Privacy Policy

Who processes your data

In this policy, “we”, “our” and “Wodi Consultoria” refer to the company above. “Platform” means the artificial-intelligence agent system we operate for our corporate customers.

Three different positions, and why that matters to you

The Platform is sold to companies that use it to talk to their customers. That is why we process data in distinct positions, with different responsibilities (LGPD, art. 5):

We are CONTROLLERS — we decide how and why to process — in relation to:

• data of people who contract or evaluate our services (name, corporate email, phone, company);
• Platform user access data (login email, role, audit records);
• data of people who submit forms on our site.

We are PROCESSORS — we process under the contracting customer’s instructions, and that customer is the controller — in relation to:

• contacts, leads and end customers that the contracting company registers or receives;
• conversations that agents conduct on its behalf (WhatsApp and email);
• the knowledge base, documents and collections portfolios it loads;
• calendar agendas it connects.

When we approach companies at a customer’s request. Our customers use the Platform to approach companies that are not yet their customers. In those cases, the customer is the controller — they decide whom to approach and why — and Wodi Consultoria acts as a processor, executing the outreach under their instructions and with the safeguards described in section 8. If you received a message from us and want to know who determined the contact, reply to it: we identify the controller and forward your request.

If you are an end customer of a company that uses our Platform and want to exercise rights over your data, the controller is that company. Send the request to them; if you write to us, we will forward it to the controller and help them respond.

Data we process and why

3.1 Platform registration and use

Email, password (stored only as a hash), access role and audit records of actions performed. Purpose: authenticate, control permissions and maintain an accountability trail. Legal basis: performance of a contract.

3.2 Contacts and conversations

Name, email, phone, company, job title and the content of messages exchanged over WhatsApp and email. Purpose: allow the contracting company’s agent to serve, qualify and schedule meetings. Legal basis: performance of a contract (for the contracting customer) and legitimate interest or consent, as applicable, in the relationship between that company and its contacts.

Audio, images and documents. We do not keep the files. When a contact sends media over WhatsApp, we store only a reference to it at the provider; when the conversation is opened, the file is fetched from the source at that moment and displayed, without passing through our storage. Audio may be transcribed so the agent can understand the message, and in that case the text of the transcription is stored with the conversation — like any other message.

3.3 Identity verification on forms

When someone fills in a contact form on a site that uses the Platform, we send a confirmation code to the email or WhatsApp provided. We store the address, phone number, timestamp, IP address and browser agent. Purpose: prove that the person owns the contact details provided before any automatic reply — this protects third parties from receiving messages because someone else entered their details. The code is stored only as a hash, never in readable form. Legal basis: legitimate interest in security and abuse prevention.

3.4 Contact data of prospected companies

For the prospecting feature, we process data that appears in public sources: Brazil’s National Register of Legal Entities (CNPJ) from the Federal Revenue Service — legal name, CNAE, address, size, registration status and the email the company itself declared in the registry — and information published openly on the company’s website. We do not buy contact lists, do not use non-public sources, and do not collect data on individuals outside a professional context.

If you received a message from us, section 8 was written for you.

3.5 Calendar agendas

See section 4, which is dedicated to this because Google has specific requirements.

3.6 Third-party system credentials

When a customer connects their email inbox, WhatsApp number or calendar, we store the credentials encrypted in our own vault. They are decrypted only at the moment of use, inside the process that runs the operation, and never appear in screens, API responses, system logs or in the context sent to language models.

Data obtained from Google (Google Calendar)

This section describes, in detail, how we process data obtained through Google APIs.

4.1 What we request, and why exactly that

We request two scopes, and nothing more:

We also request openid and email, used solely to show which account was connected (for example, name@company.com) on the administration screen.

We do not request the auth/calendar scope, which would give broad access to the calendar and its settings. We ask for the minimum needed for the feature.

4.2 What we do NOT read

We do not read the content of your events. Availability queries use the freeBusy endpoint, which returns only start and end intervals of busy periods. Titles, descriptions, attendees, attachments and locations of existing appointments are not accessed, not stored and not sent to language models. The only events whose content we know are those the Platform itself creates — meetings scheduled by the agent.

4.3 What we store

• the access refresh token, encrypted in a vault;
• the email address of the connected account, for identification on screen;
• busy intervals only in memory, while calculating times to offer — they are not written to a database;
• for each meeting we create, the event identifier and the video-call link, to allow cancellation and display in the Platform.

4.4 Limited Use

Our application’s use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

• we use the data only to offer and manage meeting scheduling, which is the feature visible to the user who authorized access;
• we do not transfer that data to third parties, except when needed to provide or improve the feature, to comply with law, or in a corporate transaction, always with consent when required;
• we do not use that data for advertising, advertising-profile creation, resale, or training of artificial-intelligence models, generalized or otherwise;
• we do not allow people to read that data, except with the user’s specific consent, for security purposes, to comply with law, or when the data is aggregated and anonymized.

4.5 How to revoke

Authorization may be revoked at any time at myaccount.google.com/permissions or by removing the calendar on the Platform administration screen. Revocation immediately stops availability queries and creation of new events. Meetings already created remain on your calendar — they are your appointments, and deleting them without your request would alter your agenda.

The same treatment described in this section applies to the Microsoft Graph integration (Outlook / Microsoft 365), with equivalent scopes.

Artificial intelligence and sending content to model providers

The Platform uses third-party language models to draft messages, qualify contacts and summarize conversations. That means the content of conversations and of the customer’s knowledge base is sent to those providers for processing, at the moment the agent acts.

• Providers used: Anthropic (default), OpenAI (fallback and audio transcription) and Google/Gemini (last resort), through our integration layer — the same three in section 6, and no others.
• Audio received in conversations may be transcribed by a third-party service (today, OpenAI) so the agent can understand the message.
• We contract those providers under enterprise terms in which content sent is not used to train their models.
• Credentials, secrets and calendar data (section 4.2) are not sent to models.
• A prospected company’s email address is also not sent to model providers. The agent works with the CNPJ — legal-entity data — and the recipient is resolved by the Platform at send time, after human approval.
• We choose the provider, not the customer, and automatic failover for unavailability only reaches the three above: that is a system restriction, not an intention.

Who we share with

We share data only with those necessary for the service to work:

The three model providers are on this list because they are the three the system can reach — and no others. The Platform chooses the model (it is not a customer option), and automatic failover for unavailability can only fall on a provider whose contractual chain has been verified. A subprocessor list that promises less than the system does is the defect this section exists to avoid.

About third-party model routers. The Platform has a ready integration with a router that resells models from other vendors, but no conversation is routed to it — neither by model choice nor by unavailability failover. If that changes, it and the destination provider become subprocessors and are added to this table before the first message goes out.

Our own audience measurement is intentionally omitted from this list: we run it on our own infrastructure (self-hosted), so site audience data is not sent to any third party. It remains under the same security regime as the rest of the Platform.

We do not sell personal data and do not share it for third-party advertising.

We may disclose data when required by law, court order or competent authority request, and in a corporate reorganization, in which case this policy will continue to be observed by the successor.

Security, isolation and retention

Isolation between customers. Each contracting company has data isolated in the database by a rule applied in the database server itself, not only by a filter in application code.

Secrets. Third-party credentials are encrypted at rest and decrypted only at the moment of use. Passwords are stored only as hashes, with an algorithm designed for that purpose.

Audit trail. Relevant actions are recorded with author, time and result.

Backups. They are generated daily, encrypted before leaving the server and stored off it. The decryption key does not live in the infrastructure that generates the backup.

Retention periods

Why a “do not contact me again” request is NOT deleted. When someone asks to stop receiving messages, we keep that request linked to the address or phone that made it. Deleting it together with other data would have the opposite effect: the person would become contactable again the first time that contact re-entered the Platform. Keeping the record is what honors the objection — and it holds only the minimum needed for that.

About backups and deletion. Once the periods expire — or a deletion request is fulfilled — the data is removed from production systems immediately. It may still exist in backups until the periods in the table above expire, when it disappears from those too. Backups are encrypted and used exclusively for restoration in case of an incident.

If you received a prospecting message

Where your address came from. From Brazil’s public CNPJ registry, where the company itself declared it, or from the company’s website. We use no other source, do not buy lists, and do not obtain addresses from third parties.

Legal basis. Legitimate interest (LGPD art. 7, IX) in offering products and services to companies whose profile matches what we serve, with the safeguards described below.

How to stop receiving messages now. Reply to the message with the word sair. Removal is immediate and lasting: the address enters a do-not-contact list checked on every send, across all channels, and does not depend on who asked us to approach you. You may also use the unsubscribe link or header that accompanies the message.

The safeguards we apply.

• We only use an address when it reaches the company itself. Addresses that would reach a third party — accounting, agency or hosting, for example — are refused.
• Every cold send goes through human approval before it goes out.
• Every message carries information on where the address came from and how to opt out.
• There is a send cap and an automatic brake by bounce rate.
• Your address is not sent to artificial-intelligence providers (section 5).

Your rights. You may at any time object to the processing (art. 18, §2), request confirmation and access to the data we hold about you, its correction and its erasure. Write to contato@tideseek.com.

What we keep after you opt out. Only the record that you asked not to be contacted, linked to the address — and for an indefinite period, for the reason explained in section 7.

Your rights

Under Brazil’s LGPD (Law 13.709/2018), you may request: confirmation that we process your data; access to the data; correction of incomplete or outdated data; anonymization, blocking or deletion of unnecessary data or data processed in non-compliance; portability; information about sharing; withdrawal of consent; and opposition to processing based on legitimate interest.

To exercise any of them, write to contato@tideseek.com. We will respond as soon as possible and, in any case, within the timelines provided by law. We may ask for additional information to confirm your identity — which prevents a third party’s request from exposing your data.

If you are an end customer of a company that uses the Platform, see section 2: that company is the controller.

How we handle an erasure request (art. 18, IX)

Once the controller has granted the request, we delete: conversation history on both channels, including the team’s internal notes; received messages, with the original content and the media reference; content of forms filled on the site; pending reply drafts and the context in use by the agent; the service text in the search index; and your name from within meeting records.

We retain, and the reason for each:

• Your registration row, without the name (replaced by an em dash). It cannot be deleted because business records point to it — deleting it would destroy, along with it, collections and opportunities of third parties.
• Open collections, opportunities and meetings already held. The data subject has a right to erase their data, not to erase the existence of a contract in performance (art. 16, I).
• Your phone or email, exclusively on the do-not-contact list. Without knowing who refused, the next campaign would contact you again: keeping that minimum is what honors your objection, and is what art. 16 authorizes. No content remains associated with it.
• The audit record of the erasure itself, which proves the act while storing an internal identifier — never your phone or email.

What erasure does not reach. Data that lives outside the Platform: the contracting company’s own management system, its email inbox, the conversation history on the device of whoever spoke with you, and meeting events already created on the calendar of the professional who served you — those are appointments between two people, and we do not alter them on our own. A meeting still to happen is flagged to the contracting company at the moment of erasure, so they can decide whether to cancel and notify you.

Timeline: we respond within 15 days (art. 19, §1).

Data Protection Officer (LGPD, art. 41): Ricardo Wodianer de Mello, reachable at contato@tideseek.com.

Where your data lives, and international transfers

The Platform is operated on infrastructure located in Brazil (Campinas/SP). Production data — contacts, conversations, knowledge base and collections portfolios — is processed on national territory.

There are two exceptions, and they are international transfers:

1. The third parties in section 6 that operate outside the country — language-model providers, Meta (WhatsApp) and Google Analytics 4 — process data in the United States.
2. Backups are stored, encrypted, in storage located in the eastern United States. The vendor does not offer a South America region; the decision is deliberate and copies leave the server already encrypted, with the key kept outside that environment.

These transfers occur under the hypotheses of LGPD art. 33, through contractual clauses that ensure an adequate level of protection.

In the case of Google Analytics, the transfer only happens after your consent on the site banner (section 11). If you refuse, no data is sent.

Our own audience measurement does not create a transfer to a third party, because the tool runs on our infrastructure — the data does not leave our environment.

Cookies and audience measurement

Inside the Platform (authenticated area) we use only browser local storage, to keep your session and theme preference. There are no advertising cookies or third-party trackers in the authenticated area.

On the institutional site we use two measurement tools, with different treatments:

You choose. The banner shown on the first visit lets you accept or refuse measurement by cookies. While you do not accept, Google Analytics is not loaded and no data is sent to it. Refusal does not limit access to the site or any functionality. The choice can be changed at any time via the same banner.

Google Analytics processes data in the United States (see section 10) and operates with anonymized IP. We do not enable Google Analytics advertising features: site audience data is not used to create advertising audiences, remarketing or ad profiles.

Children

The Platform is intended for corporate use by people 18 or older. We do not knowingly collect data from children or adolescents.

Changes

We may update this policy. The date at the top shows the latest revision; material changes will be communicated to contracting customers through usual channels.

Contact

Wodi Consultoria — Ricardo Wodianer de Mello LTDA · CNPJ 44.189.505/0001-11
contato@tideseek.com