Privacy Policy

1. Who is the controller and who is the processor#

The LGPD (Lei nº 13.709/2018, the Brazilian data protection law) separates two roles, and the difference changes who answers for what.

• On YOUR customers' data (the WhatsApp conversations, the appointments, the files they send): your company is the controller and atendIA is the processor. You are the one who decides what that data is used for. We only execute.
• On the data of those who use the dashboard (name, email, phone, CPF or CNPJ (Brazilian individual or company tax ID) used at sign-up, access log): atendIA is the controller.

Data protection officer (DPO) and data subject channel: [email protected]. Full identification of the company in the footer of this page.

2. Which data is processed#

Sensitive health data

Some of our customers are clinics. A patient conversation and an attached exam are sensitive personal data under article 5, II of the LGPD, and receive the same technical treatment as the rest: isolation per company, access by permission and a log of who opened it. The legal basis for this processing is the protection of health (article 11, II, f) when it applies, and otherwise performance of the contract between you and your patient. The choice of which data goes into the conversation belongs to the clinic, which is the controller.

3. On what legal basis#

• Performance of a contract (article 7, V): almost everything. Storing conversations, booking appointments, showing reports.
• Compliance with a legal obligation (article 7, II): tax data of the subscription and access log.
• Legitimate interest (article 7, IX): platform security, fraud prevention, product improvement from aggregated data, without identifying a person, and measurement of our ads with the Meta Pixel and the Google Ads tag on this site, which you can turn off whenever you want (section 10).
• Consent (article 7, I): only where it is truly free and specific, such as connecting your Google account. You can disconnect whenever you want.

4. Artificial intelligence: what leaves here and what does not#

When the AI is on, the content of the conversation is sent to the model provider chosen in your company's configuration to generate the answer. Received audio is sent for transcription. This is the normal operation of the product and is described here so that you know exactly what crosses the border.

• We do not train models on your conversation, and we contract providers under a mode that does not use content sent through the API to train their models.
• What the AI's tools return carries no identity. When it queries your calendar or your services, what goes back to the model is time, service and duration. The contact's name and phone are left out by design decision, and there is an automated test that breaks our build if someone puts identity there.
• You can turn off the AI at any time in the dashboard. With it off, no conversation content is sent to a model provider.

5. Who we share with (sub-processors)#

The list below is the real one and is the one your customer's legal team will ask for. We do not share data with anyone else, and we do not sell data to anyone, under any circumstances.

The same list, with when each one receives data, is in Sub-processors. atendIA's obligations as processor of your customers' data are in the Data Processing Agreement.

International transfer

The AI model providers, Meta, Google, Cloudflare and Stripe process data outside Brazil. The transfer takes place on the basis of article 33 of the LGPD, for performance of the contract between you and atendIA and under the contractual clauses of the respective suppliers. If your operation cannot transfer data outside the country, talk to us before signing up: the AI can be left off, and in that case the product works as an inbox and calendar.

6. How long we keep it#

• Active account: conversations, contacts and calendar are kept while your company is a customer. It is the history you use every day.
• Activity log: the retention window may vary by plan and is stated in the dashboard.
• After cancellation: we keep the data for 30 days in case of a change of mind or a late export. After that period, the company's data is deleted. Data that the law requires us to keep (tax data, for example) follows the legal period.
• Deletion on request: at any time, through the path described in Data deletion.

7. Google data#

This section exists because Google requires it to exist, and it covers the scope that atendIA actually requests: Gmail. atendIA does not access your Google Calendar.

What we request and why

• gmail.readonly: read the emails in the mailbox you connect, so that they appear as conversations in the dashboard alongside WhatsApp.
• gmail.send: send your reply from the same mailbox, so that the customer receives it from the usual address.
• userinfo.email: know which account was connected, to show it on screen and avoid connecting the wrong mailbox.

We request the narrowest scope that makes the feature work. You connect on your own initiative, see a screen explaining what will happen before consenting, and disconnect at any time in the dashboard or at myaccount.google.com/permissions.

Limited Use

atendIA's use and transfer of information received from Google APIs adhere to the Google API Services User Data Policy, including the Limited Use requirements. In practical terms, and plainly:

• We use Google data only to deliver the features you turned on in the dashboard.
• We do not use Google data to train artificial intelligence models, neither ours nor a third party's.
• We do not transfer Google data to third parties, except to operate the feature at your request, as required by law, or with your explicit consent.
• We do not sell Google data and do not use it for advertising.
• No person reads your emails, except with your express authorization for support, as required by law, or on aggregated and anonymized data.

8. Your rights, and how to exercise them#

Articles 17 to 22 of the LGPD guarantee: confirmation that processing exists, access to the data, correction, anonymization or deletion of unnecessary data, portability, information about sharing, withdrawal of consent and review of automated decisions.

To exercise any of them, write to [email protected]. We reply within 15 days. We ask for identity confirmation before handing over data, because handing data to the wrong person would itself be the leak.

If the request is about the conversation you had with a company that USES atendIA, the one who answers is that company, which is the controller. We forward the request to it and notify you.

9. Security incident#

If an incident that may create a relevant risk happens, we notify the affected companies and the ANPD (Brazil's national data protection authority) within the LGPD deadlines, with what is known, what was done and what is still being done. The description of the technical measures is in Security and data.

10. Cookies and ad measurement#

This site uses two types of cookie:

• Necessary: the ones that make the site work and the record of your choice in Cookie preferences, stored in your own browser (and, if you turn it off, in the atendia-rastreio cookie, which is also read by the dashboard's sign-up page).
• Ad measurement (Meta Pixel): it turns on when you open the site, unless you have turned it off. With it on, Meta Platforms (owner of Facebook and Instagram) receives: the address of the page visited and of the previous page; whether the plans section appeared on screen; clicks on the free trial buttons (with the plan, the price and the part of the site where the button was) and on the contact ones (WhatsApp, email and phone); technical data of the browser (IP address, browser, screen size and time zone); and its own cookies, _fbp and, if you arrived by clicking a Meta ad, _fbc. It serves to let us know which ads bring customers and to show atendIA ads to those who already visited the site.
• Ad measurement (Google Ads tag): it turns on and off together with the Pixel. With it on, Google receives: the address of the visited page and of the previous page; technical data of the browser (IP address, browser, language and screen size); and its own cookies, _gcl_au and, if you arrived by clicking a Google ad, _gcl_aw, which stores the identifier of that click. Clicks on the site's buttons do not go to Google. It serves to let us know which Google ads bring customers and to show atendIA ads to those who already visited the site.

The legal basis is legitimate interest (article 7, IX of the LGPD): measuring the results of our ads, only with the data listed above and with your right to object guaranteed in one click (below). We process this data in accordance with the LGPD and do not publish or sell it. Meta processes it outside Brazil and also for its own purposes, as a controller, under Meta's Privacy Policy. Google does the same, under the Google Privacy Policy and the page How Google uses information from sites that use its services.

If the Pixel was on and you create an account in the dashboard, the dashboard tells Meta that the sign-up happened. These go without transformation: the plan chosen and that it starts on the free trial, the time, the address of the sign-up page, the IP address and the browser used, and the _fbp and _fbc cookies (the latter only if it exists). These go as a SHA-256 hash: your email, phone, country and the identifier of the account created, which also forms the notice code. A hash is not anonymization: Meta computes the same hash of the data on its own accounts to find the matching person. It is what tells which ad brought a customer. If you turned the Pixel off before signing up, the dashboard sends nothing.

If the Pixel was on at sign-up and you later pay the subscription, the dashboard tells Meta of the first payment, only once: subsequent monthly payments are not reported. These go without transformation: the amount paid and the currency, the time, and the same data as the sign-up notice (the address of the sign-up page, the browser used there and the _fbp and _fbc cookies, the latter only if it exists). These go as a SHA-256 hash: the billing identifier, which forms the notice code, and, as at sign-up, your email, phone, country and account identifier. The IP address does not go in this notice. For this the dashboard keeps this data from sign-up and deletes it when sending, or after 90 days if there is no payment. Turning the Pixel off afterwards, in Cookie preferences, does not reach what sign-up has already stored: to cancel this notice, use the channel in section 8 and we delete it.

The same Pixel also turns on in the dashboard's sign-up page (painel.atendiatec.com.br/signup), where Meta receives only the visit to the page: its address, the technical data of the browser and the _fbp and _fbc cookies. There too there is the Turn off link, and turning it off in either place applies to both.

The Google Ads tag also turns on in the dashboard's sign-up page. It receives the visit to the page and, if you create the account, a notice that a sign-up happened. In both cases what goes is the page address, the technical data of the browser and the _gcl_au and _gcl_aw cookies (the latter only if it exists). No form data goes to Google: no name, email, phone or document. It is what tells which Google ad brought a sign-up. If you turned measurement off before, none of this is sent.

To object at any time, use Cookie preferences, in the footer of any page: Turn off there for the Pixel and the Google tag, including in other open tabs of the site, deletes their cookies and is stored in your browser. Ad blockers also prevent both from loading.

11. Changes to this policy#

When we change something relevant, the date at the top changes and we notify customer companies by email. Previous version available on request through the DPO channel.

12. Who answers for this policy#

ATENDIA TECNOLOGIA LTDA, CNPJ 69.450.061/0001-57. R Visconde do Rio Branco, 1488, Conj 909, Andar 09, Cond Universe Life Square, Bloco Com., Centro, Curitiba / PR, CEP 80.420-210. General contact: [email protected]. DPO: [email protected].