, export (FHIR and PDF), correct, revoke consents, and delete your account at any time under Privacy."

Open items (legal review)

See the list in open_items.