Purpose
This Privacy Policy sets out CoelhoVoip’s commitment to privacy and personal data protection under Brazil’s General Data Protection Law (Law No. 13,709 of August 14, 2018, or LGPD) and other applicable legislation, in connection with the contracting and use of our services, products, internal systems, websites, applications and other resources offered to clients. This policy explains how personal data is processed. Browsing or using services does not constitute blanket consent for all processing operations; where consent is the applicable legal basis, it will be requested for specific purposes.
Scope
This policy applies to all CoelhoVoip products and services and any associated services.
General provisions
To maintain the quality of its information and policies, CoelhoVoip may amend this Privacy Policy whenever necessary. Data subjects will be notified of updates through our communication channels. We recommend reading it periodically and checking the document version and effective date.
Definitions for this policy
To make this document easier to understand, the following terms have these meanings:
“LGPD” means Brazil’s General Data Protection Law (Law No. 13,709/2018);
“Controller” means the natural or legal person responsible for decisions concerning the processing of personal data;
“Processor” means the natural or legal person that processes personal data on behalf of the controller;
“Data subject” means the natural person whose personal data is processed;
“Personal data” means information relating to an identified or identifiable natural person, including the personal data of clients, suppliers and partners;
“Sensitive personal data” means personal data concerning racial or ethnic origin, religious beliefs, political opinions, membership of a trade union or religious, philosophical or political organization, health or sex life, or genetic or biometric data linked to a natural person.
“Cookies” are small text files stored on a visitor’s computer that can be retrieved by the website that sent them during browsing. Websites mainly use cookies to identify and store information about visitors.
Data subject rights
The LGPD grants data subjects rights concerning their personal data. Subject to applicable legislation and its limitations, individuals have the following rights:
The right to confirmation that processing takes place;
The right to access their data;
The right to correct incomplete, inaccurate or outdated data;
The right to anonymization, blocking or deletion of unnecessary or excessive data, or data processed in breach of the LGPD;
The right to transfer data to another service or product provider, while protecting the company’s commercial and industrial secrets;
The right to deletion of personal data processed with consent, except where retention is permitted or required under the LGPD;
The right to information about public and private entities with which the company has shared data;
The right to information about the possibility of withholding consent and the consequences of doing so;
The right to withdraw consent, subject to the LGPD and its applicable procedures and conditions.
The right to object to processing carried out unlawfully.
These rights are guaranteed and may be exercised under the terms of the LGPD. Requests, complaints, information enquiries or the exercise of data subject rights may be submitted in writing to dpo@coelhovoip.com.
To begin a request, provide your name, a reply contact and a description of your request. To protect the data subject’s information, identity verification may be needed, proportionate to the request and the risk of improper disclosure. Additional documents will be requested only when necessary, with instructions on how to submit them.
How personal data is collected
Data collected directly from prospective clients — We may collect their personal data in the following ways:
when a prospective client contacts us by telephone, email or WhatsApp;
when scheduling and conducting meetings or technical visits;
during the initial requirements assessment for commercial proposals and quotations;
during technical visits when information about the company, site or project managers is needed.
Data collected directly from clients — We may collect their personal data in the following ways:
when a client opens and follows tickets in the technical support system;
during sales and commercial interactions when a client shares contact information;
when purchasing products or services and providing the contact and billing information needed for the transaction;
when issuing invoices and payment slips, collecting Brazilian tax identification numbers (CPF), telephone numbers and other data for accounting and tax records.
Data collected when delivering services — We collect personal data in the course of providing services as follows:
during requirements and project kick-off meetings, including image and voice recordings of participants;
when accessing a client’s technical environment through a VPN for deployment, configuration and support, potentially collecting usernames, IP addresses, logs, access credentials and metadata.
Data collected directly from suppliers and partners — We may collect their personal data in the following ways:
during negotiations and contract discussions, when data about the supplier’s representative is collected;
when receiving and checking service invoices and processing related payment receipts;
when a ride-hailing driver is needed for client visits.
Data collected automatically by systems — We automatically collect:
authentication records, audit logs and metadata generated when accessing corporate and client systems and environments.
Data collected
The following data is collected for each category of data subjects using our services.
| Data subject | Personal data | Data requiring additional protection |
|---|---|---|
| Client | Full name; Email; Telephone; WhatsApp; Job title; Brazilian tax ID (CPF); Brazilian identity document number (RG); Address; Department; Organizational level; Company name; Registered company name; VAT Number; Employee ID; Usernames; Approval record | Signature; Photograph; Access credentials; Bank details |
| Supplier | Full name; Email; Job title; Brazilian tax ID (CPF) | Signature |
| Ride-hailing driver | Full name | |
| Participants | Full name; Email; Job title; Telephone; Usernames; Access profiles; IP addresses; Access logs | Image and voice recordings |
| Client employees | Full name; Email; Telephone; Job title; Department; Employee ID; Usernames; Authentication records; Audit logs; Metadata; user registration and identification data; personal data in corporate databases | Access credentials; Bank details |
| Client suppliers and partners | Full name; Email; Telephone; Address; Brazilian tax ID (CPF); Brazilian identity document number (RG); user registration and identification data; Audit logs; Metadata; personal data in corporate databases | Bank details; Signature |
| Clients of the contracting company | Full name; Email; Telephone; Address; Brazilian tax ID (CPF); Brazilian identity document number (RG); user registration and identification data; Metadata; personal data in corporate databases | Signature |
| Client’s legal representative | Full name; Email; Telephone; Brazilian tax ID (CPF) | — |
| Client environment technical data | Email; Telephone; Job title; Usernames; IP addresses; Authentication records; Audit logs; Metadata; user registration and identification data; personal data in corporate databases | Access credentials |
The website’s current contact page provides telephone, email and WhatsApp links, with no submission form or document upload. Information sent by visitors is processed through the channels used for their enquiry, subject to the applicable purposes and retention periods.
The public website does not use Google Analytics, Google Tag Manager, Meta Pixel or other analytics tracking tools, as confirmed by the company on October 13, 2026. Hosting and security logs must be considered separately from browser cookies and technologies.
The table reflects the inventory in the company’s documentation. Inclusion in the additional-protection column does not, by itself, change the legal definition of sensitive personal data.
Purposes of data processing
Personal data is used for the following purposes and on the legal bases that authorize its processing:
| Purpose | Data | Legal basis |
|---|---|---|
| Specialist pre-sales technical consulting to support clients in validating projects and solutions | Client: Email, Telephone, WhatsApp; CoelhoVoip representative: Full name, Email, Image and voice recordings, Telephone, Job title, Access credentials; Participants: Full name, Email, Job title, Image and voice recordings; Client environment technical data: Email, Telephone, Job title, Usernames, IP addresses, Authentication records, Access credentials, user registration and identification data, Audit logs, Metadata, personal data in corporate databases; | B5, B9 |
| Management of corporate travel and client-visit expenses | CoelhoVoip representative: Full name, Brazilian tax ID (CPF), Address, Transaction date and time, Signature, Partial card number, Vehicle registration plate, Dates of stay, Brazilian identity document number (RG), Destination locations, Bank details, Email, Telephone, Date of birth, Passport; Supplier: Full name, Brazilian tax ID (CPF); Client: Full name, Brazilian tax ID (CPF), Signature, Address, VAT Number, Registered company name; Driver: Full name; | B5 |
| Recording of purchase invoices | Supplier: Full name, Email, Brazilian tax ID (CPF); Driver: Signature; | B2 |
| Consulting on solution deployment and configuration | Participants: Full name, Email, Job title, Telephone, Access profiles, Usernames, IP addresses, Access logs; Client employees: Email, Telephone, Job title, Authentication records, Employee ID, Access credentials, Department, user registration and identification data, Audit logs, Metadata, personal data in corporate databases; Client suppliers and partners: Full name, Email, Telephone, Address, user registration and identification data, Audit logs, Metadata, personal data in corporate databases; Clients of the contracting company: Full name, Email, Telephone, Address, user registration and identification data, Metadata, personal data in corporate databases; Client: Full name, Job title, Department, Organizational level, Photograph, Email, Signature, Approval record; CoelhoVoip representative: Email, Usernames, IP addresses, Access logs, Login identifier, Access profiles, Authentication records, Access credentials, Approvers’ names, Signature, Evidence of actions performed (system images and data); | B5 |
| Specialist technical support for tickets escalated to level 3. | Client employees: Full name, Email, Job title, Bank details, Usernames, Authentication records, Employee ID, Access credentials, user registration and identification data, Audit logs, Metadata, personal data in corporate databases; Client suppliers and partners: Full name, Email, Address, Bank details, user registration and identification data, Metadata, personal data in corporate databases, Brazilian tax ID (CPF), Signature, Brazilian identity document number (RG); Clients of the contracting company: Full name, Email, Telephone, Address, user registration and identification data, personal data in corporate databases, Brazilian tax ID (CPF), Signature, Brazilian identity document number (RG); Client: Full name, Email, Telephone, Job title, Employee ID, Access credentials, Usernames, Brazilian tax ID (CPF), Signature, Brazilian identity document number (RG); CoelhoVoip representative: Full name, Access logs, Evidence of actions performed (system images and data), Brazilian tax ID (CPF), Signature; | B5 |
| Preparation of proposals for projects and services to be delivered to clients. | Client: Full name, Email, Telephone, Job title, Brazilian tax ID (CPF), Address; CoelhoVoip representative: Full name, Brazilian tax ID (CPF), Signature; | B5, B9 |
| Billing for services and equipment sold by CoelhoVoip | Client: Full name, Email, Telephone, Brazilian tax ID (CPF), Address, Company name; Legal representative of a corporate client: Full name, Email, Telephone, Brazilian tax ID (CPF); CoelhoVoip representative: Full name, Email, Telephone, Job title; | B2 |
| Purchase of materials and equipment for project delivery | CoelhoVoip representative: Full name, Job title, Brazilian tax ID (CPF), Signature; Supplier: Full name, Job title, Brazilian tax ID (CPF), Signature; | B5 |
| Generation of payment slips | Client: Full name, Email, Telephone, Brazilian tax ID (CPF), Address, Bank details; | B5 |
Legal basis key: B2 — compliance with a legal or regulatory obligation (Article 7, II); B5 — performance of a contract or preliminary procedures at the data subject’s request (Article 7, V); B9 — legitimate interests, subject to the legal conditions (Article 7, IX).
Cookies
Cookies are small files stored by browsers. Similar technologies include local and session storage. The inspection of public pages without logging in on October 13, 2026 found no analytics or advertising cookies, or cookies installed by the website during those visits.
The notice appears on your first visit. When you click “Got it”, this browser saves only the acknowledgment date in local storage, using the key cv-privacy-notice-v1, for up to 180 days. This record does not identify the visitor or authorize advertising or analytics. You can reopen the notice from the footer or delete this storage in your browser settings. If storage is unavailable, the notice may reappear.
Session storage named wpEmojiSettingsSupports was identified. WordPress uses it to check browser support for emojis. The login screen and dashboard may use technical authentication and test cookies, which differ from public browsing.
Languages are selected through separate pages, with no preference cookie. WhatsApp, Gmail, Outlook and Google Maps are accessed only through links chosen by the visitor and have their own privacy policies.
No optional cookie categories are active in the current configuration that require consent. If optional features are introduced, the information must be reviewed and, where consent is required, the features must remain blocked until the visitor chooses, with mechanisms for rejection and preference changes.
Read about cookies and similar technologies.
Data sharing
CoelhoVoip may work with other companies to provide features related to our services, which may involve sharing personal data. Personal data will be shared only on the basis described in the following table:
| Purpose of sharing | Reason |
|---|---|
| Technology and cloud storage service providers | We use technology service providers that operate the technical infrastructure needed to provide and maintain our management systems, including cloud storage and corporate platforms used in projects. Data is shared with these processors only as necessary for secure system operation. |
| Communication services with clients, Suppliers and participants | We share personal data through corporate communication channels to send and receive proposals, documents, invoices and other information needed to perform contracts and deliver services, after confirming the recipient. |
| Accounting management services, Tax management and invoice issuance | We share personal data with accounting, tax management and invoice-issuance platforms to meet the company’s accounting and tax obligations, including billing, invoice recording and expense control. |
| Information sent to banks and payment institutions | We share personal data with financial institutions and payment providers to issue payment slips and receive or transfer funds, including payments for international services. |
| Suppliers of materials and equipment | We share necessary data with suppliers to formalize and carry out purchases of materials and equipment related to project contracts. |
| Compliance with law, court orders and/or Brazil’s National Data Protection Agency (ANPD) | We share personal data when we believe in good faith that it is necessary to comply with a legal or regulatory obligation, respond to valid legal process such as a search warrant, court order or subpoena, or fulfil requests from Brazil’s National Data Protection Agency. |
Data transfers
Personal data is collected in accordance with Brazilian law. If services are contracted or data and information are hosted internationally, CoelhoVoip ensures that personal data is transferred only when the protection criteria in this policy are observed. Accordingly, data may be transferred only to parties in countries or international organizations with a legally adequate level of data protection or subject to contractual safeguards required by the LGPD.
Retention period
CoelhoVoip retains clients’ personal data for as long as necessary to fulfil the purpose for which it was collected, including compliance with legal, regulatory, tax or contractual obligations. Data no longer needed for a particular purpose will be deleted or anonymized.
Personal data cannot be deleted or anonymized where its retention is required by law or a regulatory authority.
Personal data security
CoelhoVoip adopts appropriate security measures to prevent accidental loss, unauthorized use or access, alteration or disclosure of personal data. Employees, agents, contractors and other third parties access client data only as necessary to perform specific activities, following CoelhoVoip’s instructions and under confidentiality duties and signed confidentiality agreements.
CoelhoVoip maintains procedures to assess and respond to security incidents involving personal data. Incidents that may cause significant risk or harm to data subjects must be reported to the ANPD and affected individuals in the circumstances and within the time limits established by applicable law and regulations.
DPO contact
CoelhoVoip’s designated Data Protection Officer is Julia Nauter. For requests, enquiries and the exercise of your rights, contact dpo@coelhovoip.com.