This is a translation of the Portuguese version. If they differ, the Portuguese version prevails.
This policy belongs to Annura Desenvolvimento de Software Ltda., CNPJ 41.550.149/0001-21, which is responsible for the processing of the data described here (the controller).
Annura builds custom systems, integrations and software solutions for businesses. This page explains what personal data we process when you visit this website or contact us, what we use it for and what your rights are, under the Lei Geral de Proteção de Dados (Brazil’s General Data Protection Law, Law No. 13,709/2018, or LGPD).
This policy covers the data of people who visit the website or have a business relationship with Annura. When, in the course of providing services, we access personal data for which a client is responsible, we act as a processor, following the instructions of and the contract with that client, who is the controller of that data.
What data we process
- Contact data: name, phone number, email, company and job title, when you provide them to us.
- Content of conversations: text messages, audio, videos, images and files you send us by WhatsApp, by email or through the website’s contact form, and our replies.
- Meetings: notes, recordings and transcripts of meetings you take part in with us. We always let you know when a meeting is recorded.
- Technical message data: date, time and identifiers generated by WhatsApp and by email.
- Browsing data: IP address, date and time of access, browser type and device type. These are recorded automatically by the service that hosts the website and, when you submit the form, they are sent along with your message.
To find out how many people visit the website, where they come from and how they navigate it, we use audience measurement tools that do not store cookies in your browser. They record browsing data such as the page visited, the source of the visit, clicks and page scrolling, approximate region, and browser and device type.
To find out whether our Google ads lead to contact, we use the Google Ads conversion tag. It stores cookies in your browser and, when it loads, your browser sends your IP address to Google. We configured the tag for measurement only, without ad personalization signals. If you prefer, you can block or delete these cookies in your browser settings, and you will still be able to use the website.
The contact form uses a service that protects against automated submissions, which evaluates technical signals from the browser and does not use cookies to track your browsing.
What we use it for
- To respond to your inquiry and understand your needs.
- To prepare proposals and provide the contracted services.
- To keep a record of the relationship, so we do not lose track of requests, deadlines and agreements.
- To comply with legal, tax and contractual obligations.
- To protect the website and the form against spam and abuse.
- To measure the website’s audience, to find out how many people visit it, where they come from and how they navigate it.
- To measure whether our Google ads resulted in contact.
- Occasionally, to send people who have already contacted us communications about our services. You can ask to stop receiving them at any time.
We use software tools, including artificial intelligence features, to organize, transcribe and summarize conversations and meetings. These tools support our work; decisions about how we serve you are made by people.
We do not sell personal data and we do not use it to send third-party advertising.
Legal basis
We process data on the following legal bases (Article 7 of the LGPD):
- Preliminary procedures related to a contract, at your request, and performance of a contract: to respond to your inquiry, prepare proposals and provide the services.
- Compliance with a legal or regulatory obligation: for tax, accounting and record-keeping obligations.
- Regular exercise of rights: to keep records that may be needed in judicial, administrative or arbitration proceedings.
- Legitimate interest: to keep an organized record of our communications with you, including recording and transcribing meetings, to protect the website and the form against spam and abuse, to measure the website’s audience and the results of our ads, and for occasional communications about our services.
We do not rely on your consent for this processing. If any future processing depends on it, we will ask first.
Who we share it with
We share data only with vendors that operate the services we use to do our work, to the extent necessary for that:
- Meta, for WhatsApp Business.
- Hosting, storage and cloud infrastructure providers.
- Providers of email, calendar, documents and internal team communication.
- Website audience measurement tools and tools that protect the form against bots.
- Transcription and artificial intelligence tools that help us organize and summarize conversations and meetings.
- Google, for measuring conversions from our ads.
You can request the list of vendors through the channel indicated under “Contact”.
We may also share data when required by law or by an order from a competent authority.
International data transfers
Some of these vendors store and process data on servers outside Brazil, mainly in the United States and in European Union countries. This means that the data you send us through the website, by email or by WhatsApp, and browsing data, are transferred to these countries for the purposes described in this policy and for the period indicated under “How long we keep it”. These transfers are based on contractual clauses entered into with the vendors, under Articles 33 to 36 of the LGPD and the regulations of the ANPD (Autoridade Nacional de Proteção de Dados, Brazil’s National Data Protection Authority). You can request more information about these safeguards through the channel indicated under “Contact”.
How long we keep it
We keep the data for as long as the conversation or business relationship lasts and, after that, for as long as necessary to comply with legal obligations and protect rights. If the conversation does not result in a contract, you can request deletion at any time.
Your rights
Under Article 18 of the LGPD, you can request confirmation that we process your data, access to it, correction of incomplete, inaccurate or outdated data, anonymization, blocking or deletion of unnecessary or excessive data, portability, deletion of data processed based on your consent, and information about who the data has been shared with. You can also object to processing you consider unlawful and, when processing depends on consent, refuse or withdraw that consent at any time.
To exercise these rights, write to contato@annura.dev. The request is free of charge and we respond within 15 days. We may ask for information to confirm your identity. You can also file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).
Security
We restrict access to the data to those who need it to serve you, and we use services with access control and encrypted communication. No system is completely immune to incidents; if one occurs that may pose a significant risk to you, we will notify you as required by law.
Contact
To exercise your rights or ask questions about this policy, write to contato@annura.dev. This is our communication channel with data subjects. As a small-scale processing agent, Annura is exempt from appointing a data protection officer (encarregado) (Resolução CD/ANPD nº 2/2022, ANPD Board of Directors Resolution No. 2/2022).
Changes
We may update this policy. The version in effect is always the one published on this page, with the date of the last update at the top.