Privacy Policy
Last updated: [PUBLICATION DATE]
This policy explains how Afulink Educação Tecnologia e Inovação LTDA processes personal data on the afulink.com website and in its products ResidencialLink and Arquivme, in accordance with Brazil’s General Data Protection Law (Law No. 13,709/2018 — LGPD).
1. Who we are
Afulink Educação Tecnologia e Inovação LTDA, registered in Brazil under CNPJ No. [CNPJ], headquartered at [FULL ADDRESS] (“Afulink”, “we”). For privacy matters, contact us at contato@afulink.com.br.
2. Data we process
On the website
- Contact form: name, email, WhatsApp number (optional), product of interest and the message you write.
- Cookie preference: your choice in the cookie notice, stored in your own browser.
- Technical data: IP address, browser type and pages visited, recorded automatically by the server.
In ResidencialLink
- Resident data entered by the building, such as name, unit (block and apartment), email and WhatsApp number.
- Package records: arrival date, package identification, recipient and pickup.
- Building Wi-Fi usage data needed to manage the network.
- Login data of building managers, front-desk staff and administrators.
In Arquivme
- User account data: name, email and access permissions.
- Files uploaded by customers, which may contain third parties’ personal data under the customer’s responsibility.
- Access and activity logs (who accessed, shared or changed each file).
3. How we use it
- To answer inquiries, present our products and send proposals.
- To provide the contracted services, such as notifying residents by email and WhatsApp when a package arrives.
- To keep accounts secure, prevent fraud and investigate incidents.
- To comply with legal and regulatory obligations, including keeping access logs as required by Brazil’s Internet Civil Framework (Marco Civil da Internet).
- To issue invoices and tax documents for contracts.
- To improve the website, only if you accept measurement cookies.
4. Legal bases
| Activity | Legal basis (LGPD, art. 7) |
|---|---|
| Answering the contact form | Consent and pre-contractual steps |
| Providing the contracted services | Performance of a contract |
| Access logs and tax data | Compliance with a legal obligation |
| Security and fraud prevention | Legitimate interest |
| Measurement cookies | Consent |
5. Our role in the products
For the data customers enter into ResidencialLink and Arquivme (for example, a building’s list of residents or a company’s documents), the customer is the controller and Afulink acts as the processor, handling the data only according to the customer’s instructions and the contract. Requests from data subjects about that data should first be sent to the building or company responsible; we support the customer in handling them.
For website data and our customers’ account data, Afulink is the controller.
6. Sharing
We do not sell personal data. We share only what is necessary with:
- Infrastructure: server, hosting and network providers that keep the systems running.
- Messaging: email and WhatsApp services used for notifications.
- Website fonts: the site loads fonts from Google Fonts, which sends your IP address to Google.
- Authorities: when required by law or court order.
Some of these providers may store data outside Brazil. In those cases, we apply the safeguards set out in articles 33 to 36 of the LGPD.
7. Cookies
Cookies and similar technologies are small records stored in your browser.
- Essential: needed for the site to work, such as remembering your cookie choice. They do not require consent.
- Measurement: help us understand how the site is used. They are only enabled if you click “Accept all”.
You can change your choice at any time:
8. Security
We use encrypted connections (HTTPS), role-based access control, encrypted password storage, backups and activity logs. No system is completely immune to failure; if an incident occurs that may pose a relevant risk to data subjects, we will notify those affected and Brazil’s National Data Protection Authority (ANPD), as the law requires.
9. How long we keep data
- Website inquiries: up to [PERIOD, e.g. 12 months] after the last contact, if no contract follows.
- Product data: while the contract is active. After termination, data remains available for export for [PERIOD, e.g. 30 days] and is then deleted.
- Access logs: at least 6 months, as required by the Marco Civil da Internet.
- Tax data: for the period required by tax law.
10. Your rights
Under the LGPD, you may request: confirmation that we process your data; access; correction; anonymization, blocking or deletion of unnecessary data; portability; information about sharing; and withdrawal of consent. You may also file a complaint with the ANPD.
To exercise any right, write to contato@afulink.com.br. We may ask for information to confirm your identity before responding.
11. Data protection officer
Data protection officer (Encarregado): [OFFICER NAME] — contato@afulink.com.br.
12. Changes
We may update this policy. The date of the last update appears at the top of this page and, for relevant changes, we will notify customers through their registered contact channels.
The Portuguese version of this policy prevails in case of any discrepancy between translations.