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Privacy Policy

Last updated: September 9, 2026

1. Who we are

Braluma is a technology platform developed and operated by Optivoo Digital Brasil Ltda. (CNPJ 40.807.362/0001-03) (“we”, “us”). We have no Canadian establishment at this time. This English notice applies to visitors and leads in Canada, excluding Quebec, and is governed by Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada’s Anti-Spam Legislation (CASL) for commercial electronic messages. If you reside in Quebec, this English notice is not intended for you: Québec's Law 25 imposes distinct French-language and governance requirements that are not addressed here. Please contact our Privacy Officer before providing personal information from Québec.

2. Information we collect

We collect only what is needed to respond to inquiries and operate the service:

  • Identification and contact: name, email, phone, company, city/province
  • Interaction data: booking history, service preferences, messages you send us
  • Technical data: masked IP address, browser type, pages visited (see our cookie policy)
  • Meta/WhatsApp integration data: Meta/Facebook account identifiers, WhatsApp Business Account (WABA) and phone number identifiers, authorized scopes, and connection status, plus messages and attachments where a tenant connects an official number via Meta

3. Purposes and consent

We use your information to:

  • Respond to inquiries and provide requested services
  • Operate scheduling, communications, and billing where applicable
  • Improve our services and secure the platform
  • Send commercial electronic messages only with your express opt-in consent (CASL). Each message identifies the sender, includes a mailing address, and offers a working unsubscribe that we honour within 10 business days

We rely on meaningful consent: marketing and analytics cookies and commercial messages are off by default and require your affirmative action. You may withdraw consent at any time (see section 7).

3A. WhatsApp and Meta platform data

Where a tenant connects an official number, we operate tenant-connected WhatsApp messaging through Facebook Login for Business, WhatsApp Embedded Signup, and the WhatsApp Cloud API (including status webhooks). We process only what is needed to connect the number and deliver the messages the tenant authorizes:

  • Identifiers collected: Meta/Facebook account IDs, WhatsApp Business Account ID, Phone Number ID, authorized scopes, and connection status, plus messages and attachments sent through the connected number
  • Opt-in: marketing WhatsApp messages are off by default and sent only with your express consent (opt-in, CASL). Each message identifies the sender and offers a working opt-out
  • Opt-out: reply STOP, sair, or unsubscribe at any time to opt-out of automated WhatsApp messages; we honour opt-out requests promptly
  • Meta measurement (per tenant): where a tenant enables it, browser Meta Pixel (fbq) and server Conversions API events with event_id deduplication, gated on consent v2

We keep this data only as long as needed to operate the connection and meet legal duties, and delete or anonymize it afterwards. To request deletion, see our data deletion instructions or contact our Privacy Officer (DPO): dpo@braluma.com.

3B. Meta permissions and data use

When a tenant connects a Meta asset, we use only the data required for the selected permission and authorized workflow. The permissions have separate purposes:

  • whatsapp_business_messaging (WhatsApp Business Messaging): WABA and phone identifiers, messages, attachments, and delivery status for the tenant's support inbox.
  • whatsapp_business_management (WhatsApp Business Management): WABA, phone, template, and registration state needed to connect and manage the authorized business asset; it is not used to open another tenant's conversations.
  • leads_retrieval, pages_show_list, and pages_manage_metadata, pages_read_engagement, and ads_management (Lead Ads dependencies): form-submitted lead fields, Page/form/ad identifiers, and access/subscription state needed to create a lead in the tenant CRM. Although ads_management is a dependency in Meta's documented Leadgen flow, Braluma does not use these permissions to create or modify ads.
  • pages_show_list, pages_manage_metadata, and pages_messaging (Messenger): messages, delivery/read events, and identifiers for the authorized Page so tenant operators can provide support and reply.
  • instagram_business_basic and instagram_business_manage_messages (Instagram Messaging): professional-account identifiers, profile data, and messaging events for support. Instagram uses a separate Business Login and is not granted automatically by a Facebook Page connection.
  • ads_read and business_management (Ads Read): ad accounts, campaigns, and aggregate performance metrics such as impressions, clicks, conversions, and spend for authorized reporting. These permissions are read-only in the Ads Read flow.
  • ads_read, business_management, and ads_management (Ads Management): data required for tenant-approved campaign actions subject to budget, audit, and rollback controls; campaigns start paused and are not changed without the applicable authorization.
  • whatsapp_business_management and whatsapp_business_manage_events (Conversions API): conversion events linked to WhatsApp CTWA interactions, with identifiers and value where applicable, only with consent and within the provider's operational event window. Raw conversation content is not sent.

Integration credentials are encrypted server-side, are not exposed in the browser, and remain bound to the tenant that authorized the asset. You may withdraw consent and request access, correction, or deletion through our Privacy Officer (DPO).

4. Sharing and cross-border transfers

Your information may be shared with:

  • Braluma licensees delivering the services you request
  • Payment processing (Stripe) for financial transactions
  • Infrastructure hosting (Vercel, Neon)
  • Email delivery (Resend) and monitoring with minimized logs (Sentry/Better Stack)
  • AI providers (Google Gemini, Groq, or OpenAI) only where the feature is enabled
  • Meta/WhatsApp, where a tenant connects an official number via the WhatsApp Cloud API
  • Government authorities where required by law

Providers may process information in Brazil, the United States, the European Union, or other global regions, depending on the service. Our current provider inventory lists Vercel, Neon, and Stripe as US/global; Resend as US; Meta/Evolution as Brazil/global; Sentry/Better Stack as US/EU; and Google Gemini, Groq, or OpenAI as US/global. Where a provider processes information outside Canada, we assess the transfer and seek appropriate data-processing agreements, transfer mechanisms, and contractual safeguards; the applicable protection depends on the provider and service. Information stored outside Canada may be subject to lawful access under local laws, including in the United States. We do not sell or rent your personal information to third parties for their marketing.

Google Ads / Business Profile / Calendar data use

We request the following Google scopes only when the connected feature needs them: adwords to read and manage the connected Google Ads account, campaigns, and performance data; datamanager to send and inspect conversion events through Google Data Manager; business.manage to read and manage the connected Google Business Profile businesses and locations; and calendar.events.owned to create, update, or delete calendar events owned by the connected Google account for scheduling. External sharing of data obtained through these scopes is limited to the Google APIs at googleapis.com needed to operate the requested feature. OAuth tokens are retained until you use Disconnect; conversion events follow the retention terms of the applicable service contract and legal obligations. Limited Use: Braluma uses Google user data only to provide or improve the user-facing features you request, does not use it for advertising or sell it, and does not transfer it except as permitted by the Google API Services User Data Policy. For questions, contact our DPO at dpo@braluma.com.

5. Retention

  • Lead and inquiry records: as long as reasonably needed to respond, maintain the relationship, protect the service, and meet legal obligations. Timing varies by record, and public lead records are currently outside the automated retention cleanup. Deletion requests are handled through our privacy request process
  • Security logs: up to 1 year for fraud prevention and platform security
  • Account and billing records: as required by tax and legal obligations

We review data for deletion or anonymization when it is no longer needed. Timing varies by category and legal duties, and backups may persist until their normal expiration. You may request earlier deletion at any time, subject to legal retention duties — see our data deletion instructions.

6. Safeguards

We use proportionate technical and organizational measures, including encryption in transit (HTTPS/TLS), infrastructure protection at rest, role-based access control, server-side secrets, and minimized logging.

7. Your rights

Under PIPEDA you may:

  • Request access to the personal information we hold about you
  • Request correction of inaccurate or incomplete information
  • Withdraw consent, subject to legal or contractual limits
  • Challenge our compliance with PIPEDA principles

We respond within 30 days. Contact our Privacy Officer (DPO): dpo@braluma.com. If unsatisfied, you may complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca).

8. Breach notification

Where a breach creates a real risk of significant harm, we notify affected individuals and the Privacy Commissioner as required by PIPEDA and keep an incident register.

9. Changes and contact

Material changes will be announced on this page or by email. Questions for our Privacy Officer (DPO): dpo@braluma.com.