Privacy Policy

1. Introduction

Manda4 Tecnologia Ltda. ("Manda4", "we" or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store and protect information when you use Manda4 Jarvis IA.

This policy applies to all users of Manda4 Jarvis IA and observes the Brazilian General Data Protection Law (LGPD) and the European Union General Data Protection Regulation (GDPR).

2. Information we collect

2.1 Account data

• Full name and contact information
• Email address and phone number
• Company information (name, tax ID, address)
• Identifier of the Bitrix24 portal where the application is installed
• Billing and payment data

2.2 Usage data

• Access and activity logs
• IP addresses and device information
• Bot, agent and flow configurations you create
• Usage and performance metrics

2.3 Content processed by artificial intelligence

• Text messages exchanged between the bot and your customer
• Voice messages sent by the customer and their transcriptions
• Instructions and prompts you configure for the agents
• Responses generated by Manda4 Jarvis IA
• Record of actions the agents performed in your CRM

2.4 Data accessed in Bitrix24

• Leads, contacts, companies and deals needed to answer
• Product catalog, when catalog lookup is enabled
• Calendar appointments, when scheduling is enabled
• Interaction history related to the ongoing conversation

Access uses official Bitrix24 authentication and is limited to the permissions granted when the application was installed.

3. How we use information

3.1 Service delivery

• Provide and maintain Manda4 Jarvis IA
• Generate AI-powered service responses
• Perform the actions you authorized in your CRM
• Process and manage your account and subscription

3.2 Service improvement

• Analyze usage and performance to fix defects
• Develop new features
• Investigate incidents you report

3.3 Communication

• Send important service notifications
• Provide technical support
• Inform you about updates and new features

3.4 Legal compliance

• Meet legal and regulatory obligations
• Respond to requests from competent authorities
• Protect Manda4's rights and property

4. Processing by artificial intelligence

4.1 We do not use your data to train third-party models

Conversation content and your CRM data are not used to train third-party artificial intelligence models. Any use to improve Manda4's own models occurs only in aggregated and anonymized form, without identifying your company or your customer, or with your specific authorization.

4.2 Voice transcription

When your customer sends a voice message, Manda4 Jarvis IA transcribes the content in order to interpret it and reply. The audio and the transcription are treated as conversation content and follow the same retention policy described in section 7. It is your responsibility to inform your customers about this processing where applicable law requires it.

4.3 Automated decisions

Manda4 Jarvis IA performs actions in the CRM according to the configuration you define, such as creating a lead, moving a deal to another stage or booking an appointment. These actions are operational and do not constitute automated decision-making with legal effect on the data subject. If your configuration leads the Software to interfere with such a decision, you are responsible for ensuring human review and for the rights to information and review provided by the LGPD.

4.4 Disclosure of automated service

We recommend configuring the bot to identify itself as automated service. Besides being good transparency practice, it is a requirement in some jurisdictions and in some messaging channel policies.

5. Legal basis and processing roles

We process personal data on the following legal grounds:

• Contract performance: to provide the contracted service
• Consent: when you give us specific permission
• Legitimate interest: for service security and improvement
• Legal obligation: to meet legal requirements

Regarding your customers' data processed within Manda4 Jarvis IA, you act as controller and Manda4 acts as processor, handling data according to your instructions. Defining the legal basis and informing data subjects is your responsibility.

6. Data sharing

6.1 We do not sell your data

Manda4 never sells, rents or trades personal data to third parties.

6.2 Authorized sharing

We share data only in the following situations:

• Infrastructure providers: hosting and services that support the Software, under confidentiality agreements
• Bitrix24: as needed for the integration and to record the outcome of the conversation in your CRM
• The messaging channel you connect: to the extent needed to deliver the response to your customer
• Legal obligation: when required by law or court order

7. Security and retention

7.1 Retention periods

We keep personal data only as long as necessary for the purposes described in this policy, unless a longer period is required by law:

• Account data: for the subscription term and 5 years after termination
• Conversations, audio and transcriptions: according to the configuration you define
• System logs: 2 years, for security and audit purposes
• Financial and tax data: as required by applicable law

8. Your rights

You have the following rights regarding your personal data:

8.1 Rights under LGPD

• Confirmation and access: know whether we process your data and what it is
• Correction: correct incomplete, inaccurate or outdated data
• Anonymization, blocking or deletion: of unnecessary data or data processed unlawfully
• Portability: receive your data in a structured format
• Information about sharing: who we share your data with
• Objection and withdrawal: object to processing and withdraw consent

8.2 How to exercise your rights

Write to [email protected]. If you are an end customer of a company that uses Manda4 Jarvis IA, please direct your request to that company, which is the controller of your data. We can assist them in fulfilling the request.

9. International transfers

Some infrastructure providers may be located outside Brazil. Where international transfer occurs, we adopt safeguards such as:

• Standard contractual clauses
• Assessment of the destination country's level of protection
• Other legally recognized guarantees

10. Cookies and similar technologies

The Manda4 Jarvis IA dashboard uses cookies and similar technologies to:

• Keep you authenticated
• Remember configuration preferences
• Analyze service usage
• Strengthen security

You can control cookies in your browser settings.

11. Minors

Manda4 Jarvis IA is intended for business use and not for individuals under 18. We do not knowingly collect personal data from minors. If we identify such collection, we will take steps to delete the information.

12. Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or within Manda4 Jarvis IA. We recommend reviewing this policy regularly.

13. Data Protection Officer (DPO)

Our Data Protection Officer is available to clarify questions about this policy and your rights:

14. Contact

For questions about this Privacy Policy or about your personal data: