Afulink
Legal document

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

In ResidencialLink

In Arquivme

3. How we use it

4. Legal bases

ActivityLegal basis (LGPD, art. 7)
Answering the contact formConsent and pre-contractual steps
Providing the contracted servicesPerformance of a contract
Access logs and tax dataCompliance with a legal obligation
Security and fraud preventionLegitimate interest
Measurement cookiesConsent

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:

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.

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

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.