Privacy Policy
Effective September 28, 2026 · Version 2.0
This Privacy Policy describes how WILLIAN LUAN DA SILVA & CIA LTDA, trade name Conexão Informática, which operates the Systemlog brand and platform (“Systemlog”, “we”, “us”), registered in Brazil under CNPJ 10.649.000/0001-70, located at R. São Paulo, 967, Sala 1, Centro, Lupionópolis/PR, ZIP 86.635-000, Brazil, collects, uses, shares, stores and deletes personal data.
It applies to the Systemlog website, the Systemlog ERP, our APIs and our application integrated with the WhatsApp Business Platform provided by Meta Platforms, Inc. (“Meta”). It follows the Brazilian General Data Protection Law (Law 13,709/2018 — “LGPD”), the Brazilian Internet Civil Framework (Law 12,965/2014) and the Meta Platform Terms. The Portuguese version prevails in case of discrepancy.
1. Who we are and our role
Systemlog is a software company that develops business management software and acts as a Tech Provider for the WhatsApp Business Platform, allowing business customers to connect their own WhatsApp Business accounts to our system to send and receive messages related to their operations.
- As a processor: when we process data on behalf of business customers (e.g. their end customers’ contacts and WhatsApp messages), the business customer is the controller and Systemlog is the processor, acting only on the customer’s instructions and contract.
- As a controller: for data from our own relationships — system users, business contacts, website visitors and business customers’ account data.
2. Data we collect
| Category | Examples | Source |
|---|---|---|
| System users | Name, email, department, role, login, password (stored hashed), permissions | Registered by the business customer |
| Access logs | IP address, date and time, browser, actions performed | Automatically generated |
| Operational data | Orders, deliveries, invoices, inventory, purchasing, addresses and contacts of the customer’s end customers | Entered by the business customer |
| WhatsApp data | Detailed in section 3 | Meta / WhatsApp Business Platform |
| Business contact | Name, email, phone, company and message | Provided by you |
We do not intentionally collect sensitive personal data (such as health, biometric, religious or political data) and we instruct business customers not to send it through the system or WhatsApp.
3. Data received from the Meta / WhatsApp platform
When a business customer connects its account to our app through Meta’s Embedded Signup and grants the whatsapp_business_management and whatsapp_business_messaging permissions, we receive and process:
- Business customer data: Business portfolio ID, WhatsApp Business Account (WABA) ID, phone number ID and business phone number, display name, verification and quality status, and the account’s message templates.
- Access token: a credential issued by Meta that allows our system to act on the customer’s WhatsApp Business account within the granted permissions.
- Data of people who message the business: phone number (WhatsApp ID), public WhatsApp profile name, content of sent and received messages (text, images, documents, audio and location, when sent), timestamps and delivery status (sent, delivered, read, failed).
Our commitments regarding Meta Platform Data:
- We use this data only to provide the service to the business customer that authorized it: sending, receiving, logging and displaying messages in that customer’s system.
- We do not sell, license or purchase Platform Data.
- We do not use it for advertising, profiling, ad targeting, surveillance, or to make eligibility decisions about credit, employment, housing or insurance.
- We do not share one customer’s data with another customer, nor combine data across customers.
- We do not use message content to train artificial intelligence models.
- We delete the data when no longer needed, when the customer disconnects the account, when the data subject requests it, or when Meta requests it.
4. How we use data
- Operate the ERP and integrations contracted by the business customer.
- Send, on behalf of the business customer, WhatsApp messages about its operations — order confirmation and status, delivery updates, internal approvals and customer support — only to contacts who gave the business customer their consent (opt-in).
- Receive and display replies so the business customer can assist its contacts.
- Manage message templates and the phone number of the customer’s WhatsApp Business account.
- Authenticate users, prevent fraud, investigate incidents and keep the services secure.
- Provide technical support and comply with legal, tax and regulatory obligations.
- Respond to business inquiries.
5. Legal bases (LGPD, art. 7)
- Performance of contract — providing the services to business customers and their users.
- Consent — for contacts to receive WhatsApp messages (collected by the business customer, who is responsible for obtaining and evidencing it).
- Legal obligation — retention of access logs (Internet Civil Framework, art. 15) and tax obligations.
- Legitimate interest — security, fraud prevention and technical improvement, always respecting data subjects’ rights.
6. Who we share data with
- Meta Platforms, Inc. / WhatsApp LLC — to transmit messages through the WhatsApp Business Platform, under the WhatsApp Privacy Policy and WhatsApp Business Terms.
- The business customer that controls the data — only its own contacts and messages.
- Infrastructure providers (hosting, storage, backup and email), bound by confidentiality and security obligations and prohibited from using the data for their own purposes.
- Public authorities, when required by law, court order or a competent authority.
- Successors, in case of merger, acquisition or reorganization, with the protections of this policy maintained.
7. International transfers
The WhatsApp Business Platform (Cloud API) is operated by Meta on servers that may be located outside Brazil, including the United States. When using the integration, message data is transferred to Meta under article 33 of the LGPD, for the performance of the contract and with the safeguards set out in Meta’s terms.
8. Data retention
| Data | Period |
|---|---|
| WhatsApp messages and delivery status | While the contract with the business customer is active, or up to 12 months after sending, whichever comes first, unless the customer instructs otherwise |
| Meta access token | Until the customer disconnects the account; deleted within 15 days of disconnection |
| WhatsApp Business Account and phone number IDs | While the integration is active; deleted within 15 days of termination |
| System access logs | 6 months (Internet Civil Framework, art. 15) |
| Operational and user data | During the contract; upon termination, returned to the customer and deleted within 90 days |
| Tax and contractual records | For the period required by law |
9. Security
- All communication is encrypted in transit (HTTPS/TLS).
- Access tokens and passwords are stored encrypted and never shown to users.
- Role-based and per-customer access restrictions, with audit logs of actions.
- Signature validation of webhooks sent by Meta.
- Regular backups, system updates and server monitoring.
If a security incident may cause relevant risk or harm, we will notify affected business customers, the Brazilian National Data Protection Authority (ANPD) and, when applicable, Meta and data subjects, within legal deadlines.
10. 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 unlawfully processed data;
- data portability;
- information about who we share your data with;
- withdrawal of consent and deletion of data processed based on it.
When we act as a processor, we forward the request to the responsible business customer and assist in fulfilling it. We respond within 15 days. You may also file a complaint with the ANPD (gov.br/anpd).
11. Data deletion and opt-out
- Stop receiving messages: reply SAIR (or STOP) in the WhatsApp conversation. The number is opted out immediately.
- Delete your data: email willianluan@gmail.com with the subject “Data deletion request”, including your phone number or email. We complete and confirm the deletion within 15 days.
- Business customers: can remove the Systemlog app’s access at any time in Meta Business Suite → Settings → Accounts → Integrations.
Full instructions (Portuguese): Data deletion instructions.
12. Cookies
The system uses only essential cookies to keep authenticated sessions and protect forms. We do not use advertising or third-party tracking cookies. The website loads fonts from Google Fonts, which sends the visitor’s IP address to Google solely to deliver the font files.
13. Children
Our services are intended for businesses and are not directed to anyone under 18. We do not knowingly collect children’s data; if identified, it will be deleted.
14. Changes to this policy
We may update this policy to reflect legal, technical or service changes. The current version and date are always shown at the top of this page, and relevant changes will be communicated to business customers in advance.
15. Contact and Data Protection Officer
WILLIAN LUAN DA SILVA & CIA LTDA — Systemlog
CNPJ 10.649.000/0001-70
R. São Paulo, 967, Sala 1, Centro, Lupionópolis/PR — ZIP 86.635-000, Brazil
Data Protection Officer (DPO): Willian Luan da Silva
Email: willianluan@gmail.com
Phone: +55 (43) 9689-7991