Privacy policy

1. Introduction

1.1. This Privacy Policy (“Policy”) explains how Gerencia VIP processes the personal data of those who use the gerencia.vip website, the seller panel, the storefront and the checkout, the buyer area and the Telegram bots, in accordance with the Brazilian General Data Protection Law (Law No. 13,709/2018, “LGPD”).

1.2. Here you will find which data is processed, for which purposes, who it is shared with, how long it is kept and how to exercise your rights.

1.3. To talk about your data, write to privacidade@gerencia.vip.

1.4. This Policy is written in Portuguese, and the English version is a translation offered for convenience. In case of any divergence between them, the Portuguese version prevails.

2. Definitions

2.1. For ease of reading, these are the main terms used in this Policy, as defined by the LGPD:

Personal data: information relating to an identified or identifiable natural person.

Data subject: the natural person to whom the personal data refers.

Processing: any operation carried out with personal data, such as collection, use, storage, sharing and deletion.

Controller: whoever makes the decisions about the processing of personal data.

Processor: whoever processes personal data on behalf of the controller.

3. Who is responsible for your data

3.1. Gerencia VIP is the controller of the data of seller and buyer accounts, of the website and of the cookies.

3.2. In a purchase, the controller of the buyer’s data is the seller they buy from, and in a conversation with a seller’s bot, it is the seller who owns that bot. Gerencia VIP acts as the processor of that data, processing it on the seller’s behalf so that the sale, the delivery, the purchase emails and the conversations work.

3.3. For this reason, requests about the data of a purchase or of a conversation with a seller’s bot must be made to the seller. If you cannot reach the seller, write to privacidade@gerencia.vip.

4. What data we process

4.1. The data processed depends on how you use the Platform.

4.2. Sellers: name, email and password; when signing in with a Google account, also that account’s photo and language. In addition, what the seller registers on the Platform, such as the storefront and the products, the payment accounts and the connected bots and, if they use the Gerencia VIP bot, their Telegram account.

4.3. Buyers: the email and, as the seller requests or the payment method requires, name, phone number, CPF or CNPJ (Brazilian taxpayer numbers) and, for a boleto (Brazilian bank slip), the address. Of the payment, the product, the amounts, the status and, for a card, only the brand, the last four digits and the reason for any decline are processed. The card number is typed into the gateway’s own fields and never reaches us. In the buyer area, the email, the name and the language are processed.

4.4. Those who start a purchase and do not complete it: the email and the other data they filled in, to send a reminder email about the purchase.

4.5. Telegram: the identifier, the name, the username and the language of whoever uses a bot or joins a group or channel through the Platform, as well as the joins and departures of those groups and channels. In private conversations with a seller’s bot, also the messages exchanged, including the answers to the bot’s questions and, in a forwarded message, the name of whoever wrote it. The files of these conversations stay on Telegram and are only fetched when the seller opens them, and contacts, locations and polls sent to the bot are not shown to the seller. Messages exchanged in the groups and channels are not stored.

4.6. Use and security: the browser’s time zone, the type of device used to sign in, the email and IP address of each sign-in attempt and browser signals used to block automated access.

4.7. The email and the data required by the payment method are necessary to buy: without them, the purchase cannot be completed.

5. What we use the data for

5.1. Personal data is used only for specific purposes, described below.

5.2. To create and maintain accounts, process purchases, grant and maintain access and send account and purchase emails, based on the performance of a contract (art. 7, V, of the LGPD).

5.3. To protect the Platform against fraud, automated access and abuse, and to keep the record of sales.

5.4. To send a single reminder email to whoever started a purchase and did not complete it, based on the seller’s legitimate interest (art. 7, IX, of the LGPD). Every reminder email carries a link to unsubscribe.

5.5. To know where each seller came to us from, based on our legitimate interest, and, with your consent, to measure the use of the website and the results of our ads. The details are in the Cookies section.

5.6. So that the seller can talk directly with whoever chats with their bot, following the conversation and answering in the panel, based on the seller’s legitimate interest in assisting whoever talks to them (art. 7, IX, of the LGPD).

6. Who we share it with

6.1. Personal data is shared only to the extent necessary for the purposes of this Policy:

a) with the seller you buy from, who receives the purchase data to deliver the product and assist you, and with the seller who owns the bot you talk to, who follows that conversation to talk directly with you;

b) with the payment gateway chosen by the seller, which receives the data the payment requires and, for a card, also your IP address. The gateway may collect data from your device on the payment page to prevent fraud;

c) with Telegram, through which the bots, the groups and the channels work;

d) with our providers of hosting, database, network, file storage, protection against automated access, email delivery, sign-in with Google and, with your consent, measurement and advertising (Google Analytics and Google Ads);

e) with authorities, when the law or a court order so requires.

6.2. Gerencia VIP does not sell your personal data.

7. International transfer

7.1. The Platform is hosted in the United States, and some of the providers mentioned above process data outside Brazil for it to work. Emails are sent from Brazil.

8. How long we keep the data

8.1. Personal data is kept for as long as each purpose requires, as set out below.

8.2. Account data is kept while the account exists. The registration of a seller who does not confirm their email is deleted after 3 days.

8.3. The data of a sale is kept while the order exists, even after the buyer’s or the seller’s account is deleted.

8.4. The data of an incomplete purchase is deleted after 30 days, except for the contact kept for the reminder email: when you unsubscribe, you stop receiving these emails, and the contact is deleted if you delete your account.

8.5. The messages of a private conversation with a seller’s bot are available to the seller for 24 hours and are then deleted. The technical copy of the messages the bots receive, used to process them, is deleted within 3 days, and joins and departures of groups and channels are kept for 2 years.

8.6. When a seller account is deleted, the record of the registration is kept only for counting, detached from the account and without name, email or any other contact.

8.7. Technical and security records have their own periods, from 30 days to 5 years, depending on the type. Data sent to Google follows the periods configured in our Google Analytics and Google Ads accounts.

9. Cookies

9.1. Cookies are small files stored in your browser. Gerencia VIP uses the cookies described below.

9.2. Necessary: they keep you signed in to the panels, link a payment to the browser it was made in and store your choice about cookies. As they are essential for the Platform to work, they do not depend on a choice.

9.3. Sign-up origin: a cookie of ours keeps, for 90 days, the link’s campaign data, the partner code, the ad network of the click (only its name, never the click identifier), the site you came from and the page you landed on. When you create a seller account, this origin is kept with the registration and does not leave Gerencia VIP. It is on by default, based on legitimate interest, and you can turn it off.

9.4. Analytics and marketing: analytics cookies (Google Analytics) and marketing cookies (Google Ads) are used only if you accept them, in the notice shown on the website, in the panel and in the seller sign-in. With consent, Google Ads cookies last 90 days and Google Analytics cookies up to 2 years.

9.5. Without consent, Google’s tools store no cookies, but they still send Google cookieless usage signals to estimate visits and conversions.

9.6. With marketing consent, when you create a seller account, your email is sent to Google converted into a code (hash), to recognize whether you came through one of its ads.

9.7. Your choice applies to every gerencia.vip address, is kept for 12 months and can be changed at any time under “Cookies”, in the website footer, or under Settings → My account, in the panel. When you decline, we delete the cookies your choice no longer allows.

10. Security

10.1. Gerencia VIP adopts technical measures to protect personal data.

10.2. Every connection to the Platform is encrypted. The database and the backups are encrypted at rest, and the credentials of the payment accounts, the bot tokens and the sessions get an extra layer of our own encryption. The Gerencia VIP team accesses the Platform with two-step verification.

11. Your rights

11.1. Under art. 18 of the LGPD, you may request at any time:

a) confirmation that we process your data;

b) access to your data;

c) correction of incomplete, inaccurate or outdated data;

d) anonymization, blocking or deletion of data that is unnecessary, excessive or processed in breach of the law;

e) portability of your data;

f) deletion of the data processed with your consent;

g) information about who we share your data with;

h) information about the possibility of not consenting and about what happens if you do not consent;

i) revocation of your consent.

11.2. You may also object to processing based on legitimate interest.

11.3. To exercise your rights, write to privacidade@gerencia.vip. You can also delete your account through the panel or the buyer area, leave the reminder emails through the link in each of them and change your cookie choice under “Cookies”.

11.4. Deleting the account does not erase the sales records.

11.5. You may also file a complaint with the Brazilian National Data Protection Authority (ANPD) and with consumer protection bodies.

12. Minors

12.1. The Platform is strictly prohibited to persons under 18.

13. Changes to this Policy

13.1. Gerencia VIP may change this Policy at any time. The version in force is always the one published on this page, identified by the date at the top.

14. Contact

14.1. If you have any questions about this Policy or about your data, write to privacidade@gerencia.vip.