Privacy policy

1. Who we are and what this policy covers

MVN DESENVOLVIMENTO DE SOFTWARE LTDA, CNPJ 54.121.767/0001-06, headquartered at Avenida Praia de Ponta Negra, 8892, Ponta Negra, Natal/RN, 59094-100, Brazil. Contact: contato@mvndevelopment.com.

This policy applies to:

• the website mvndevelopment.com;
• messages you send us by email;
• the AI agents on WhatsApp we operate for business customers;
• data about the people responsible for the businesses that hire our services.

Sonora (playsonora.com) and Trampeiro (trampeiro.com) have their own privacy policy and terms of use, published on each product’s website. Those documents govern those products.

2. Our role: controller or processor

On the website, in email contact and in our relationship with business customers, MVN is the controller: we decide how and why data is processed.

In the AI agents on WhatsApp, MVN is a processor. The agent serves the customers of a business that hired us. That business is the controller of the conversation data: it sets the purpose, the legal basis and how long the data is kept, and we process the data on its behalf and according to its instructions. If you talked to a business’s agent, you can contact that business directly or write to us; we will help and forward your request to the business when appropriate.

3. What data we process

When you visit the website

The website uses no analytics, no advertising and no tracking cookies. To deliver and protect the pages, Cloudflare, which hosts the site, processes technical request data such as IP address, browser, page visited, and date and time.

We use a single functional cookie, named lang, that stores the language you chose (Portuguese or English) for up to one year. It does not identify you and is not shared.

When you write to us

Your name, your email address and whatever you write in the message.

When you talk to an AI agent on WhatsApp

• the name and phone number on your WhatsApp profile;
• text messages, voice messages and their transcripts, photos and other files you send;
• the date and time of messages;
• whatever you choose to share in the conversation, such as your neighborhood, product measurements or the date you need something;
• the summary the agent prepares for the person at the business who will continue the conversation;
• usage data, such as message counts and processing cost.

The agent does not ask for sensitive data (such as health, religion or biometrics) or identity documents. Please do not send them.

When your business hires us

Name, email and phone number of the people in charge, company details, contract and billing data, and the content the business provides for the agent’s knowledge base.

4. Why we use data and on what legal basis

• Answering people who write to us and preparing proposals: legitimate interest and pre-contractual steps (LGPD, art. 7, V and IX).
• Keeping the website online and secure: legitimate interest (art. 7, IX).
• Operating the AI agents on WhatsApp: providing the service hired by the business customer, following its instructions. The legal basis for this processing is set by the business, as controller.
• Performing contracts and billing: performance of a contract (art. 7, V).
• Meeting legal and tax obligations and defending ourselves in legal proceedings: art. 7, II and VI.

We do not sell personal data, we do not use conversations for advertising and we do not train our own AI models on them.

The AI agent does not make decisions that affect your rights: it answers questions from the business’s knowledge base and hands the conversation to a person. Even so, you may request a review of any automated processing (art. 20).

5. Who we share data with

We share data only with providers needed to deliver the service (sub-processors), under contract and only for that purpose:

• Cloudflare: website hosting, DNS, security and email forwarding.
• Meta Platforms and WhatsApp: the channel messages travel through.
• Anthropic: AI models that read the conversation and write the replies.
• Google Cloud, including Gemini: AI models and cloud infrastructure.
• Our mailbox provider, where messages sent to contato@mvndevelopment.com arrive (currently Proton AG).

For the AI agents, the business customer that hired the service has access to the conversations with its own customers. We may also share data with authorities when required by law or court order.

6. International transfers

Some of these providers process data outside Brazil, mainly in the United States and the European Union. These transfers follow article 33 of the LGPD and rely on the contractual safeguards offered by the providers, such as data protection clauses.

7. How long we keep data

• Website technical logs: for as long as Cloudflare keeps them for operations and security.
• Emails: while the matter is ongoing and for up to two years after the last contact, unless it becomes a contract.
• AI agent conversations: for the period set by the business customer, during the contract. When the contract ends, we delete the data or return it to the business within 90 days.
• Contracts and tax records: for the periods required by law.

8. Security

We use encrypted connections (HTTPS and TLS), access limited to those who need it, passwords and keys stored outside the code, and providers with recognized security practices. No system is completely secure; if an incident could cause significant risk or harm, we notify Brazil’s National Data Protection Authority (ANPD) and the people affected, as the LGPD requires.

9. Your rights

Under article 18 of the LGPD, you may request at any time:

• confirmation that we process your data, and access to it;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or deletion of unnecessary or excessive data, or data processed in breach of the law;
• portability to another provider;
• deletion of data processed on the basis of your consent;
• information about who we share your data with;
• information about the option of not giving consent and its consequences;
• withdrawal of consent;
• objection to processing that does not comply with the LGPD.

To exercise any of them, write to contato@mvndevelopment.com. You may also file a complaint with the ANPD at gov.br/anpd.

10. How to request deletion of your data

You can ask us to delete your data at any time, including data from conversations with an AI agent on WhatsApp.

1. Send an email to contato@mvndevelopment.com with the subject Data deletion.
2. Tell us the WhatsApp number, with country and area code, that talked to the agent, or the email address you used to contact us. If you know it, also tell us which business you were talking to.
3. To make sure the request is yours, we may ask you to send a message from that number.

We reply within 15 days. We delete from our systems the messages, voice messages, transcripts, images and summaries linked to you, and we notify the business customer involved, which is the controller of that data.

Some data is not held by us and we cannot delete it for you: messages already in the WhatsApp app of the business you talked to, and copies kept by WhatsApp itself, which follow its own policy. We may also keep the minimum needed to meet a legal obligation, and only for that reason.

If you are a business customer, you can request deletion of all data in your account through the same email.

11. Children and teenagers

The website and the AI agents are not made for children. If we learn that we processed a child’s data without a guardian’s consent, we delete it.

12. Changes to this policy

We may update this policy. The date at the top of the page shows the latest change. If a change is significant, we notify business customers before it takes effect.

13. Contact and data protection officer

The channel for anything about your data, including contact with the person in charge of personal data processing (encarregado), is contato@mvndevelopment.com.

MVN DESENVOLVIMENTO DE SOFTWARE LTDA, CNPJ 54.121.767/0001-06, Avenida Praia de Ponta Negra, 8892, Ponta Negra, Natal/RN, 59094-100, Brazil.