Brazil · Legal
Terms and Conditions
Version 2 · Last updated 18 July 2026
Effective Date: 1 July 2026
| Operator | Global Guest s.r.o. trading as Global Health |
|---|---|
| Czech Company No. | IČO: 19071680 |
| Registered Office | Rybna 24, 110 00 Prague 1 |
| Website | www.myglobalhealth.online |
| Contact | globalhealth@myglobalhealth.online |
| Effective Date | 1 July 2026 |
| Operating Markets | See www.myglobalhealth.online/markets |
These Master Terms govern use of the Global Health platform across all markets in which Global Health operates. They must be read together with the Country Addendum for the specific market in which you are accessing the Services. In the event of any conflict between these Master Terms and a Country Addendum, the Country Addendum prevails.
The full list of markets in which Global Health operates can be seen at www.myglobalhealth.online.
1. About Us
Global Health is a telemedicine platform operated by Global Guest s.r.o., a limited liability company incorporated in the Czech Republic (IČO: 19071680; registered office: Rybna 24, 110-00 Prague 1. Global Health operates in a number of markets, details of which can be find at www.myglobalhealth.online.
Depending on the market in which you access the Services, Global Health operates either as a registered healthcare provider or as a technology platform connecting patients with independently registered Clinicians. The applicable operating model for your market is set out in the Country Addendum.
References in these Terms to "we", "us", or "our" are to Global Guest s.r.o. trading as Global Health. References to "you" or the "Patient" are to any individual who accesses or uses the Platform or Services.
Our primary contact details are:
- Email: globalhealth@myglobalhealth.online
- Website: www.myglobalhealth.online
Country-specific contact details, addresses, and regulatory registration numbers are set out in the applicable Country Addendum.
2. Definitions
In these Master Terms and in any Country Addendum, the following terms have the meanings given below:
- "Platform" means the Global Health website at www.myglobalhealth.online, any associated mobile applications, and any booking, consultation, or patient management systems operated by or on behalf of Global Health.
- "Services" means online medical consultations, specialist referrals, prescription services, home health tests, prescription delivery, Credit Plans, and any other healthcare-related services made available through the Platform.
- "Patient" or "you" means any individual who registers for, books, or uses the Services.
- "Clinician" means a doctor, specialist, nurse, or other regulated healthcare professional who delivers consultations or clinical services through the Platform, registered with the relevant medical regulatory authority in the country in which they practise.
- "Consultation" means a remote medical consultation conducted via video call, telephone, or secure messaging through the Platform.
- "Provider Model" means the operating model applicable in markets where Global Health holds a healthcare provider registration and delivers Services as a regulated healthcare provider. In Provider Model markets, Clinicians practise under Global Health's provider registration.
- "Platform Model" means the operating model applicable in markets where Global Health acts as a technology intermediary connecting patients with independently registered Clinicians. In Platform Model markets, each Clinician holds their own regulatory registration and delivers Services in their own right.
- "Credit Plan" means a recurring monthly subscription through which a Patient receives a defined number of Credits each billing cycle to be used towards Services, as further described in Clause 7.
- "Credit" or "Credits" means the unit of value issued to a Patient under a Credit Plan or purchased on a one-off basis, redeemable against eligible Services on the Platform.
- "Country Addendum" means the country-specific supplement to these Master Terms applicable to the market in which you are accessing the Services, which specifies among other things the applicable operating model, governing law, regulatory registration details, and consumer rights.
- "Applicable Data Protection Law" means the data protection and privacy legislation in force in your jurisdiction, including where applicable: GDPR (Regulation (EU) 2016/679); UK GDPR and the Data Protection Act 2018; and equivalent legislation in non-EU markets as specified in the applicable Country Addendum.
- "Health Data" means any personal data relating to the physical or mental health of an individual, including data about the provision of healthcare services to that individual, which is classified as sensitive or special category data under Applicable Data Protection Law.
- "Consumer Protection Law" means the mandatory consumer protection legislation applicable in your country of residence, which cannot be excluded or limited by these Terms regardless of any choice of law clause.
3. Acceptance of Terms
By accessing or using the Platform or Services, you confirm that you have read, understood, and agree to be bound by these Master Terms, the applicable Country Addendum, our Privacy Policy, and our Cookie Policy.
If you do not agree to these Terms, you must not access or use the Platform or Services.
These Terms are available at all times at www.myglobalhealth.online/terms. We recommend that you save or print a copy for your records.
4. Eligibility and Registration
4.1 Age requirement
You must be at least 18 years of age to register for or use the Services independently. The minimum age may be higher in certain jurisdictions — please refer to your Country Addendum. Patients under the applicable minimum age may only access the Services with the active participation and written consent of a parent or legal guardian, who accepts these Terms on their behalf and takes responsibility for the accuracy of all information provided.
For any consultation involving a minor, the parent or guardian must be present or immediately available during the consultation unless the Clinician determines otherwise in the clinical interest of the patient.
4.2 Accuracy of information
You must provide accurate, complete, and current information during registration and throughout your use of the Services. Providing false or misleading medical information to a Clinician may compromise the quality of care you receive and may constitute an offence under applicable law.
4.3 Account security
You are responsible for maintaining the confidentiality of your account login credentials. You must notify us immediately at globalhealth@myglobalhealth.online if you become aware of or suspect any unauthorised access to your account.
4.4 One account per patient
Each patient may hold one active account. Creating multiple accounts to circumvent any restriction, suspension, or ban is prohibited and may result in termination of all associated accounts.
5. Nature of the Services and Clinical Limitations
5.1 Operating models
The way in which Global Health delivers Services differs by market. In some markets Global Health operates as a registered healthcare provider. In others it operates as a technology platform connecting patients with independently registered Clinicians. The model applicable to your market, and its implications for regulatory oversight, complaints, and liability, is set out in the applicable Country Addendum. These Master Terms apply in full regardless of the operating model.
5.2 Telemedicine limitations
Our Services provide remote medical consultations and are not a substitute for in-person care where that is clinically appropriate. A Clinician conducting a remote consultation has limited ability to perform physical examinations. Diagnosis and clinical advice are based on the information you provide, your medical history as recorded on the Platform, and clinically appropriate remote assessment techniques.
You acknowledge that the quality and accuracy of clinical advice may be affected by the completeness and accuracy of the information you provide.
5.3 Emergency situations
IMPORTANT: Our Services are not suitable for medical emergencies. If you or someone else is experiencing a medical emergency, call emergency services immediately and attend your nearest emergency department. Do not use this Platform in a medical emergency.
Emergency contact numbers for each market are listed in the applicable Country Addendum and on the relevant country page of the Platform.
5.4 Prescriptions
Prescriptions are only issued where clinically appropriate and where permitted under the law of the country in which the patient is located at the time of consultation. Prescriptions are issued by Clinicians who hold current registration with the relevant medical regulatory authority in their country of practice. The name, registration number, and regulatory body of the prescribing Clinician are available on request and disclosed in your consultation record.
Prescriptions for controlled or restricted substances are not issued through the Platform. Country-specific prescription rules — including the regulatory frameworks governing digital prescriptions, applicable formularies, and cross-border validity — are set out in the applicable Country Addendum.
5.5 Cross-border prescription validity
A prescription issued by a Clinician in one country may not be valid or accepted by pharmacies in another country. It is the patient's responsibility to verify the validity of any prescription in the country where they intend to use it. Global Health does not guarantee that prescriptions issued through the Platform will be accepted outside the country of issue.
5.6 Referrals
Where clinically indicated, a Clinician may recommend referral to an in-person specialist or emergency facility. Global Health does not guarantee the availability, cost, waiting time, or clinical outcome of any third-party referral or in-person service.
5.7 No guaranteed outcomes
We cannot and do not guarantee specific clinical outcomes. Services are provided on the basis of professional clinical judgment applied to information available at the time. Individual results will vary.
5.8 Service availability
We aim to maintain platform availability at all times but do not guarantee uninterrupted access. Scheduled maintenance, technical issues, or circumstances beyond our control may result in temporary unavailability. Where a consultation cannot proceed due to platform unavailability, any Credits used to book that consultation will be reinstated to your account, and you will be offered a rescheduled appointment.
5.9 Clinical governance
Regardless of the operating model applicable in your market, Global Health maintains a clinical governance framework covering the quality and safety of Services delivered through the Platform. All Clinicians operating through the Platform are required to hold current registration with the relevant medical regulatory authority in their country of practice and to maintain appropriate professional indemnity or liability insurance.
The scope of Global Health's governance responsibilities and the applicable regulatory oversight in your market are set out in the Country Addendum.
5.10 Geographic restrictions
Services are only available in markets where Global Health operates. The current list of markets is seen at www.myglobalhealth.online. Accessing the Platform from a country in which Global Health does not operate does not entitle you to receive Services in that country.
5.11 Third-party technology
The Platform uses third-party technology providers for booking, payment processing, video consultation, and data storage. Whilst we take reasonable steps to select reliable providers, we are not liable for disruption or failure caused by third-party systems beyond our reasonable control.
6. Booking, Payment, and Pricing
6.1 Booking
Consultations may be booked through the Platform using Credits or by direct payment where applicable. A booking is confirmed when you receive an email confirmation from us. Booking confirmation does not guarantee a specific Clinician unless expressly stated at the time of booking.
6.2 Pricing and currency
All prices and Credit values are displayed in the currency applicable to your market, inclusive of any applicable taxes or levies. Current pricing for all Services and Credit Plans is published on the Platform's Pricing page and on each individual service page. The price applicable to your booking or Credit purchase is the price confirmed at the time you complete the transaction.
Where you access Services in a currency different from that of your payment card, your bank or card provider may apply exchange rate charges. Global Health is not responsible for any such charges.
We reserve the right to amend pricing at any time with reasonable notice. Price changes will not affect Credit Plans already active at the time of the change until the next billing cycle, and will not affect individual bookings already confirmed.
6.3 Payment
Payment is required in full at the time of booking or Credit purchase. We accept the payment methods displayed on the Platform at the time of transaction. All payments are processed securely by our payment provider. We do not store full payment card details on our systems.
6.4 Taxes
Prices displayed are inclusive of applicable local taxes where we are required to charge them. In certain jurisdictions, local taxes or levies applicable to digital health services may vary. Please refer to your Country Addendum for details.
7. Credits and Credit Plans
7.1 How Credits work
Credits are the unit of value used to book and access Services on the Platform. Credits may be obtained by: (a) subscribing to a Credit Plan, under which a defined number of Credits is issued to your account at the start of each monthly billing cycle; or (b) purchasing Credits on a one-off basis at the prices published on the Platform.
The Credit value of each Service is displayed on the relevant service page and at the time of booking. Credit values may be updated from time to time; the Credit value applicable to your booking is the value confirmed at the time you complete the booking.
7.2 Credit Plan subscriptions
Credit Plans are billed monthly on a rolling basis. There is no minimum contract term and no lock-in period. You may cancel your Credit Plan at any time — see Clause 7.5.
Credits issued under a Credit Plan are allocated to your account at the start of each billing cycle. Unused Credits roll over to the next cycle, subject to a maximum carry-forward limit published on the Platform. Credits do not expire whilst your Credit Plan remains active.
7.3 One-off Credit purchases
Credits purchased on a one-off basis outside of a Credit Plan do not expire and may be used at any time. One-off Credits are consumed before Credit Plan Credits when booking Services.
7.4 Non-refundable Credits
Credits are generally non-refundable once purchased, except as set out in these Terms or as required by applicable Consumer Protection Law in your jurisdiction. Credits have no cash value and may not be transferred to another patient account.
7.5 Credit Plan cancellation
You may cancel your Credit Plan at any time through your account settings or by contacting us at globalhealth@myglobalhealth.online. Cancellation takes effect at the end of the current monthly billing cycle. You will retain access to your allocated Credits and Plan benefits until the end of the paid period. No partial refund is issued for any unused portion of the current billing cycle, unless required by applicable Consumer Protection Law.
Following cancellation, Credits already allocated under the cancelled Plan remain available in your account for 12 months from the cancellation date, after which unused Plan Credits expire. One-off Credits are unaffected by Plan cancellation.
7.6 Cancellations, rescheduling, and Credit reinstatement
If you cancel a confirmed booking at least 24 hours before the scheduled appointment time, any Credits used to make that booking will be reinstated to your account in full.
Cancellations made less than 24 hours before the appointment will result in the Credits being forfeited, except where the cancellation is due to a documented medical emergency or a platform-side failure, in which case Credits will be reinstated.
You may reschedule a confirmed appointment up to 12 hours before the scheduled time, subject to Clinician availability, without incurring any Credit charge. Each booking may be rescheduled once without charge. Further rescheduling requests may be treated as a cancellation under this clause.
7.7 No-show
If you fail to attend a scheduled consultation without prior cancellation or rescheduling notice, the Credits used to book that consultation are forfeited. No reinstatement will be made for a no-show.
7.8 Cancellation by Global Health
If we are unable to provide a booked consultation within 2 hours of the scheduled time for reasons attributable to us, any Credits used will be reinstated in full. You may alternatively request a cash refund of the monetary value of the Credits used, processed within 5-10 business days to your original payment method.
7.9 Statutory cancellation and cooling-off rights
Depending on the country in which you are located, you may have statutory rights to cancel a distance contract within a defined cooling-off period. These rights vary by jurisdiction and are set out in full in the applicable Country Addendum. Your statutory rights are not affected by these Terms.
Where a statutory cooling-off period applies and you expressly request that a consultation take place within that period, you may waive your right to cancel that specific consultation upon completion. Country-specific details are in your Country Addendum.
8. Health Data, Medical Records, and Data Protection
8.1 Commitment to data protection
We are committed to protecting your personal data and Health Data in accordance with Applicable Data Protection Law in each market in which we operate. The specific data protection framework that applies to you depends on your country of residence and is set out in the applicable Country Addendum.
8.2 Health Data processing
Health Data is classified as sensitive personal data in all markets in which we operate and requires a higher standard of protection. We process your Health Data only on lawful bases as required by Applicable Data Protection Law in your jurisdiction. These bases are specified in the applicable Country Addendum and in our Privacy Policy.
8.3 Data Protection Officer
Global Health has appointed a Data Protection Officer (DPO) for the purposes of GDPR and applicable data protection legislation in EU markets. The DPO's contact details are published in our Privacy Policy at www.myglobalhealth.online/privacy.
8.4 Data retention
We retain clinical records for the minimum periods required by the law and professional regulatory guidance of each country in which we operate. Specific retention periods are set out in the applicable Country Addendum and in our Privacy Policy.
8.5 Your data rights
Depending on Applicable Data Protection Law in your jurisdiction, you may have some or all of the following rights: access; rectification; erasure (subject to legal retention obligations); restriction of processing; data portability; objection to processing; and the right not to be subject to solely automated decision-making.
To exercise any of these rights or to request a copy of your medical records, please contact globalhealth@myglobalhealth.online. We will respond within the timeframe required by Applicable Data Protection Law in your jurisdiction, and in any event within 30 days.
8.6 International data transfers
As a multi-market operator, personal data may be transferred between countries in which Global Health operates. Where data is transferred internationally, we ensure appropriate safeguards are in place as required by Applicable Data Protection Law, including EU Standard Contractual Clauses or equivalent mechanisms. Full details are set out in our Privacy Policy.
8.7 Data breach notification
In the event of a personal data breach likely to result in a high risk to your rights and freedoms, we will notify you without undue delay in accordance with our obligations under Applicable Data Protection Law in your jurisdiction.
8.8 Privacy Policy
Our Privacy Policy at www.myglobalhealth.online/privacy contains full details of how we collect, use, store, share, and protect your personal and Health Data across all markets, including our sub-processor register as required under applicable data protection law.
9. User Responsibilities and Prohibited Conduct
In accessing and using the Services, you agree to:
- Provide accurate, honest, and complete information to Clinicians and on the Platform at all times.
- Not provide false medical history, symptoms, or information that could mislead a Clinician.
- Not use the Platform for any unlawful purpose or in any way that violates applicable law or regulation.
- Not attempt to gain unauthorised access to the Platform, its systems, or any other user's account.
- Not use automated tools, bots, or scripts to access or interact with the Platform without our prior written consent.
- Not impersonate any person, including any Clinician or Global Health employee.
- Not upload or transmit any content that is unlawful, harmful, defamatory, or that infringes the intellectual property rights of any third party.
- Comply with all applicable laws and regulations in your country of residence when using the Services.
Breach of any of the above obligations may result in immediate suspension or termination of your account and, where appropriate, referral to law enforcement authorities.
10. Intellectual Property
All content on the Platform, including but not limited to text, graphics, logos, images, audio, video, and software, is owned by or licensed to Global Guest s.r.o. and is protected by applicable copyright, trademark, and other intellectual property laws.
You are granted a limited, non-exclusive, non-transferable, revocable licence to access and use the Platform and its content for your personal, non-commercial use only. You may not reproduce, distribute, modify, create derivative works from, publicly display, or otherwise exploit any content from the Platform without our prior written consent, except as expressly permitted by applicable law.
11. Limitation of Liability
Nothing in these Terms excludes or limits our liability for: death or personal injury caused by our negligence or the negligence of our Clinicians; fraud or fraudulent misrepresentation; or any other liability that cannot lawfully be excluded or limited under the applicable law of your jurisdiction.
Subject to the above, and to the fullest extent permitted by law in your jurisdiction, our total aggregate liability to you arising out of or in connection with your use of the Services shall not exceed the total fees paid by you to us in the 12 months immediately preceding the event giving rise to the claim.
We are not liable for any indirect, incidental, special, consequential, or punitive losses or damages, including loss of data, loss of revenue, or loss of profits, arising from your use of the Platform or Services.
The allocation of liability between Global Health and individual Clinicians for clinical acts and omissions depends on the operating model applicable in your market and is set out in detail in the applicable Country Addendum.
We are not liable for the availability, content, or services of any third-party website linked from the Platform, or for third-party service providers to whom you are referred.
Where Consumer Protection Law in your jurisdiction imposes mandatory terms or remedies more favourable to you than the above, those mandatory terms apply and cannot be excluded.
12. Complaints and Regulatory Bodies
If you have a complaint about our Services, please contact us in the first instance at globalhealth@myglobalhealth.online with the subject line "Formal Complaint". We will acknowledge your complaint within 2 business days and aim to resolve it within 14 business days.
In addition to contacting us directly, you may have the right to refer concerns to a relevant regulatory body depending on the market in which you accessed the Services and whether Global Health is operating as a healthcare provider or as a platform in that market. Applicable regulatory bodies, complaints procedures, and alternative dispute resolution options for each market are set out in the applicable Country Addendum.
13. Changes to These Terms
We may update these Master Terms or any Country Addendum from time to time to reflect changes in our services, applicable law, regulatory requirements, or the markets in which we operate.
For material changes that adversely affect your rights, we will notify you by email to the address associated with your account at least 30 days before the changes take effect and will display a prominent notice on the Platform.
If you do not accept the updated Terms, you may close your account before the changes take effect without penalty. Any Credits remaining in your account at closure will be refunded at their monetary value within 10 business days. Continued use of the Platform after the effective date constitutes acceptance of the updated Terms.
Minor changes, such as corrections of typographical errors or clarifications that do not affect your substantive rights, may be made without advance notice.
14. Governing Law and Dispute Resolution
14.1 Default governing law
These Master Terms are governed by the laws of the Czech Republic, being the jurisdiction of incorporation of Global Guest s.r.o. Where the mandatory Consumer Protection Law of your country of residence provides greater protection than Czech law, those mandatory protections apply and cannot be excluded by this clause.
14.2 Country-specific governing law
Each Country Addendum specifies the governing law and jurisdiction applicable to patients in that market. Where a Country Addendum specifies a governing law, that law governs your use of the Services in that market and takes precedence over Clause 14.1.
14.3 Complaints procedure
Please refer to Clause 12 for our complaints procedure. If we cannot resolve your complaint, you have the right to refer the matter to the relevant alternative dispute resolution body in your country, as specified in the applicable Country Addendum.
14.4 Online dispute resolution — EU patients
For patients in EU member states, the European Commission provides an Online Dispute Resolution platform at https://ec.europa.eu/consumers/odr. You may use this platform to submit a complaint if you are unable to resolve a dispute with us directly.
14.5 Non-EU patients
For patients in non-EU markets, applicable dispute resolution mechanisms are specified in the relevant Country Addendum.
15. General Provisions
15.1 Entire agreement
These Master Terms, together with the applicable Country Addendum, our Privacy Policy, Cookie Policy, and where applicable the Credit Plan terms, constitute the entire agreement between you and us relating to your use of the Platform and Services.
15.2 Severability
If any provision of these Terms is found to be invalid, unlawful, or unenforceable by a court of competent jurisdiction, that provision shall be deemed severed and the remaining provisions shall continue in full force and effect.
15.3 Waiver
Our failure to enforce any right or provision of these Terms shall not constitute a waiver of that right or provision.
15.4 Assignment
You may not assign or transfer any of your rights or obligations under these Terms without our prior written consent. We may assign our rights and obligations to a successor entity in the event of a merger, acquisition, or sale of substantially all of our assets, provided your rights are not materially diminished.
15.5 Force majeure
We shall not be liable for any failure or delay in performance of our obligations arising from causes beyond our reasonable control, including acts of God, pandemic, war, civil unrest, government action, power failure, or internet disruption. We will notify you as soon as practicable and take reasonable steps to minimise the impact on you.
15.6 Language
These Terms are drafted in English. Where a translation is provided for convenience, the English language version prevails in the event of any conflict or ambiguity.
15.7 New markets
When Global Health begins operating in a new market, the applicable Country Addendum will be published at www.myglobalhealth.online/terms before Services are made available in that market. The Master Terms apply in all markets from the date of first availability.
16. Contact Us
For questions about these Master Terms or about the Platform generally:
Global Health (Global Guest s.r.o.)
IČO: 19071680
Registered Office: Rybna 24, 110 00 Prague 1
Email: globalhealth@myglobalhealth.online
Website: www.myglobalhealth.online
Country Addendum — Brazil
Platform Model | Brazilian Law Governed
Effective Date: 1 July 2026
Brazil Addendum — Summary
| Platform Operator | Global Guest s.r.o. trading as Global Health |
| Czech Company No. | IČO: 19071680 |
| Irish Branch (CRO) | CRO No. 910267 |
| Operating Model | Platform Model (plataforma digital intermediadora) |
| Medical Providers | Independent Pessoas Jurídicas with CNPJ and CRM registration |
| Services at Launch | Online medical consultations only |
| globalhealth@myglobalhealth.online | |
| Website | www.myglobalhealth.online |
| Governing Law | Brazil (federal law, including CDC) |
| Lead Data Protection Authority | ÚOÚ (Czech Republic) — one-stop-shop for EU operations |
| Brazilian Data Protection Authority | ANPD — www.gov.br/anpd |
| Effective Date | 1 June 2026 |
This Country Addendum supplements the Global Health Master Terms and Conditions v2.3 for patients accessing Services in Brazil. In the event of any conflict between this Addendum and the Master Terms, this Addendum prevails for Brazilian patients.
Operating Model: Global Health operates in Brazil under the Platform Model as a technology intermediary (plataforma digital intermediadora). Global Health does not provide medical services directly. Medical consultations are provided by independent Medical Providers (Pessoas Jurídicas) holding their own CNPJ and CRM registration, who are solely responsible for all clinical decisions.
Governing Law: Brazil (federal law including CDC) | Languages: English and Português
BR-1. Nature of the Service in Brazil — Platform Model
In Brazil, Global Health operates exclusively as a technology platform intermediary (plataforma digital intermediadora). Global Health does not provide medical services directly to patients in Brazil. Medical consultations are provided by independent licensed Medical Providers (Pessoas Jurídicas) who hold valid CNPJ registration and valid registration with the Conselho Regional de Medicina (CRM) of their operating state.
Each Medical Provider operates independently and has entered into a separate Platform Services Agreement with Global Guest s.r.o. governing their use of the Global Health platform. Global Health acts solely as the technology intermediary that facilitates the booking, payment processing, and communication between patients and Medical Providers.
The medical consultation contract is formed directly between the patient and the Medical Provider. Global Health is not a party to that medical contract and does not direct, supervise, or control the clinical decisions of any Medical Provider.
Platform Model: In Brazil, Global Health's role is limited to: (a) operating the booking and communications platform; (b) processing payments and remitting fees to Medical Providers; and (c) providing administrative support. Notwithstanding this model, under Artigo 7, parágrafo único and Artigo 25, §2 of the Código de Defesa do Consumidor (CDC), Global Health may be held jointly liable with Medical Providers for consumer complaints. The complaint handling framework in BR-8 reflects this exposure.
BR-2. Operating Entity
Global Health services in Brazil are provided by Global Guest s.r.o. (IČO: 19071680), a company incorporated in the Czech Republic with a registered branch in Ireland (CRO: 910267), trading as Global Health. Global Health operates in Brazil under the freedom to provide cross-border digital services, providing platform intermediary services to patients and Medical Providers located in Brazil through the Platform at www.myglobalhealth.online.
Global Guest s.r.o. does not have a registered legal entity or branch in Brazil. Each Medical Provider holds their own CNPJ and operates as an independent Pessoa Jurídica.
Contact details for Brazilian patients:
- Email: globalhealth@myglobalhealth.online
- Website: www.myglobalhealth.online
BR-3. Medical Providers on the Platform
All Medical Providers offering consultations through the Global Health platform in Brazil:
- Are registered legal entities (Pessoas Jurídicas) holding valid CNPJ registration.
- Hold valid registration with the Conselho Regional de Medicina (CRM) of the state in which they practise.
- Have entered into a Platform Services Agreement with Global Guest s.r.o. governing their access to and use of the Platform.
- Are solely responsible for the clinical services they provide, including the content of consultations, clinical decisions, diagnoses, and any prescriptions issued.
- Maintain their own professional liability insurance (seguro de responsabilidade civil profissional) as required by applicable CFM regulations.
Each Medical Provider's CRM registration number and CNPJ are available on their individual profile page on the Platform. Patients may verify a Medical Provider's registration at any time via the CFM online register at portal.cfm.org.br.
BR-4. Payment Flow and Invoicing
The payment flow in Brazil operates as follows:
- The patient pays the full consultation fee to Global Health at the time of booking through the Platform.
- Global Health invoices the Medical Provider a platform service fee (taxa de plataforma) for each consultation facilitated, in accordance with the Platform Services Agreement.
- The Medical Provider invoices the patient directly for the consultation service (Nota Fiscal de Serviços — NFS-e) in accordance with their CNPJ registration and applicable Brazilian tax law.
- Global Health issues its own invoice (Nota Fiscal) to the Medical Provider for the platform service fee.
The consultation fee paid by the patient to Global Health is held on behalf of the Medical Provider pending completion of the consultation, subject to Global Health's right to deduct its platform service fee and to apply any refund or cancellation policy as set out in this Addendum.
BR-5. Medical Regulation and Prescriptions in Brazil
BR-5.1 CFM regulation
Telemedicine in Brazil is regulated by the Conselho Federal de Medicina (CFM) under CFM Resolution No. 2.314/2022. Each Medical Provider on the Platform is individually responsible for compliance with CFM Resolution No. 2.314/2022 and all applicable CRM regulations in their operating state.
BR-5.2 Prescriptions
Prescriptions issued through the Platform in Brazil are issued solely by the Medical Provider and are the clinical and legal responsibility of that Medical Provider. Global Health does not issue, review, or approve prescriptions and takes no clinical responsibility for any prescription issued by a Medical Provider through the Platform.
Electronic prescriptions must comply with CFM Resolution No. 2.299/2021 and applicable ANVISA regulations. The Medical Provider is solely responsible for ensuring that any prescription issued through the Platform complies with all applicable Brazilian laws and regulations.
No prescriptions for controlled substances (medicamentos controlados) subject to Portaria SVS/MS No. 344/98 (as updated) may be issued through the Platform.
BR-5.3 ANVISA
The regulation of medicines and health surveillance in Brazil is the responsibility of the Agência Nacional de Vigilância Sanitária (ANVISA). Any queries regarding the validity or dispensing of a prescription in Brazil should be directed to ANVISA at www.gov.br/anvisa or to the dispensing pharmacy.
BR-6. Consumer Rights in Brazil
BR-6.1 Applicable consumer legislation
Your rights as a consumer in Brazil are protected by the following legislation and cannot be excluded or limited by these Terms:
- Código de Defesa do Consumidor (CDC) — Lei No. 8.078/1990.
- Decreto No. 7.962/2013 — e-commerce and distance selling rules.
- Lei No. 14.181/2021 — additional consumer protection provisions.
BR-6.2 Joint liability under the CDC
Under Artigo 7, parágrafo único and Artigo 25, §2 of the CDC, participants in a supply chain may be held jointly liable (responsabilidade solidária) for consumer harm. As the platform that receives the patient's payment and facilitates the consultation, Global Health acknowledges that it may be held jointly liable with the Medical Provider for consumer complaints relating to consultations booked through the Platform, regardless of the platform intermediary model described in BR-1.
Where a patient complaint relates to a clinical matter, Global Health will receive the complaint, log it, and refer it to the relevant Medical Provider for resolution. Where a complaint relates to a platform matter, Global Health will handle and resolve it directly. The full complaint handling framework is set out in BR-8.
BR-6.3 Statutory 7-day right of withdrawal
Under Artigo 49 of the CDC and Decreto No. 7.962/2013, you have the right to withdraw from any distance contract within 7 (seven) calendar days from the date of contracting or the date of receipt of the service, whichever is later, without giving any reason and without penalty.
If a consultation has already taken place within the 7-day period at your express request, a proportionate deduction reflecting the value of the consultation delivered will apply to any refund. Refunds will be processed within 7 business days of the withdrawal request.
BR-6.4 Mandatory e-commerce disclosures
In accordance with Decreto No. 7.962/2013, Global Health makes available on the Platform: full identification of the platform operator; complete description of services facilitated; pricing inclusive of all applicable charges; payment terms and methods; cancellation and refund policies; and information on the right of withdrawal.
BR-6.5 Credit Plan — no minimum term
Credit Plans available in Brazil are billed monthly with no minimum contract term and may be cancelled at any time with effect from the end of the current billing cycle. The 7-day right of withdrawal under the CDC applies from the date of first subscription, subject to the proportionate deduction set out in BR-6.3.
BR-6.6 Emergency services
EMERGÊNCIA: In Brazil, call 192 (SAMU — Serviço de Atendimento Móvel de Urgência) or 190 (police) for emergencies. Do not use the Global Health Platform in a medical emergency.
BR-7. Data Protection in Brazil (LGPD)
BR-7.1 Applicable law and supervisory authority
Data processing for patients in Brazil is governed by the Lei Geral de Proteção de Dados Pessoais (LGPD) — Lei No. 13.709/2018 as amended by Lei No. 13.853/2019.
The national supervisory authority for data protection in Brazil is the Autoridade Nacional de Proteção de Dados (ANPD) at www.gov.br/anpd. You have the right to lodge a complaint with the ANPD at any time. ANPD notification of Global Health's DPO appointment is in progress and will be completed prior to go-live.
Global Guest s.r.o.'s lead supervisory authority for EU GDPR purposes is the Czech data protection supervisory authority (ÚOÚ). The LGPD applies independently to the processing of Brazilian patient data.
BR-7.2 Data Protection Officer
Global Health has appointed Dr Ahmed Maklad as Data Protection Officer (DPO) for all markets in which Global Health operates, including Brazil. The DPO can be contacted at dpo@myglobalhealth.online. Full DPO contact details are published in the Privacy Policy at www.myglobalhealth.online/privacy.
BR-7.3 Data roles
Global Health acts in two distinct capacities with respect to patient data in Brazil:
- Controller (Controlador) of transactional and platform data: name, date of booking, service type, and payment amount. This data is processed by Global Health for platform operation, billing, invoicing, and legal compliance.
- Processor (Operador) of clinical data: consultation notes, prescriptions, patient medical history, and all other clinical records generated during a consultation. This data is stored in the Global Health platform but is accessible only by the Medical Provider who generated it. The Medical Provider is the data controller of this clinical data.
BR-7.4 Legal bases for processing
Global Health processes transactional patient data in Brazil on the following legal bases under the LGPD:
- Artigo 7, V — processing necessary for the execution of a contract to which the data subject is a party.
- Artigo 7, II — compliance with a legal or regulatory obligation.
- Artigo 7, IX — legitimate interests of the controller, where not overridden by the data subject's fundamental rights.
BR-7.5 Security measures for clinical data
As a data processor of clinical data on behalf of Medical Providers, Global Health implements appropriate technical and organisational security measures including: access controls limiting clinical data to the generating Medical Provider; encryption of data in transit and at rest; regular security assessments; and incident response procedures. Global Health does not sell, share, or use clinical data for any purpose other than secure storage on behalf of the Medical Provider.
BR-7.6 Your rights under the LGPD
Under Artigo 18 of the LGPD, you have the following rights in relation to your personal data: confirmation of the existence of processing and access to your data; correction of incomplete or inaccurate data; anonymisation, blocking, or deletion of unnecessary data; portability; deletion of data processed with your consent; information about entities with which your data has been shared; and revocation of consent.
For requests relating to transactional data held by Global Health as controller, contact globalhealth@myglobalhealth.online. We will respond within 15 days as required by ANPD guidance. For requests relating to clinical data held by Global Health as processor on behalf of a Medical Provider, contact the Medical Provider directly.
BR-7.7 Data retention
Transactional data is retained for 5 years from the date of the transaction for billing, tax compliance, and legal purposes. Clinical data stored on behalf of Medical Providers is retained in accordance with their instructions and applicable CFM regulations — as a general principle under the Código de Ética Médica, medical records should be retained for a minimum of 20 years following the last consultation entry.
BR-7.8 International data transfers
As Global Health is operated by a Czech entity, transactional data of Brazilian patients may be transferred to and processed in the Czech Republic and other countries in which Global Health operates. Such transfers are made in accordance with Chapter V of the LGPD, using appropriate safeguards including standard contractual clauses or other mechanisms recognised by the ANPD. Full details are in our Privacy Policy at www.myglobalhealth.online/privacy.
BR-8. Complaint Handling and Escalation — Brazil
This section sets out the complete complaint handling process for Brazil, including response timeframes, escalation steps, and the remedies available to patients. It reflects Global Health's joint liability exposure under the CDC.
BR-8.1 Two categories of complaint
Category A — Platform Complaints
Complaints about the Platform itself: payment errors; booking failures; cancellation or refund disputes; platform technical issues; or billing discrepancies. These are handled and resolved directly by Global Health.
Category B — Clinical Complaints
Complaints about the quality, outcome, or conduct of a medical consultation: clinical advice received; a diagnosis; a prescription; the conduct of a Medical Provider; or the standard of care provided. These are referred to the relevant Medical Provider for resolution, with Global Health monitoring and escalating where necessary.
BR-8.2 How to submit a complaint
Contact Global Health at globalhealth@myglobalhealth.online with the subject line "Formal Complaint — Brazil". Include your full name, booking reference number, date of the consultation, name of the Medical Provider, and a clear description of the complaint. We accept complaints in English and Portuguese.
Global Health will log every complaint, assign a reference number, and send an acknowledgement within 2 business days confirming the complaint category and next steps.
BR-8.3 SLA — Category A: Platform Complaints
- Acknowledgement: within 2 business days of receipt.
- Resolution: within 14 business days of receipt.
- Refund (where applicable): within 7 business days of the refund decision being confirmed.
BR-8.4 SLA — Category B: Clinical Complaints
Step 1 — Global Health acknowledges within 2 business days, logs the complaint, and notifies the Medical Provider.
Step 2 — Medical Provider acknowledges to Global Health and the patient within 5 business days of referral.
Step 3 — Medical Provider provides a substantive response and proposed resolution within 14 business days of referral.
BR-8.5 Escalation process
Where a Medical Provider fails to respond within the timeframes above, Global Health escalates as follows:
- Level 1 — Formal warning (triggered at Day 6 if no acknowledgement, or Day 15 if no resolution): Global Health issues a written warning under the Platform Services Agreement requiring response within 5 further business days. Patient is notified.
- Level 2 — Suspension (triggered at Day 11 if no acknowledgement, or Day 20 if no resolution after Level 1): Global Health suspends the Medical Provider's platform access. A full or partial refund of the platform fee is issued to the patient within 7 business days where appropriate. Global Health pursues recovery from the Medical Provider.
- Level 3 — Termination (triggered where Level 2 fails within a further 14 business days, or for serious or repeated failures): Global Health terminates the Platform Services Agreement and issues the patient a full refund where within Global Health's power. Where the complaint involves potential professional misconduct, the Medical Provider is reported to the relevant CRM.
Global Health reserves the right to apply Level 2 or Level 3 escalation immediately where the complaint involves patient safety, serious misconduct, or repeated non-compliance.
BR-8.6 Remedies available
Depending on the nature and outcome of the complaint, the following remedies may be available: full or partial refund of the consultation fee; a replacement consultation at no charge; or a platform credit valid for 12 months. The availability of each remedy depends on the circumstances and applicable CDC provisions.
BR-8.7 External dispute resolution
If you are not satisfied with the outcome of Global Health's complaint process, you may refer the matter to:
- Procon — state consumer protection offices: www.procon.gov.br
- consumidor.gov.br — federal online consumer dispute platform: www.consumidor.gov.br
- CFM — for clinical conduct complaints: portal.cfm.org.br
- ANPD — for data protection complaints: www.gov.br/anpd
BR-8.8 Governing law and jurisdiction
For patients in Brazil, this Addendum and any dispute arising from your use of Services are governed by Brazilian federal law, including the CDC. In accordance with Artigo 101, I of the CDC, disputes may be brought before the courts of the consumer's domícilio in Brazil.
BR-9. Regulatory Framework in Brazil
Global Health operates in Brazil in compliance with the following regulatory framework:
| Body | Role | Website |
|---|---|---|
| Conselho Federal de Medicina (CFM) | National medical regulation and telemedicine rules | portal.cfm.org.br |
| Conselhos Regionais de Medicina (CRM) | State-level medical practitioner registration | portal.cfm.org.br/crm |
| Agência Nacional de Vigilância Sanitária (ANVISA) | Health surveillance, medicines, and medical devices | www.gov.br/anvisa |
| Autoridade Nacional de Proteção de Dados (ANPD) | LGPD data protection enforcement | www.gov.br/anpd |
| Procon / consumidor.gov.br | Consumer protection — state and federal level | www.consumidor.gov.br |
BR-10. Future Clinic Operations
Global Health currently operates in Brazil solely as a platform intermediary as described in this Addendum. Global Health intends to establish direct clinic operations in Brazil in the future, subject to patient growth and regulatory requirements. When direct clinic operations commence, this Addendum will be updated to reflect the expanded operational model, including any additional regulatory registrations, direct medical liability, and expanded data controller obligations that apply to direct healthcare providers in Brazil.
Patients will be notified of any material change to the operational model with at least 30 days' advance notice in accordance with the Master Terms.
BR-11. Language
These Terms are provided in English. Global Health will make a Portuguese (Português Brasileiro) language version available for Brazilian patients at www.myglobalhealth.online/brazil/pt. In the event of any conflict between the English and Portuguese versions, the English version shall prevail unless Brazilian law requires otherwise.
BR-12. Contact Details for Brazil
Global Health — Brazil
Global Guest s.r.o. trading as Global Health | IČO: 19071680 | CRO: 910267
Email: globalhealth@myglobalhealth.online
Website: www.myglobalhealth.online
