TERMS AND CONDITIONS OF USE OF THE CDOCTORSTEAMS PLATFORM

CDoctorsTeams is a digital platform owned by GeneralGateway, that connects users with health professionals, with providers of health-related products and services, and professionals with each other. CDoctorsTeams is not a health service provider: it acts solely as a technological facilitator of such connections.

Through the Platform, Users may access the creation and management of medical teams, clinic registration, sharing of professional content, and support tools such as artificial intelligence (AI) for informational consultations.

Additionally, you will find content that health professionals and providers share with all CDoctorsTeams Users, including videos, images, and advertising content. CDoctorsTeams is a platform for you to stay informed and guided by certified professionals.

By accessing, registering for, or using the Platform (web/mobile app), you accept these Terms and Conditions (“T&Cs”), the Privacy Policy, and any supplementary rules. If you do not agree, do not use the Platform.

• Professional: A natural person with a healthcare professional degree, duly authorized, who registers on the Platform.
• Individual User: A Professional registered as such who does not belong to a team or clinic.
• Team: A group of professionals created by an Administrator. It may be: Team 1-3 (up to 3 members) or Team 4-6 (4 to 6 members).
• Clinic: A special registration for a clinical entity/medical center, treated as a Team 4-6 for membership pricing purposes.
• Administrator: The user who creates the Team or registers the Clinic and assumes responsibility for validating and approving its members.
• Provider: An entity or person offering products (pharmaceuticals, supplies, medical equipment, etc.) or health services (elder care, physiotherapy, nursing, etc.).
• AI: Artificial intelligence tools integrated for informational support in clinical consultations.

3.1.

Every Professional or Provider must register by providing truthful information (résumé/CV, supporting documents, valid licenses, photograph, contact details, etc.).

3.2.

CDoctorsTeams performs initial verification (by country) of the applicant only. It does not validate subsequent information for members added by Administrators or for Providers’ offerings.

3.3.

Any falsehood will result in immediate suspension without liability for the Platform.

4.1.

Individual Membership: Standard pricing.

4.2.

Team Membership: Progressive discounts (1-3 and 4-6).

4.3.

Clinic Registration: Billed as Team 4-6 (maximum benefit).

4.4.

Providers: Specific memberships or plans for listings and content (detailed on the Platform).

4.5.

Prices may be changed with prior notice.

5.1.

Approved Professionals may create Teams or register Clinics, becoming Administrators.

5.2.

They accept these T&Cs, in particular Section 10.

Users agree to comply with ethical, legal, and health regulations applicable in each country of operation. In particular, they must maintain the confidentiality of patient data in accordance with local data protection laws, including but not limited to:

• United States: HIPAA (Health Insurance Portability and Accountability Act) — protection of medical data (PHI).
• Canada: PIPEDA (Personal Information Protection and Electronic Documents Act) and applicable provincial laws (PHIPA Ontario, HIA Alberta).
• Brazil: LGPD (Lei Geral de Proteção de Dados — Law 13,709/2018) — health data as a sensitive category.
• Chile: Law 21,719 on Personal Data Protection (effective December 2026) — data protection authority, portability, DPO.
• Mexico: Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP) and the General Health Law Reform (DOF 01/15/2026) on digital health.
• Peru: Law No. 29,733 on Personal Data Protection and its regulations (DS 016-2024-JUS).
• Colombia: Law 1581 of 2012 (General Data Protection Law) and Decree 1377 of 2013.
• Argentina: Law 25,326 on Personal Data Protection and Law 26,529 on Patient Rights.
• Dominican Republic: Law 172-13 on Personal Data Protection.
• Spain / European Union: General Data Protection Regulation (GDPR — EU 2016/679).
• Any other local regulations in effect in the country where the User operates.

Professionals and Providers using the Platform accept responsibility for complying with data protection laws in the countries where they operate. They are responsible for the processing of their patients'/clients' data, including obtaining informed consent and fulfilling the security obligations that correspond to them as data controllers.

CDoctorsTeams is a technology platform and professional social network that connects users with health professionals and providers of health-related products and services, where professionals can share health content with the entire community. CDoctorsTeams does NOT provide health services, does NOT issue diagnoses, does NOT prescribe treatments, does NOT act as a healthcare facility, does NOT enable electronic prescribing, and does NOT provide electronic signature functionality.

Regarding personal data, CDoctorsTeams acts as:

• Data controller: with respect to account data, profile, billing, and Platform usage data for all Users.
• Data processor (business associate): with respect to patient data that Professionals manage through Platform tools (clinical chat, consultation notes, medical history, video consultations, AI support).

As a processor, CDoctorsTeams will process data solely in accordance with the responsible Professional's instructions and under the security measures described in this section and in the Privacy Policy.

CDoctorsTeams implements the following technical and organizational measures to protect personal data processed on the Platform:

• Encryption in transit: all communications are protected with TLS (HTTPS). HSTS enabled with preload and a 2-year duration. Automatic HTTP-to-HTTPS upgrade in production.
• Encryption at rest: data is stored on infrastructure with AES-256 server-level encryption. Medical files are hosted in encrypted storage.
• Role-based access control (RBAC): 6 role levels with specific permissions. Providers do not have access to clinical data.
• Least-privilege clinical access: professionals can only access data of patients with whom they have an active relationship (care team, shared appointment, or audited emergency access with justification and time limit).
• Audit and traceability: all access to health data is logged (actor, patient, action, resource, date, anonymized IP). Audit logs retained for 7 years.
• Session protection: single active session per user; new device verification via OTP code; automatic lockout after failed login attempts.
• Secure passwords: stored with cryptographic hashing (bcrypt); never in plain text. Credentials are protected with deny-access database policies.
• HTTP security headers: Content-Security-Policy (CSP), anti-clickjacking, anti-MIME-sniffing, strict referrer policy, and permissions policy for camera/microphone.
• Abuse protection: rate limiting on all API routes; file type validation on uploads; content sanitization; file size limits by type.
• Secure payments: Stripe integration; card numbers are never stored on our servers. Payment notification signature verification.
• Granular consent: explicit consent at registration, before each teleconsultation, before video recording, before AI transcription, and for sharing medical history.
• Complete data deletion: users may request permanent and irreversible deletion of their account and all associated data.
• Incident notification: in the event of a security breach, CDoctorsTeams will notify authorities and affected individuals within legally mandated timeframes.
• Row-Level Security (RLS): database security policies that restrict record access based on the authenticated user's identity.

These measures constitute Platform commitments. Professionals and Providers retain their own legal security and data protection obligations in each jurisdiction where they operate.

Each Professional or Provider is personally liable for their acts, diagnoses, treatments, products/services, and harm caused.

Users grant a non-exclusive license to use their profile and public content. Content must be truthful and must not infringe third-party rights.

CDoctorsTeams is a technology facilitator and does NOT provide medical services, sell products, or assume liability for quality, suitability, outcomes, or conduct of Users.

10.1.

When creating a Team or registering a Clinic, the Administrator assumes full and exclusive responsibility for:

• a) Verifying, validating, and approving the truthfulness, validity, and legitimacy of degrees, licenses, experience, and any data of each professional they invite or add.
• b) Ensuring that all members comply with applicable ethical, legal, and health regulations.
• c) Overseeing appropriate use of the Platform by their Team/Clinic.

10.2.

CDoctorsTeams verifies only the initial Administrator. It does not verify or validate additional members incorporated by the Administrator.

10.3.

CDoctorsTeams is exempt from all liability for:

• a) Inaccuracies, falsehoods, or irregularities in information or credentials of Team/Clinic members.
• b) Acts, omissions, negligence, or breaches by such members.
• c) Internal disputes (employment, contractual, fee-related, etc.) between Administrator and members, or between members and third parties (patients, authorities, etc.).

Any dispute related to the composition, verification, or activities of the Team/Clinic must be resolved directly between the Administrator and the affected parties, without intervention or liability on the part of CDoctorsTeams.

10.4.

Indemnity: The Administrator shall indemnify and hold CDoctorsTeams harmless against any claim, lawsuit, damage, cost, or expense (including legal fees) arising from:

• Incorporation or activities of members not adequately verified.
• Regulatory breaches by their Team/Clinic.
• Any harm related to management of the Team/Clinic.

10.5.

CDoctorsTeams may immediately suspend or remove any Team/Clinic or Administrator account if it detects (or reasonably suspects) irregularities in verification or incorporation of members.

11.1. Definition and registration

Providers offer products (pharmacies, supplies, medical equipment) or services (elder care at home/clinics/hospitals, physiotherapy, nursing, etc.). Initial verification by CDoctorsTeams; exclusive liability of the Provider for subsequent quality/legal compliance.

11.2. Obligations

Ensure truthfulness of information; comply with all local/national regulations in countries of operation, including:

• U.S.: FDA, state laws (Florida and others).
• Colombia: INVIMA, Ministry of Health.
• Peru: DIGEMID.
• Chile: ISP.
• Argentina: ANMAT.
• Ecuador: ARCSA.
• Spain: AEMPS, GDPR.
• Any other country where the Platform operates.

11.3. Liability for products/services and content

Full liability for damages and claims; content must be truthful and not misleading.

11.4. CDoctorsTeams disclaimer

No liability for quality, transactions, disputes, or Provider content.

11.5. Indemnity

The Provider indemnifies CDoctorsTeams for related claims.

11.6. Suspension

Suspension for breach.

11.7. Reference to Privacy Policy

Providers are responsible for local compliance (e.g. GDPR in Spain, Law 1581 in Colombia).

12.1. Nature

AI as auxiliary support for informational consultations (diagnostic/therapeutic questions, reviews). It is not a diagnostic instrument and does not replace clinical judgment.

12.2. Benefits and risks

Benefits: Faster processing of information, differential suggestions, access to guidelines.

Drawbacks/Risks: Possible inaccuracies, biases, hallucinations, lack of explainability, over-reliance; it does not replace comprehensive patient assessment.

12.3. Exclusive liability of the Professional

Full liability for clinical decisions; always verify AI suggestions; assume all legal/ethical liability for errors, harm, or malpractice claims.

12.4. Obligations

Do not present AI as a definitive diagnosis; inform patients where applicable; comply with local regulations (FDA U.S., AEMPS Spain, INVIMA Colombia, etc.).

12.5. CDoctorsTeams disclaimer

No liability for AI outputs, clinical decisions, or consequences.

12.6. Indemnity

The Professional indemnifies CDoctorsTeams for claims arising from use of AI.

12.7. Suspension

Suspension for misuse.

CDoctorsTeams may suspend/remove accounts for breach, risk, or request of authorities.

We may modify the T&Cs by publication/notification. Continued use constitutes acceptance.

These T&Cs are governed by the laws of the State of Florida, United States, without prejudice to mandatory compliance with local laws in each country of operation (South America and Spain). Disputes shall be submitted to the courts of Tampa, Florida, except where mandatory local rules provide otherwise.

For questions: support@cdoctorsteams.com or the help section.

Local regulatory compliance

Professionals and Users must comply with telemedicine laws and regulations applicable in their country or region, including but not limited to professional licensing, data protection, and service restrictions. CDoctorsTeams will adjust its operations to comply with specific regulations (e.g. HIPAA in the U.S., GDPR in Spain, LGPD in Brazil) and will notify Users of any additional requirements.

1. United States (Florida base)

Key regulations

• HIPAA (Health Insurance Portability and Accountability Act): Regulates privacy and security of medical data (PHI).
• Florida Telehealth Law (F.S. 456.47): Allows telemedicine by professionals licensed in Florida or registered for patients in the state.
• 21 CFR Part 11: Regulates electronic records and digital signatures on health platforms. Note: CDoctorsTeams does not implement electronic signatures or electronic prescribing.

Requirements

• Professionals must be licensed in Florida or in the patient’s state (where applicable).
• Informed consent in writing or electronically before the teleconsultation.
• Use of secure platforms with encryption (e.g. AES-256) to protect data.
• Restrictions on prescribing controlled substances (Schedule II) without a prior in-person visit. Note: CDoctorsTeams does not enable electronic prescribing; professionals must issue prescriptions outside the Platform.

Implications for CDoctorsTeams

• Verify state licenses of Professionals.
• Implement encryption systems and HIPAA audits.
• Include a digital consent form on the Platform.

2. Chile

Key regulations

• Law 20.584: Regulates patients’ rights and duties, including remote care.
• Exempt Resolution No. 744 (MINSAL): Sets standards for telemedicine.
• Law 19.947 (Personal Data Protection): Protects sensitive information.

Requirements

• Professionals must be registered in the National Registry of Individual Health Providers (Superintendence of Health).
• Explicit, documented informed consent.
• Medical data must be stored on secure servers and meet interoperability standards (e.g. HL7).

Implications for CDoctorsTeams

• Validate Professional registration in Chile.
• Ensure secure data storage and patient access to their records.
• Warn that telemedicine does not replace emergency care.

3. Brazil

Key regulations

• CFM Resolution No. 2,227/2018 (as amended by Resolution 2,314/2022): Regulates telemedicine in Brazil.
• LGPD (General Data Protection Law — Law 13,709/2018): Equivalent to GDPR for personal data.

Requirements

• First consultation must be in person, except in remote areas or emergencies (post-COVID flexibilities may apply).
• Professionals must be registered with the Regional Medical Council (CRM).
• The Platform must ensure confidentiality and allow recording of consultations (with consent).
• Mandatory informed consent before each teleconsultation.

Implications for CDoctorsTeams

• Require CRM registration and warn about initial in-person consultation requirements in some cases.
• Implement recording option with explicit consent.
• Comply with LGPD (encryption, breach notification).

4. Peru

Key regulations

• Law No. 30421 (Framework Telesalud Law): Regulates telesalud in the country.
• Supreme Decree No. 015-2019-SA: Sets technical and operational requirements.
• Law No. 29733 (Personal Data Protection): Similar to GDPR.

Requirements

• Professionals must be registered with the Peruvian Medical Association.
• Prior informed consent and clinical data in interoperable systems.
• Technology infrastructure must ensure continuity and security (ISO 27001 recommended).

Implications for CDoctorsTeams

• Verify Medical Association registration.
• Ensure interoperability with Peruvian health systems.
• Protect data in accordance with Law 29733.

5. Ecuador

Key regulations

• Organic Health Law (Art. 33): Allows telemedicine under supervision of the Ministry of Public Health (MSP).
• Organic Law on Personal Data Protection (2021): Regulates sensitive data.

Requirements

• Professionals must be registered with the MSP.
• Informed consent and strict protection of medical data.
• Use limited to consultation, follow-up, or education—not emergencies.

Implications for CDoctorsTeams

• Validate MSP registration of Professionals.
• Implement data security measures aligned with the 2021 Law.
• Limit teleconsultations to non-urgent cases.

6. Mexico

Key regulations

• NOM-024-SSA3-2010: Regulates electronic medical records.
• General Health Law (Art. 77 Bis): Allows telemedicine under National Health System standards.
• Federal Law on Protection of Personal Data (LFPDPPP): Protects sensitive data.

Requirements

• Professionals must hold a valid professional license registered with the Ministry of Health.
• Informed consent in writing or electronically.
• Electronic systems must comply with NOM-024 (integrity, confidentiality).

Implications for CDoctorsTeams

• Verify professional licenses.
• Ensure NOM-024 compliance for EMRs.
• Protect data under LFPDPPP.

7. Bolivia

Key regulations

• Law No. 164 (General Health Law): Does not specifically regulate telemedicine but allows innovative health services.
• Law No. 1178 (Personal Data Protection, in progress): Full implementation pending.

Requirements

• Professionals must be registered with the Ministry of Health.
• Mandatory informed consent.
• Lack of specific regulation requires alignment with international standards (e.g. WHO).

Implications for CDoctorsTeams

• Validate Ministry of Health registration.
• Adopt international standards (ISO 27001, HL7) until local rules are in place.

8. Spain

Key regulations

• General Data Protection Regulation (GDPR — EU 2016/679): Strict data protection.
• Law 41/2002 (Patient Autonomy): Regulates informed consent and patient rights.
• Royal Decree 81/2014: Technical standards for telemedicine.

Requirements

• Professionals must be registered with the corresponding Medical Association.
• Detailed, explicit informed consent.
• The Platform must comply with GDPR (encryption, right to erasure, DPO where required).

Implications for CDoctorsTeams

• Verify Professional registration with Medical Associations.
• Appoint a Data Protection Officer (DPO) where required.
• Ensure GDPR rights (access, rectification, erasure).

9. Canada

Key regulations

• PIPEDA (Personal Information Protection and Electronic Documents Act): Protects personal data.
• Provincial regulations (e.g. Ontario’s PHIPA): Vary by province; govern health data.
• CMA Telemedicine Guidelines: Ethical guidelines of the Canadian Medical Association.

Requirements

• Professionals must be licensed in the patient’s province.
• Informed consent and robust security measures (encryption, audits).
• Restrictions on prescribing controlled substances. CDoctorsTeams does not enable electronic prescribing.

Implications for CDoctorsTeams

• Validate provincial licenses.
• Comply with PIPEDA and PHIPA (as applicable by province).
• CDoctorsTeams does not enable electronic prescribing; professionals must issue prescriptions through official channels in their jurisdiction.

To comply with these regulations, CDoctorsTeams may incorporate the following into its Telemedicine Policies:

1. Professional verification

• Require valid registration/license in the Professional’s jurisdiction and the patient’s (by country).
• Create a Platform process to upload and validate credentials.

2. Informed consent

• Implement a mandatory digital form before each teleconsultation, adaptable to languages and legal requirements by country (e.g. detailed for Spain, simpler for Bolivia).

3. Data protection

• Use AES-256 encryption and comply with international standards (ISO 27001, HL7).
• Adapt the Privacy Policy to GDPR, HIPAA, LGPD, etc., according to the User’s country.
• Offer rights of access, rectification, and erasure of data.

4. Service limitations

• Include clear warnings that telemedicine is not suitable for emergencies or complex diagnoses, tailored to each regulatory framework.

5. Electronic prescriptions and electronic signatures

• CDoctorsTeams does NOT enable electronic prescribing and does NOT provide electronic signature functionality in any jurisdiction.
• Professionals who need to issue prescriptions or sign documents electronically must do so outside the Platform, using systems authorized by the health authorities in their country.
• This limitation protects both users and the Platform from regulatory liabilities associated with prescription and digital certification of clinical documents.

6. Flexible jurisdiction

• Provide that the User’s local laws prevail over Florida law in case of conflict, to reduce legal risk.