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Terms of Use: GreenNotes AI Data Processing Feature

Last updated September 2026

By enabling and using GreenNotes AI features ("the Features"), you agree to these Terms of Use. These Terms govern your use of the AI-powered tools for medical data transcription, extraction, translation, summarization, and clinical support, and the processing of sensitive patient information.

1. Purpose and Functionality

GreenNotes uses artificial intelligence to process patient-related content including text, images, PDFs, videos, scanned notes, and audio files to:

  • Transcribe spoken notes
  • Extract structured clinical information
  • Summarize or translate records
  • Offer clinical documentation suggestions

The goal is to assist healthcare providers in improving the accuracy and efficiency of clinical documentation workflows. These Features do not replace medical judgment and human oversight should at all times be applied to the output of the Features.

2. Data Processing and International Transfer

Service Providers and Locations

The Features are provided using the following services, which involve transferring data outside South Africa:

  • Google Cloud Vertex AI, for notes, letters, summaries and extracting information from documents and images. Processing takes place in the European Union (the Netherlands and Belgium), with the United States as a fallback. Patient Overview summaries may be processed in any region where Google provides the service.
  • Google Cloud Speech-to-Text, for transcription. Processing takes place in the European Union, with the United States as a fallback.
  • Groq, for transcription. Processing takes place in the United States, and in other countries where Groq or its own sub-processors operate.

Our Sub-processors page keeps this list up to date.

Changes to Providers and Models

We may change the models used within an existing provider without notice, where the change does not materially alter the purposes, categories of information, processing locations or data-protection safeguards described in these Terms. Where we introduce a new provider, or materially change how patient information is processed, we will update the Sub-processors page and give any notice that our Data Processing Agreement requires.

Data Processing Agreements

Google and Groq process data for the Features as GreenNotes’ sub-processors. Google does so under its Cloud Data Processing Addendum, and Groq under its Customer Data Processing Addendum. These agreements:

  • restrict each provider to processing the data to provide its service;
  • prohibit it from using the data to train or fine-tune AI models;
  • require it to notify security incidents and to delete the data; and
  • bind its own sub-processors to equivalent terms.

Data is sent to the providers over encrypted connections. The section “Transfers of personal information outside South Africa” in our Privacy Policy, and section 9 of our Data Processing Agreement, explain the basis for these transfers under section 72 of POPIA.

3. User and Patient Consent

Patient Consent

As a contractual condition of using Features that record consultations or send identifiable patient information for AI processing, GreenNotes requires you to obtain the patient’s express, voluntary and informed consent first. This applies even where POPIA may provide another lawful basis for some of the underlying clinical processing. You confirm that you have obtained that consent before using the Features.

What you tell the patient should cover, as applicable:

  • that the consultation is recorded;
  • that AI is used to transcribe it or to draft documents, or both;
  • that processing takes place outside South Africa, and the kinds of providers and the countries involved (our Sub-processors page lists them);
  • that authorised GreenNotes staff may, in limited cases, see a short passage of a transcript when reviewing medical terms suggested for the practice (section 5); and
  • that the clinician reviews, and remains responsible for, anything the AI drafts.

The patient does not need contract-level detail about the providers, but these facts should be readily available to them.

You hereby indemnify and hold GreenNotes harmless from and against any claims (including third-party claims) arising from your failure to obtain consent to the use of your data subjects' personal information with the Features.

Use Confirmation

By using the Features, you consent to the international processing, temporary storage, and analysis of data through GreenNotes AI systems.

Legal Responsibilities

You remain responsible for your obligations as the responsible party, including establishing an appropriate lawful basis for processing, giving patients the notices they are owed, obtaining any consent that the law or these Terms require, and using the Features in line with the Health Professions Act, HPCSA rules and other professional and ethical requirements. GreenNotes remains responsible for its own obligations under POPIA as your operator and, where applicable, as a responsible party.

4. Data Subject Rights

Under POPIA, data subjects (patients) have the right to:

  • Access their personal information
  • Request the correction or deletion of personal information
  • Object to the processing of such personal information

Patients may exercise these rights through you as the healthcare provider, or via GreenNotes Support. Please visit our Privacy Notice and PAIA Manual for guidance on the process to follow to request access to, or the correction or deletion of, personal information.

5. Security and Retention

Encryption

All data is encrypted in transit and at rest using industry-standard protocols.

Service Providers’ Role

Google and Groq process data only to provide the Features, under the data processing agreements described in section 2, and do not use it to train AI models.

  • Groq. GreenNotes has configured Groq’s Zero Data Retention setting for the transcription service. Under that configuration, Groq does not retain consultation audio or transcription output as customer data after processing. Groq may retain service usage metadata that does not contain the audio or the transcript.
  • Google Speech-to-Text. Data logging is turned off for our project, so Google processes the audio only to return the transcript, under its Cloud Data Processing Addendum.
  • Google Vertex AI (Gemini). By default, Google caches inputs and outputs in memory (never on disk), for no more than 24 hours and within the processing region, to speed up responses. Google may also log prompts to detect abuse of its services, as section 4.3 of the Google Cloud Platform Terms of Service allows.

Neither provider may use this data to train AI models.

Recordings and Transcripts

  • A consultation is recorded in short audio segments so that transcription can start while the consultation is still under way. Each segment is deleted once it has been transcribed.
  • Where a clinician keeps the full recording, it is stored as an encrypted attachment to the clinical note, in the practice’s GreenNotes account.
  • Transcripts and AI-generated drafts are stored in the practice’s GreenNotes account so that the clinician can review and complete the note.

Improving Transcription for Your Practice

When clinicians correct transcripts, GreenNotes may build a list of medical terms for that practice, such as drug and place names, to improve its future transcriptions. GreenNotes staff review suggested terms before they are used, which can show a reviewer the short passage of the transcript a term came from. This access is limited to authorised personnel who need it to perform the review, is subject to confidentiality obligations and access controls, and is used only to improve transcription for that practice. A practice’s list is used only for that practice’s own transcriptions.

Retention by GreenNotes

Files and structured data remain in your GreenNotes account for your records. You can remove files you have attached. Clinical records are archived rather than deleted, so that they remain available for the retention periods that apply to health records.

6. Clinical Oversight

Extracted or transcribed data is provided "as is". You are responsible for reviewing, verifying, and approving outputs before using them in clinical care. GreenNotes AI tools are designed to support, not automate, clinical decisions. No decision about a patient is made by automated means alone.

7. Acceptance and Revocation

Explicit Consent

You must accept these Terms before using any GreenNotes AI-powered Feature. In the GreenNotes Android and iOS apps, your acceptance is recorded with your account.

Revocation

You may disable AI features at any time. Previously processed data remains governed by these Terms and our Privacy Notice.

8. Contact and Support

For assistance or compliance questions, please contact us at help@greennotes.co.za. For any data subject requests, please follow the process set forth in our PAIA Manual which is available on our website.