Privacy Policy

1. Who we are

Corporate name: Nvoip Plataforma de Comunicação Ltda
CNPJ: 30.910.196/0001-12
Address: Av. Barão do Rio Branco 5129, rooms 201 and 202, CEP 36026-500, Juiz de Fora – MG
Our website address is: https://www.nvoip.com.br

This Policy explains how we collect, use, share and protect personal data and how you can exercise your rights. Our privacy policy is applicable to website visitors, leads, Customers and end users treated via CPaaS (Voice, WhatsApp, Chat, Social Networks), according to the role of Nvoip (controller or operator) indicated below. The policy extends to the site’s subdomains.

2. Scope and roles (controller and operator)

• Controller: for account and relationship data (registration, billing, support, regulatory compliance, dashboard access logs, usage metrics) and visitor data of the website.

• Operator (processor): when we process data under customer instructions (e.g.: content and metadata of calls/WhatsApp, contacts served in chat, recordings, transcripts, metrics per queue/agent), including necessary sub-operators. (Based on the ANPD Agent and Officer Guide.)

3. Data we collect

3.1 Registration/account data: name, email, company, CNPJ/CPF, address, telephone, position, access credentials, internal IDs.
3.2 Billing and tax data: payment methods, billing/note history, audit trails.
3.3 Technical and platform usage data: IP, device/UA, access and event logs, configurations, integrations, tokens (masked), operational metrics.
3.4 Telecommunications data and messages (when operator): call metadata (CDR), queues, agents, recordings (if activated by the customer), WhatsApp messages (metadata and content when applicable to the contracted service), attachments sent by the customer/holder.
3.5 Support/service: tickets, recordings and support chats.
3.6 Cookies and similar technologies: strictly necessary, functional, performance/analytics and advertising (when enabled). See Section 8 (Cookies).

3.7. Advertising measurement data: where valid permission exists, we may process advertising and click identifiers, traffic source and campaign, pages visited and technical browser or device information, technical event identifier, event date and type and, for eligible purchases, value and currency. Data that can be linked to an individual is not anonymous merely because it uses technical identifiers. This measurement does not include call content, recordings, transcripts, messages, CRM contacts or end-customer data processed by our customers.

4. Purposes and legal bases

(a) Contract execution and preliminary procedures (onboarding, support, SLA, functionality delivery);
(b) Compliance with legal/regulatory obligation (e.g. Anatel requirements, tax and security obligations);
(c) Legitimate interest (continuous improvement, fraud/abuse prevention, security, product analytics – with balancing and impact tests on the owner);
(d) Consent, when necessary (e.g. marketing communications, non-essential cookies).

Measurement of our own campaigns: the purpose is to measure the source of visits, completed registrations and paid subscriptions or purchases, attribute results to Nvoip campaigns and assess their effectiveness. This is an optional advertising purpose, separate from contract performance, subject to the specific choice described in section 8.

5. Sharing with third parties (operators/sub-operators)

Data Sharing. Personal data may be shared strictly when necessary, observed:

• Service providers contracted to enable the execution of the contract and technical operation (e.g. hosting, message delivery, anti-fraud, support), under instructions from Nvoip and with security and confidentiality measures;

• Public authorities and regulatory bodies, when there is a legal/regulatory obligation or valid requests;

• Strategic partners upon consent of the holder, when applicable (e.g. marketing communications).
  Nvoip does not sell personal data. Some providers process data outside Brazil. The destination country of each transfer, and whether or not it is covered by the ANPD standard contractual clauses, is described in section 6 and in the Security and Privacy Center.

Recipients and responsibilities: the centralized list of providers and recipients, purposes and information about processing locations is available in our Security and Privacy Center (in Portuguese). Each third party’s role depends on the service and processing activity: advertising providers should not be presumed to be processors in every case. The list supplements this Policy without expanding the purposes or replacing the applicable permission.

6. International transfers

Some of Nvoip’s providers process data outside Brazil, mainly in the United States. For part of them, the transfer is covered by the standard contractual clauses approved by the ANPD (Resolution CD/ANPD No. 19/2024), incorporated into the provider’s contract. For the others, the provider’s contract does not yet include those clauses: in these cases the confidentiality, security and deletion obligations of the provider’s contract apply. The list by provider, with purpose, destination country, data and applicable contract, is in the document International data transfers (in Portuguese), in the Security and Privacy Center. You may ask the Data Protection Officer, at [email protected], for the full text of the standard clauses used, which we send within 15 days, with trade and industrial secrets preserved.

7. Information security

We apply technical and organizational measures proportional to the risk: encryption in transit, access controls, segregation of environments, event recording, monitoring, vulnerability management, backups and periodic tests. (Without prejudice to applicable sectoral obligations.)

8. Cookies and tracking preferences

8.1. Cookies and choices: strictly necessary cookies enable the website and the recording of preferences. Optional categories, where available, remain disabled until the corresponding choice is made. The notice and preference center allow you to accept, reject or configure advertising measurement; essential cookies do not authorize this measurement.

8.2. Advertising measurement: the measurement described in sections 3.7 and 4 may use cookies, pixels and browser tools or server-to-server communications. Nvoip acts as controller for measurement of its own campaigns. Recipients and purposes are identified in the Security and Privacy Center (in Portuguese). Customer content processed through the platform is not used for this purpose.

8.3. Website and your own Dashboard: where the notice expressly covers both the website and Dashboard, a valid advertising measurement choice made on the website may be linked automatically to the same individual’s registration or authenticated access, without a separate confirmation for each advertising network or additional registration or purchase checkboxes. The choice does not extend to other individuals. A later preference explicitly set in the Dashboard must be respected.

8.4. Records and validity: the choice is recorded with purpose, scope, notice version and date. Its reuse between website and Dashboard has an operational validity of up to 30 (thirty) days, without renewal through browsing or access alone. Older website-only permissions, registration alone, general acceptance of terms or essential cookies will not be converted into advertising permission for the Dashboard. Permission will not apply retroactively to events preceding the applicable choice.

8.5. Refusal and withdrawal: you may refuse, change or withdraw your choice free of charge in the website cookie preferences and Dashboard privacy preferences, without preventing registration, access, purchase or use of services. The current preference is checked before new collection or transmission that relies on this permission; refusal, withdrawal or expiry stops that processing. Withdrawal does not automatically erase events already received by third parties, without prejudice to applicable rights and erasure requests.

8.6. Enabling the new scope: reuse between website and Dashboard may only be used once consistent notices and corresponding controls are available in both environments. Until enabled, the scope actually presented when the individual made their choice remains applicable. Updating this Policy alone does not create or expand existing permissions.

9. Data Retention and Disposal

9.1. General principles. Nvoip keeps data for as long as necessary to fulfill the purposes informed to the holder and/or the applicable legal and regulatory obligations, observing the principles of necessity and minimization. At the end of the retention periods, the rule is irreversible anonymization: the record remains, without identifying anyone, for reports and statistics. Deletion is limited to what cannot be anonymized or should not be kept: audio files of call recordings; attachments to messages and support tickets; identification documents and supporting documents; the technical configuration of closed accounts (such as extensions, IVR, queues and flows); backups, which expire with their own retention window; and audit trails, log files and temporary copies, which expire or are deleted at the end of the period. (LGPD, arts. 15 and 16).
In telecommunications services with numbering resources, Anatel requires the storage of certain records for specific minimum periods; Nvoip complies with these sectoral rules.

9.2. Rules by data category. Without prejudice to longer legal/regulatory deadlines, the following guidelines apply, where appropriate:

• Account registration, user profiles and settings on the Dashboard: kept during the term of the contract. After closure, the account is kept, blocked, for 6 (six) months and can be reactivated during that period. Accounts without movement for 6 (six) months are closed automatically, with prior notice; any new movement reactivates the account and restarts the count. Once 6 (six) months have passed since closure, the registration data and user profiles are anonymized and the account’s technical configuration is deleted; from then on, the same e-mail address and the same CPF or CNPJ (Brazilian taxpayer number) can be used for a new registration.

• Registration data of closed accounts: name or company name, CPF or CNPJ, e-mail address, telephone number, address and account number are kept for 5 (five) years from closure, in a separate record with restricted access, to comply with Anatel’s requirement (Anatel Resolution No. 777/2025, General Regulation of Telecommunications Services, art. 120, I) and to respond to requests from authorities. This record is not used for commercial purposes and does not prevent a new registration. At the end of the period, it is anonymized.

• Application access logs (panel/portal): kept for a minimum term of 6 (six) months, according to the Civil Rights Framework for the Internet, and may be kept for an additional period as long as necessary for security, fraud prevention and defense of rights during the contractual term; at the end, records stored in the database are anonymized, and log files and audit trails expire under the automatic retention rule.

• CDR/Billing records and call metadata (services that allow telephone traffic): kept for 5 (five) years (Anatel Resolution No. 777/2025, General Regulation of Telecommunications Services, art. 120, II and III); at the end, anonymized.

• Call recordings (IVR/customer service): kept while the contract remains active, for the period of the contracted plan, published on the plans page (https://www.nvoip.com.br/en/plans/). On the date of this version: 12 (twelve) months on Startup, 36 (thirty-six) months on Basic and 5 (five) years on PRO; the Free plan does not include recording. Recordings older than the plan’s period may be deleted; before any deletion based on the plan’s period, the account administrator is notified by e-mail 90, 30 and 7 days in advance. If the plan with recording is cancelled, the recordings are kept for 6 (six) months and then deleted, with the same notices. If the account is closed, the recordings are deleted once 6 (six) months have passed since closure. In every case, what is deleted is the audio file; the call record is kept.

• Billing/accounting (notes, invoices, receipts, taxes): 5 (five) years (tax legislation; Anatel Resolution No. 777/2025, art. 120, I; defense of rights). At the end, records are anonymized and invoice and receipt files are deleted.

• Support tickets and attachments: maintained during the relationship and, after, kept for an additional period necessary to defend rights (e.g. until 5 years). Upon customer request, Nvoip anonymizes the content (removal of personally identifiable data), subject to conservation hypotheses due to legal/regulatory obligation. At the end of the period, the content is anonymized and the attachments are deleted.

• Marketing (leads/consents/opt-out): until revocation of consent or opt-out exercise, or for a period compatible with the commercial cycle, with revalidation when applicable. At the end, records are anonymized.

• Security incident records: minimum of 5 (five) years, including incidents not communicated to the ANPD and the holders, in accordance with the Security Incident Reporting Regulation (Res. CD/ANPD nº 15/2024, art. 10); when communicated, deadlines for 3 business days for communication and 20 working days to complement information.

9.3. International transfer, operators and sub-operators. The contracts with operators/sub-operators include contractual obligations of confidentiality and security (art. 39). International transfers, with the destination country and the contract applicable to each one, are described in section 6 and in the Security and Privacy Center.

9.4. Backups and restore windows. Backups follow technical retention windows and are not edited: the data is permanently gone when the last backup that contains it expires.

9.5. Prevalence of specific norm. In case of divergence between these guidelines and legal/regulatory obligations (ex.: Anatel or Civil Rights Framework for the Internet), the specific standard prevails, including minimum storage periods.

9.6. Advertising measurement and choice records: operational validity of up to 30 days is not the retention period for all records. Attribution data and choice audit records will be kept only as long as needed for the stated purposes and to demonstrate permission or meet applicable legal obligations, with restricted access and data minimization. Once no longer needed, they will be anonymized or, in the case of files and temporary copies, deleted, subject to lawful retention exceptions. Tax and telecommunications retention periods will not be applied indiscriminately to advertising data; specific criteria will be reviewed by the Data Protection Officer and made available to individuals.

10. Rights of holders and time limits

You can request: confirmation of treatment; access; correction; anonymization, blocking or deletion; portability; information about shares; opposition; automated decision review (if any).

• Immediate (simplified) confirmation; access/complete declaration within 15 days.

• Other rights: response within a deadline compatible with the complexity, preferably within 15 days.

11. How to exercise your rights

Send your request to Person in Charge (DPO): [email protected]. To protect you, we may confirm your identity. If we act as operator for a customer, we will forward your request to the controller where appropriate, maintaining traceability.

12. Automated decisions and profiling

When there are relevant automated decisions (e.g., detection of abuse/fraud, blocking of malicious traffic), we will inform general criteria and we will offer means of human review, when required by law.

13. Security incidents

If an incident could result in relevant risk or damage, we will notify ANPD and holders within 3 business days from becoming aware of it, and may provide additional information within 20 business days, according to RCIS (Res. CD/ANPD nº 15/2024). We will maintain a record of incidents in accordance with regulation.

14. Children and teenagers

Our services are B2B and B2C. We do not direct the website to children or teenagers. If we identify data from children/adolescents without the appropriate legal basis, we will securely delete them.

15. Updates to this Policy

We will indicate the effective date and the version when updating this Policy. Material changes will be communicated via product/website channels.

Policy version: 2026-10-12. Updated on October 12, 2026.

16. Contact of the Person in Charge (DPO)

Leandro Wesley Campos – [email protected]