Privacy Policy

This policy explains which personal data Athos Data collects, why we use it, who we share it with and how you can exercise your rights. It applies to the athosdata.com website, to our support on WhatsApp and other channels, and to the platform our clients use. We follow the Brazilian General Data Protection Law (Law No. 13,709/2018, the LGPD). The Portuguese version of this policy prevails in case of any difference.

1. Data controller

The controller of the personal data processed under this policy is 60.202.354 IGOR SANTOS DE MACEDO, registered under CNPJ No. 60.202.354/0001-40, based in Bragança Paulista/SP, doing business as Athos Data.

Contact: privacidade@athosdata.com or +55 11 94357-0794.

2. Data protection officer

For any matter about personal data, contact our data protection officer at privacidade@athosdata.com. This is the communication channel required by article 41 of the LGPD.

3. What Athos Data does

Athos Data builds dashboards, automations and artificial intelligence solutions for industrial companies, law firms and real estate agencies. We use WhatsApp Business for customer service and support: answering questions, following up on requests and sending service notices, always to people who contacted us first or agreed to receive messages.

4. Data we collect

On the website

• Access logs: IP address, date and time, page visited, browser and device operating system. They are generated automatically by the server that hosts the website.
• The language cookie, which stores your choice between Portuguese and English (see section 11).

The website has no forms and does not use audience analytics tools or advertising pixels, such as Google Analytics or Meta Pixel. When you click to contact us on WhatsApp or by email, we process the data you send through those channels.

On WhatsApp

• profile name and phone number;
• content of messages and files you send (text, images, audio and documents);
• date and time of messages, and delivery and read status.

From clients and prospects

• name, job title, company, email and phone of people who contact us or represent a client company;
• data needed for proposals, contracts, invoices and billing;
• support and service history.

On the platform (client area)

• login data of the users appointed by the client, such as name and email, and the password, stored encrypted;
• platform access and usage logs;
• the data the client uploads or connects to the platform to generate dashboards, reports and alerts.

5. Why we use the data and on which legal basis

Each use relies on a legal basis under article 7 of the LGPD:

• Answering inquiries and sending the proposals and quotes you request.Legal basis: steps prior to entering into a contract (art. 7, V).
• Providing the contracted services, giving support and sending service notices, alerts and reports.Legal basis: performance of a contract (art. 7, V).
• Serving you on WhatsApp and keeping the conversation history so we can follow up.Legal basis: performance of a contract or prior steps (art. 7, V) and legitimate interest (art. 7, IX).
• Protecting the website and the platform, preventing fraud and abuse, and improving our services.Legal basis: legitimate interest (art. 7, IX).
• Sending news and offers, if you agree.Legal basis: consent (art. 7, I), which you can withdraw at any time.
• Keeping access logs, issuing invoices and meeting other legal and regulatory requirements.Legal basis: compliance with a legal or regulatory obligation (art. 7, II).
• Defending our rights in judicial, administrative or arbitration proceedings.Legal basis: regular exercise of rights (art. 7, VI).

When we rely on legitimate interest, we process only the data needed and in a way you can expect. You can object to this use by writing to privacidade@athosdata.com.

6. WhatsApp support

• We use the WhatsApp Business Platform, Meta's official API.
• Messages go through Meta's servers, and Meta acts as our processor for this service. What WhatsApp itself does with the data is governed by the WhatsApp Privacy Policy.
• We only send messages to people who started the conversation or who gave us their number and agreed to be contacted (opt-in).
• To stop receiving messages, reply STOP, PARAR or SAIR in the conversation, or write to privacidade@athosdata.com. You can still reach us whenever you want.
• We do not send marketing messages on WhatsApp today. If that changes, it will only be with your consent and with an option to cancel at any time.
• We never ask on WhatsApp for passwords, full card numbers or full document numbers. If someone asks for this data on our behalf, do not reply and let us know.
• A human is always available: at any point in the conversation you can ask to talk to a person on our team.

7. When we act as a processor

When we provide technology services to client companies and process personal data on their behalf, we act as a processor, following the instructions of the client, who is the controller. In these cases, requests about that data should be made to the client. If they reach us, we forward them.

8. Who we share data with

• Meta Platforms (WhatsApp), to send and receive messages;
• hosting, database, authentication and cloud infrastructure providers that keep the website and the platform running;
• artificial intelligence providers used in platform features, when the client uses them;
• administrative service providers, such as accounting, only as needed;
• public authorities, when required by law or court order.

These partners may only use the data for the purposes in this policy. We do not sell or rent personal data.

9. International transfers

Meta and some cloud and artificial intelligence providers process data on servers outside Brazil, such as in the United States. These transfers follow article 33 of the LGPD: they take place to provide the service or perform the contract with you, and we choose providers that offer data protection safeguards compatible with Brazilian law.

10. How long we keep data

We keep data while the service or the contract lasts and, after that, for the periods required by law or needed to exercise rights:

• website and platform access logs: 6 months (article 15 of the Brazilian Internet Civil Framework, Law No. 12,965/2014);
• invoices and accounting records: for the period set by tax law, usually 5 years;
• contract data: until the applicable limitation periods end;
• data processed based on consent: until you withdraw it.

After these periods, the data is deleted or anonymized.

11. Cookies

The website only uses the NEXT_LOCALE cookie, which stores the chosen language for up to 1 year. In the client area, we use session cookies to keep you logged in. These cookies are needed for the site to work: they are not used for advertising or to track your browsing on other sites. You can delete them in your browser settings, but without session cookies you cannot log in to the client area.

12. Security

• encryption in transit (HTTPS) on the website and the platform;
• access to data restricted to authorized people, with individual logins;
• passwords stored encrypted, never in plain text;
• servers on cloud providers with security controls.

If a security incident may cause relevant risk or harm, we will notify the affected individuals and the ANPD, as required by article 48 of the LGPD.

13. Your rights

Under article 18 of the LGPD, you can ask us at any time for:

• confirmation that we process your data;
• access to the data;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or deletion of unnecessary or excessive data, or data processed in breach of the LGPD;
• portability of the data to another provider;
• deletion of data processed based on consent;
• information about the companies and public bodies we share the data with;
• information about the option of not giving consent and what happens if you do not give it;
• withdrawal of consent.

You can also object to processing that breaches the LGPD and ask for a review of decisions made solely on the basis of automated processing (art. 20).

How to exercise them: email privacidade@athosdata.com saying what you want and the phone number or email you used with us. We may ask you to confirm your identity. We reply within 15 days. To request deletion, see the steps on Data deletion.

If you are not satisfied with our answer, you can file a complaint with the Brazilian Data Protection Authority (ANPD) at gov.br/anpd.

14. Minors

Our services are aimed at companies and professionals and are not intended for people under 18. We do not knowingly collect data from minors. If we find out this has happened, the data will be deleted.

15. Changes to this policy

We may update this policy when our services or the law change. The date of the last update is at the top of this page. If a change is significant, we will announce it on the website and, when possible, through the contact channels you gave us.

16. Contact

60.202.354 IGOR SANTOS DE MACEDO, CNPJ 60.202.354/0001-40
Bragança Paulista/SP
Privacy: privacidade@athosdata.com
Other matters: contato@athosdata.com or +55 11 94357-0794