1. Data Controller
The data controller for this Service is:
- Company Name: Entendo
- Registered Address: Brazil
- Privacy Contact: privacy@entendo.com
- Data Protection Officer: Not applicable
2. Information We Collect
2.1 Information You Provide
- Account Information: Email address, name, and encrypted password. If you sign up via Google OAuth, we collect your public Google profile information.
- Payment Information: Transaction amount and payment status. We do not store complete card numbers — card data is handled by our payment processor (see Section 5).
- Communication Records: Emails, support tickets, and feedback you send to our support team.
2.2 Information We Automatically Collect
- Device and Network: IP address, device model, operating system, browser type, timezone.
- Usage Behavior: Page visits, feature usage, operation logs, session duration.
- Log Data: Request timestamps, error logs, performance data.
3. How We Use Your Information
| Purpose | Legal Basis |
|---|---|
| Provide and maintain the Service | Contract performance |
| Billing and payment processing | Contract performance |
| Customer support | Contract performance / Legitimate interest |
| Service notifications (billing, security, policy updates) | Legitimate interest |
| Security and fraud prevention | Legitimate interest |
| Product improvement and analytics | Legitimate interest |
| Legal compliance | Legal obligation |
We may aggregate or de-identify data for statistical analysis. Such data cannot identify specific individuals.
4. Cookies and Tracking Technologies
| Type | Purpose | Can be disabled |
|---|---|---|
| Strictly necessary | Maintain login, core functionality | No |
| Functional | Language preferences, personalized settings | Yes |
| Analytics | Anonymous usage statistics, product optimization | Yes |
We use anonymous analytics tools to understand how users interact with our Service. You can adjust preferences through your browser settings or our Cookie Management Center.
5. Information Sharing and Disclosure
We do not sell your personal information, including as defined under applicable laws such as CCPA. We only share information in the following circumstances:
- Service Providers: We share data with trusted providers for cloud computing, payment processing, email delivery, and customer support, under confidentiality agreements. Payment card data is processed exclusively by our PCI-DSS compliant payment processor, Waffo Pancake, and is never stored on our servers.
- Legal Requirements: We may disclose information if required by law, court order, or legitimate government request.
- Business Transfers: In the event of a merger or acquisition, user information may be transferred with prior notice and continued protection obligations.
- With Your Consent: For any other purpose, only with your explicit prior consent.
6. Data Security
- Transmission Encryption: TLS/HTTPS
- Storage Security: Sensitive data such as passwords are encrypted or hashed
- Access Controls: Principle of least privilege; employees sign confidentiality agreements
- Regular Security Audits: Periodic security audits and vulnerability scans
In case of a security incident affecting your rights, we will notify you and relevant regulators within 72 hours of discovery, as required by applicable law. Please keep your account credentials secure and do not share them with others.
7. Data Retention
| Data Type | Retention Period | Disposal |
|---|---|---|
| Account information | During active period; 90 days after cancellation | Deleted or anonymized |
| Transaction records | As required by law (typically 5 years) | Deleted or archived |
| Support records | 2 years | Secure deletion |
| Security audit logs | 12 months | Secure deletion |
8. Your Data Rights
To exercise the following rights, contact us at privacy@entendo.com. We will process requests within 30 calendar days.
| Right | Description |
|---|---|
| Right to Know | Understand what data we collect and how we use it |
| Right to Access | Obtain a copy of your personal data |
| Right to Rectification | Correct inaccurate or incomplete information |
| Right to Erasure | Request deletion under specific conditions |
| Right to Restrict Processing | Pause data processing under specific circumstances |
| Right to Data Portability | Receive data in a machine-readable format |
| Right to Object | Object to processing based on legitimate interests or marketing |
| Right to Withdraw Consent | Withdraw consent for processing based on consent |
If you believe we have not handled your data properly, you have the right to lodge a complaint with your local data protection authority.
9. Marketing Communications and Opt-Out
With your consent, we may send marketing information via email or in-app notifications. You can unsubscribe at any time by clicking the "unsubscribe" link in emails, disabling marketing notifications in account settings, or contacting us. Opting out does not affect service-related notifications such as billing or security alerts.
10. International Data Transfers
Our servers and partners may be located in Brazil and other regions. For cross-border transfers, we ensure data security through:
- Data processing agreements incorporating Standard Contractual Clauses (SCCs)
- Transfers only to recipients providing equivalent protection levels
- Other safeguards as required by applicable law
11. Children's Privacy
This Service is intended for users aged 18 and older. We do not knowingly collect personal information from minors. If you believe your child has provided us with information, please contact us immediately at privacy@entendo.com and we will promptly delete it.
12. Third-Party Links and Services
This Service may contain links to third-party websites or integrate with third-party services. This Policy applies only to information we directly collect. We are not responsible for third-party data practices and recommend reviewing their policies before use.
13. Policy Changes
We may update this Privacy Policy from time to time. Significant changes will be communicated at least 15 days in advance via platform notice or your registered email. The "Last Updated" date at the top of this page reflects when changes take effect. Continued use after the effective date constitutes acceptance.
14. Contact Us
- Privacy Contact: privacy@entendo.com
- Customer Support: support@entendo.com
- Company: Entendo
- Address: Brazil
This Privacy Policy is provided for informational purposes and does not constitute legal advice. We recommend consulting a qualified legal professional familiar with your target market before official publication.