Draft for internal review. Passages highlighted as [TO DEFINE] or [TO REVIEW] must be reviewed before publication.
1. Who we are and who this policy applies to
Ánapse is a process mining platform provided by [TO DEFINE: D2Solutions legal name], registered under CNPJ no. [TO DEFINE: CNPJ], headquartered at [TO DEFINE: full address] (“Ánapse”, “we”).
This Policy explains how we process personal data of people who visit the website, create an account or use the platform, in accordance with the Brazilian General Data Protection Law (Law No. 13,709/2018 — “LGPD”) and the Brazilian Internet Civil Framework (Law No. 12,965/2014). It complements the Terms of Use.
Ánapse acts in two different roles, depending on the type of data:
- Controller of your account data and platform usage data (sections 2 and 3), because we decide how and why this data is processed.
- Processor of any personal data contained in the event logs you upload (section 4). In this case, you (or the company you represent) decide, and we process that data only to produce the analyses you request.
2. Data we collect
| Category | Data | How we obtain it |
|---|---|---|
| Sign-up | First name, last name, username, email and password (stored only in irreversible hashed form — we never have access to the password itself). | Provided by you when creating the account or in My account. |
| Projects | Project name and description, chosen plan, mapped columns (case, activity, timestamp, resource), applied filters and upload date. | Generated when you create and use a project. |
| Event logs | Contents of the uploaded file (CSV or XES), which may include third parties’ personal data — for example, names or identifiers of who performed each activity. | Uploaded by you. See section 4. |
| Payments | Plan purchased, amount, status and transaction identifiers. We do not receive or store card or bank account details: you enter them directly in Mercado Pago’s environment. | Provided by Mercado Pago after payment. |
| Platform usage | Buttons clicked, page you were on, date and time, session identifier, referring page (where you came from) and, when applicable, the related project and plan. | Recorded automatically while you browse, including when logged out. |
| Technical data | IP address, access date and time, browser and preferred language. | Sent automatically by your browser. [TO REVIEW: confirm which access logs the server/hosting keeps] |
3. How we use the data and on what legal basis
| Purpose | Legal basis (LGPD, art. 7) |
|---|---|
| Create and maintain your account, authenticate your access and let you update your data. | Performance of a contract (item V). |
| Process the uploaded logs and produce the process map, statistics and exports. | Performance of a contract (item V). |
| Manage plans, usage limits and payments. | Performance of a contract (item V). |
| Keep payment records required by tax legislation. | Compliance with a legal obligation (item II). |
| Keep application access records (IP, date and time) for 6 months. | Compliance with a legal obligation — Internet Civil Framework, art. 15 (item II). |
| Understand how the platform is used (clicks and pages) to fix problems and improve the product. | Legitimate interest (item IX). [TO REVIEW: legitimate interest assessment and how to object] |
| Prevent fraud and unauthorized access, and protect the platform’s security. | Legitimate interest (item IX). |
| Defend our rights in judicial, administrative or arbitration proceedings. | Regular exercise of rights (item VI). |
We do not use your data for advertising, we do not sell data and we do not make automated decisions that produce legal effects on you.
4. Personal data in the logs you upload
Event logs usually have columns such as case identifier, activity, timestamp and resource. If the file contains personal data (for example, names of employees or customers), you are the controller of that data and are responsible for having a legal basis to send it to Ánapse.
As a processor, we:
- process that data only to produce the analyses you request on the platform;
- do not use log contents for other purposes or share them with third parties, except infrastructure providers needed for the service (section 5) [TO REVIEW: confirm logs are not used to train or improve algorithms];
- store the file encrypted and show it only to the project owner (section 9);
- delete the data when you delete the project or the account (section 8). [TO REVIEW: today the generated diagram and temporary import files are not deleted together with the project — fix the system before publishing]
We recommend anonymizing or pseudonymizing columns with personal data before uploading whenever they are not needed for the analysis — for example, replacing resource names with codes.
5. Who we share data with
We do not sell or rent personal data. We share data only with:
- Mercado Pago (payments): receives the plan, the amount and an order reference number; you provide your payment details directly to it, under its own privacy policy.
- Hosting provider: [TO DEFINE: provider name and country where servers are located], where the platform and database run.
- Services that deliver page resources: fonts (Google Fonts), icons and libraries (cdnjs/Cloudflare, jQuery and Plotly). When a page loads, your browser connects to these services, which receive technical data such as IP address and browser. They do not receive your account data or your logs. [TO REVIEW: keep these external services or host these files on our own servers]
- Authorities: when required by law or court order.
6. International transfers
Some of the services listed in section 5 may process data outside Brazil. In these cases, the transfer follows art. 33 of the LGPD and the rules of the Brazilian Data Protection Authority (ANPD). [TO REVIEW: mechanism used (e.g., standard contractual clauses) and countries involved, once hosting is defined]
8. How long we keep data
| Data | Period |
|---|---|
| Account data | While the account exists. After a deletion request, within [TO DEFINE: period]. |
| Projects, uploaded logs and generated diagrams | Until you delete the project or the account. |
| Temporary import files | [TO DEFINE: automatic cleanup period] |
| Payment records | [TO REVIEW: applicable tax retention period, e.g., 5 years] |
| Access records (IP, date and time) | 6 months (Internet Civil Framework, art. 15). |
| Usage records (clicks) | [TO DEFINE: period]. If the account is deleted, the records are no longer linked to you. |
You can delete a project at any time from the project list. To delete your account, write to the contact in section 11. [TO REVIEW: offer account deletion directly in My account]
9. How we protect data
- Connections protected by HTTPS.
- Passwords stored only in irreversible hashed form, with strong-password requirements.
- Event logs stored encrypted, with one key per file protected by a master key kept outside the database.
- Each project, diagram and export is accessible only to its owner — these rules are checked by automated tests.
- Internal access restricted to the people who need it to operate the service. [TO REVIEW: internal access and backup policy]
No system is completely immune to incidents. If a security incident occurs that may cause relevant risk or harm, we will notify you and the ANPD, as required by art. 48 of the LGPD.
10. Your rights
Under art. 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 — first name, last name and email can be changed in My account;
- anonymization, blocking or deletion of unnecessary data or data processed in breach of the LGPD;
- portability of the data to another provider;
- deletion of data processed based on consent, where applicable;
- information about who we share your data with;
- review of decisions made solely on the basis of automated processing;
- objection to processing based on legitimate interest.
To exercise these rights, write to the contact in section 11. We will reply within 15 days. If the request is about third-party data contained in a log you uploaded, we will forward it to the controller of that data (you or the responsible company). You may also file a complaint with the Brazilian Data Protection Authority (ANPD).
11. Data Protection Officer (DPO) and contact
Data Protection Officer: [TO DEFINE: name]
Email: [TO DEFINE: privacy email, e.g., privacy@...]
12. Minors
Ánapse is a service for professional use and is not intended for people under 18.
13. Changes to this policy
We may update this Policy to reflect changes in the service or in the law. The date of the last update appears at the top of the page and, if the change is significant, we will notify you by email or on the platform before it takes effect.