Privacy Policy — Whats-SE
This Policy describes how PAGOTTO SALES ENGINE TECNOLOGIA DA INFORMAÇÃO LTDA ("Sales Engine", "we"), registered under CNPJ 06.035.381/0001-20, with its registered office at Rua Conceição, 233, Sala 1006, Centro, Campinas/SP, CEP 13010-050, Brasil, processes personal data in connection with Whats-SE, an integration between WhatsApp and Bitrix24, in accordance with Brazilian Law No. 13,709/2018 (LGPD).
1. Roles (controller and processor)
We act as controllers for your account and Whats-SE usage data (registration, Bitrix24 portal and billing). For content you process through the tool (WhatsApp messages, contacts and files, and your customers’ CRM records), we act as processors on your behalf and according to your instructions.
2. Data we process
- Account/installation: Bitrix24 portal domain, identifiers (member_id), OAuth access tokens, administrator email and contact details.
- Operational: messages, numbers, names and files exchanged through WhatsApp; CRM records, contacts and deals linked to conversations.
- Billing: plan, subscription status and payment identifiers (processed by Stripe; we do not store full card details).
- Technical: request/error logs and usage metadata for security and support.
3. Purposes and legal bases
- Providing and operating the integration: performance of a contract (Article 7, V).
- Billing and fraud prevention: legal obligation and legitimate interest (Article 7, II and IX).
- Support, security and service improvement: legitimate interest (Article 7, IX).
- Marketing communications: only with consent (Article 7, I).
4. Sharing and subprocessors
We share data strictly to operate the service, with:
- Meta Platforms (WhatsApp Cloud API): sending and receiving messages.
- Stripe: processing subscription payments.
- Cloudflare: CDN, security and delivery.
- VPS/infrastructure provider: hosting Whats-SE and the Evolution engine.
- Bitrix24: the platform on which the application operates, as authorized by you.
We do not sell personal data.
5. International transfers
Some subprocessors (e.g. Meta, Stripe and Cloudflare) process data outside Brazil. We adopt appropriate contractual safeguards under Articles 33–36 of the LGPD.
6. Retention and deletion
We retain data for the duration of the relationship/subscription and for applicable statutory periods. When uninstalling the application in Bitrix24, if you choose to clear application data, we delete the data associated with your account from our systems, except records required by law.
7. Data subject rights
You may request confirmation of processing, access, correction, anonymization, portability, deletion and information about sharing by emailing [email protected].
8. Security
We adopt technical and administrative measures (encryption in transit, access controls and environment segregation) to protect data against unauthorized access and incidents.
9. Changes
We may update this Policy; the last updated date identifies the current version.
10. Contact / Data protection officer
PAGOTTO SALES ENGINE TECNOLOGIA DA INFORMAÇÃO LTDA — CNPJ 06.035.381/0001-20. Rua Conceição, 233, Sala 1006, Centro, Campinas/SP, CEP 13010-050, Brasil. Email: [email protected]. Telephone: +55 19 98960-1517.