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Privacy Policy

v2.4 · October 27, 2026 · subject to formal legal review

This policy describes how Viccari Ads LTDA, a company registered in Brazil (CNPJ 47.356.569/0001-58) (“we”, “us”), which operates Hades — Commercial Intelligence OS, also distributed as Call Copilot, and Hades Training (“the product”) — handles personal data. It covers the people who use the product, the people those conversations are with, the people who visit and talk to our websites, and the companies we ourselves approach to offer the product. Because we are a Brazilian company, this handling is governed by Brazil's General Data Protection Law (Law 13,709/2018, known as the “LGPD”), wherever you live. Viccari Ads is the controller of this data, with three exceptions, where the customer company is the controller and we act as its processor: the WhatsApp conversations it connects to the product, the leads it captures through ad tracking, and its employees' sessions in Hades Training (section 2).

1. What data we handle, and whose

The user's (the person who signs in to the app, the dashboard or the mobile app): name, email, company, password (kept only as a cryptographic hash by the sign-in service), profile photo if they upload one, the version of these documents they accepted, account usage records, the device they signed in from, and the content they enter themselves (Business DNA, call scripts, proposals, notes). Whoever pays for the subscription also provides billing data (section 2, “Subscription payment”).

The prospect's (the person on the other side of the meeting, who never created an account or agreed to anything here): what they say is transcribed and analyzed during the call, because that is how the product works — suggest in real time and summarize afterwards. The salesperson may also record their name, phone and email, and ask for public research on their company before the meeting. Under the LGPD this person is a data subject even without any direct relationship with us.

The audio used for the live transcript is not recorded or kept. The sound that goes to transcription is converted into text while the conversation happens and discarded right after, including at our transcription provider: no audio file is left from it. The only exception is the meeting recording, described in the next paragraph, which only exists when someone turns it on. What is kept is the text of the conversation and its analysis: in our database and, while the app is installed, also in an app data folder on the computer of whoever ran the call, which only they can access and delete. That text is what the retention periods in section 6 and your rights in section 9 apply to.

The meeting recording, only when it is turned on. A salesperson can turn on recording for a meeting, and the team manager can make it mandatory for a salesperson. When it is on, it records on video the meeting window or the whole screen (the salesperson chooses), with the sound of their microphone and the sound of the meeting, which includes the prospect's voice and image when they appear there. The video stays on the salesperson's computer or, when they or the manager choose to upload it, is stored by us (section 2, “Meeting recording”). In an English-language account, recording starts only after the product confirms, in the transcript, the prospect's yes to being recorded; we keep the question and the answer, with the time, as proof. If the prospect says no, nothing is recorded, and we keep the question and the answer to show why the meeting has no video.

People who talk on WhatsApp with a customer company (when it connects a WhatsApp number to the product): name, phone number and profile photo as they appear on WhatsApp, the text of the messages, the files someone at the company opens or sends from the dashboard and, if lead capture is on, the identification of the ad the conversation came from.

People who become leads of a customer company through ad tracking: name, phone, email, the source campaign and ad, and the click identifiers that the company's form or WhatsApp send to the product.

Employees in training (in Hades Training, when their employer adds them): name, email, what they type or say in training sessions, the grade and feedback for each session, and marks about how the session was taken (section 2, “Hades Training”).

People who visit our websites (hades-copilot.com and hades-copilot.com.br, the blog, the help center, the sign-in and sign-up screens and the dashboard): the pages opened and the clicks, where they came from and whether they booked a meeting, tied to a random identifier kept in the browser. And, from people who chat with the website or book a meeting, what they type themselves: name, WhatsApp number, email, company website and answers.

Companies we approach to offer the product (B2B prospecting, section 2): public business contact data and, sometimes, the name and title of a decision maker and a work email. These people are not users of the product.

The Google Calendar of users who connect it (only when a user connects their own Google account in the product’s Calendar): the email of that Google account and the events on its primary calendar, meaning title, time, description, call link, number of guests and organizer. We use this data for two things: to show the meetings in the product’s Calendar (and, when the user asks for it there, to create, move, edit or delete an event), and to notify the user, in the dashboard bell and on the phone, when a new meeting appears on their calendar and when a meeting is about to start (the user turns these two notices off under Notifications). We do not read the account’s other calendars. For those notices, and only for them, we keep a minimal copy of the events in the next 60 days that have a set time: the identifier, the start, the end, the title and the status (confirmed, tentative or declined). We do not keep the description, the call link, the guests or the organizer, and we do not copy all-day events. The copy is refreshed every 10 minutes; an event leaves it when it is deleted or moved in Google and one day after it ends, and all of it is deleted the moment the user disconnects the account. Events the product itself creates carry an internal marker, only so we do not notify the user about something they just scheduled. Apart from that copy, what we keep is the access authorization, the account email and the time of the last read. The events are not used for advertising, are not sold or passed on to third parties, are not sent to the product’s artificial intelligence models and are not used to train any model. To turn it off, click “Disconnect this account” in the Calendar (the authorization is deleted immediately) or remove access at myaccount.google.com/permissions. Hades’s use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

2. Each processing activity: what, why, legal basis, how long, who receives it

The legal bases are those of article 7 of the LGPD. “Who receives it” refers to the providers that process the data on our behalf (the full list, with each one's country, is in section 13).

Account, sign-in and product usage

What: name, email, company, password (hash only), optional profile photo, version and date of acceptance of these documents, usage records (when they signed in, how many calls, how much transcription and AI they used), and the connected device: a random identifier created at install, the computer name, the IP address of the connection and when it was last seen. On a phone, the session is kept on the device itself.

What for: giving access to the account, counting plan usage and keeping one active session per account at a time (accounts cannot be shared, section 2 of the Terms).

Legal basis: performance of the contract (art. 7, V) and, for the one-session-per-account control, legitimate interest in preventing account sharing (art. 7, IX).

How long: while the account is active (section 6).

Who receives it: Supabase (database and sign-in), Vercel (dashboard) and Railway (app server).

Meetings: transcription, live suggestions and analysis

What: what the salesperson and the prospect say, turned into text; the text goes, together with the company's Business DNA, the Commercial Memory lessons, the analysis of earlier meetings with the same client and the meeting script, to the AI model that suggests and analyzes. What is kept: the transcript, the analysis, the checklist, the stage and the key moments of the meeting. The transcription audio is not kept (section 1); the meeting recording, when turned on, is the next processing activity.

What for: transcribing, suggesting during the call, analyzing afterwards and showing each client's history.

Legal basis: performance of the contract with the user (art. 7, V). For what the prospect says, since they are not a party to the contract, the legitimate interest of the user and of Viccari Ads in supporting the business conversation both sides chose to have (art. 7, IX, and art. 10), with the notice in section 10.

How long: while the account is active. The local copy on the salesperson's computer stays until they delete the app data folder.

Who receives it: Deepgram (transcription), Anthropic (the Claude model: live suggestions and analysis) and, when the analysis after the meeting uses the GPT model, OpenAI, through OpenRouter, which only forwards the request and is set to use only providers that neither keep the content nor use it to train models. None of them uses the content of meetings to train models.

Meeting recording (only when turned on)

What: the video of the meeting, with sound (the meeting window or the whole screen, as the salesperson chooses), when the recording started, its length and file size; in an English-language account, the salesperson's question and the prospect's answer, with the time; and, when the recording does not happen, the reason (the prospect refused, did not answer, the computer ran out of space).

What for: letting the salesperson, the owner and the managers of the account review the meeting, for quality control and coaching, with the moments the copilot flagged during the call.

Legal basis: performance of the contract with the user (art. 7, V). For the prospect's voice and image, the user's legitimate interest in reviewing their own business conversation (art. 7, IX, and art. 10), with the notice in section 10 and, in an English-language account, the yes confirmed before recording.

How long: on the salesperson's computer, until they delete the file. Stored by us, up to the plan's recording hours: past that limit, the oldest recordings are deleted 7 days later, with a notice to the account owner; only the record that the recording existed and was deleted remains. The meeting's transcript and analysis remain.

Who receives it: Supabase (video storage in São Paulo). The video is not sent to the AI models and is not part of the cross-account analysis.

Business DNA, Commercial Memory, client record, follow-ups and proposals

What: what the company enters about itself (offer, prices, known objections); the lessons the product computes from the account's own meetings; each client's record (name, phone, email, source and what was said in earlier meetings); and the follow-up messages and proposals the AI writes from the transcript and the analysis.

What for: preparing and running the next conversations with the same client and writing what the salesperson sends after the meeting.

Legal basis: performance of the contract (art. 7, V).

How long: while the account is active.

Who receives it: Anthropic (writes follow-ups and proposals) and the hosting providers.

Research before the meeting

What: when the salesperson asks for it, our server opens the website of the prospect's company (title, description, colors and social media links) and looks up the public data of the company's Brazilian tax registration (CNPJ), which includes the name and role of up to 10 partners. The Instagram profile is not read: only the link is kept.

What for: building the meeting script.

Legal basis: the user's legitimate interest in preparing for a meeting already scheduled (art. 7, IX), on data the company itself made public (art. 7, paragraph 4).

How long: together with the script, while the account is active.

Who receives it: BrasilAPI (tax registration lookup). The website looked up receives a visit from our server, like any other visit.

A customer company's WhatsApp conversations

What: the messages of the number the company connects (the business number or a salesperson's personal number): the contact's name, phone number and profile photo, text, reactions, scheduled messages and the files opened or sent from the dashboard.

What for: receiving and organizing conversations, replying and scheduling messages from the dashboard and linking each conversation to the client and the meeting. WhatsApp conversations are not sent to AI models and are not part of the cross-account analysis.

Legal basis: here the customer company decides and is the controller; we handle this data only to provide the service to it, following its instructions (art. 39).

How long: while the account is active. Disconnecting the number does not delete the history. Conversations of a number the company replaced with another are deleted after 90 days without messages, with an on-screen warning 7 days before. Files are kept in a storage space limited per account, which the company can clear from the dashboard. To delete conversations earlier, the company asks through the contact in section 12.

Who receives it: Uazapi (technical connection with WhatsApp, which also keeps a copy of that number's messages and files) and WhatsApp itself, a Meta service that the company and its contacts use directly, under WhatsApp's terms.

A customer company's ad tracking

What: the leads that arrive through the company's form or WhatsApp (name, phone, email, campaign, ad, click identifiers), kept together with the original message received; the data of the ad account it connects at Meta (name of who connected it, business manager name, campaigns, budgets and results); and, when the owner asks for or approves it, the daily budget change we write back to Meta, with who asked and when. The public report the company can create shows campaign numbers only, never a lead's name, phone or email.

What for: measuring which ads bring sales, suggesting and applying budget adjustments, and sending the company's conversion events back to Meta.

Legal basis: the customer company is the controller of its leads; we act as its processor (art. 39). Reading and writing on the ad account follow the authorization the owner gives at Meta and the clause the owner accepts in the product.

How long: while the account is active.

Who receives it: Meta (Facebook and Instagram): receives, for the company's own ad account, the events new lead, meeting attended and sale. Phone and email only leave our systems converted into an irreversible code (SHA-256), together with the ad's click identifiers.

Google Calendar

What: as described in section 1.

What for: showing, creating, moving, editing and deleting meetings in the product's Calendar, always at the user's request; and notifying, in the bell and on the phone, of a new meeting and of a meeting about to start.

Legal basis: performance of the contract (art. 7, V), with the authorization the user gives Google.

How long: the authorization is kept until the user disconnects; the minimal copy of the events is kept until one day after each one ends and is deleted when the user disconnects.

Who receives it: Google (the user's own calendar service).

Hades Training

What: from the manager and the employee: name and email (the invitation goes by email); from each session: everything the employee types or says (as text), the grade (passed, failed or inconclusive) and the feedback on each criterion, with the excerpt that supports it; and marks about how the session was taken — whether text was pasted (only the length of what was pasted, not the content), whether the employee switched tabs, whether they answered too fast for the length of the answer, and up to 200 characters of a message that tried to manipulate the role-play bot. In voice sessions, the employee's microphone is transcribed and the audio is not kept. The employee's camera is never turned on.

What for: training and certifying the employee in customer service, at their employer's request.

Legal basis: the customer company is the controller of its employees' data; we act as its processor (art. 39). The company decides who trains and what is done with the grade.

How long: while the company's account and the department exist.

Who receives it: Deepgram (transcribes the employee's voice), Anthropic (plays the customer and grades the session; it receives the conversation, not the employee's name or email), ElevenLabs (turns only the bot's text into voice) and, when the company buys the live face, HeyGen (receives only the bot's audio to animate the face; never the employee's microphone).

Notices: notifications, emails and the welcome message

What: the phone's notification identifier and the dashboard notifications, whose title may include the name of a meeting or a client; the meeting summary by email, only for users who turn it on; account confirmation and invitation emails; and, for people who subscribed and did not open the app within 48 hours, a WhatsApp message to the phone given at checkout, with the link to get started.

What for: telling the user what needs action and helping people who paid to start using the product.

Legal basis: performance of the contract (art. 7, V); for the welcome message, legitimate interest in the customer using what they paid for (art. 7, IX). Just reply asking not to receive it again.

How long: while the account is active; the phone identifier is removed when it stops being valid or when the user turns notifications off.

Who receives it: Expo (delivers notifications to the phone, through Apple's and Google's services), Google (sends emails through Gmail), Supabase (account and invitation emails) and Uazapi (WhatsApp).

Sign-up and free trial

What: on free-trial links that work once per person: the email address (on the Brazilian site, the CPF taxpayer number) and the IP address, kept only as a cryptographic hash made with a secret key of ours, which cannot be read back, together with the email of the account created.

What for: preventing the same person from opening several free trials.

Legal basis: legitimate interest in preventing fraud (art. 7, IX).

How long: while the one-trial-per-person rule exists; there is no automatic deletion today, and you can ask for deletion through the contact in section 12.

Who receives it: Supabase (database).

Subscription payment

What: in US dollars: Stripe receives email, phone number (required), the address and tax ID it asks for to calculate tax, and the card details. In Brazilian reais: name or company name, taxpayer number, email, phone and address go to a Brazilian payment processor, which issues the charge and the invoice (the postal code is checked with a Brazilian postal-code lookup to fill in the address). We never receive or store card numbers. We keep the plan, the amounts, the phone number (in international format) and the messages the processor sends us about each payment, which may repeat name, email, address and tax ID. If you came through the link of one of our sales partners, they see your name, your email and whether the purchase was completed, so they can be paid their commission.

What for: billing the subscription, issuing invoices, calculating commissions and using the phone number for the welcome message above.

Legal basis: performance of the contract (art. 7, V) and compliance with tax obligations (art. 7, II).

How long: while the account is active and, after that, for as long as tax law requires.

Who receives it: Stripe or the Brazilian payment processor, depending on the currency.

Measuring our websites and ads

What: pages opened, clicks, how far down the page someone scrolled, where they came from (the previous site, the campaign and whether they came from an ad) and whether they booked a meeting, tied to a random identifier kept in the browser, with no IP address in our record. We use the Meta Pixel (pages and clicks, to measure and target our ads), Microsoft Clarity (how the page was used: scrolling, clicks and movements, with all text in the signed-in dashboard masked) and Google Tag Manager, and, when a booked meeting passes our quality score, we tell Google Analytics, using its browser identifier. These services use cookies and data stored in the browser. The dashboard also uses necessary first-party cookies: sign-in, the selected account and the help center. Pages whose address contains an access code (client report, invitation, short link, sales partner link) are excluded from any measurement.

What for: learning which pages and buttons lead someone to book or subscribe, and getting our ads to people who are interested.

Legal basis: legitimate interest in promoting and improving our own service (art. 7, IX). Our websites do not show a cookie notice today; you can block this measurement in your browser (an ad blocker or clearing the site's data) or object through the contact in section 12.

How long: our visit record is deleted after 12 months; third-party cookies follow each provider's rules.

Who receives it: Meta, Microsoft and Google, which also use this data under their own policies.

Sales chats on the website and bookings

What: in the demo chat (/vitrine): name, WhatsApp number, each answer and the free text typed (which goes to the AI model), and the contact left for the Mac version notice. In the qualification chat (/chatbot): name, WhatsApp number, company website or profile and the answers, saved after each answer, even if the person stops halfway. In bookings (through Cal.com): name, email, WhatsApp number, the form answers and notes and where the visit came from. In all three, the IP address only as a cryptographic hash, to detect repeats. The product gives each lead an automatic quality score; a low score means the lead is not reported to Meta and, when we turn that option on, cancels the booking.

What for: answering people who looked for the product, scheduling and holding the meeting, contacting the person on the WhatsApp number they left, and measuring which ads bring good leads.

Legal basis: steps prior to a contract, at the person's own request (art. 7, V); for keeping the answers and contacting on WhatsApp in the qualification chat, the consent the person ticks on screen (art. 7, I), which can be withdrawn at any time; for measurement and scoring, legitimate interest (art. 7, IX). Anyone whose booking was cancelled by the score can ask for a human review (art. 20, section 9).

How long: there is no automatic deletion today: we keep it while a business conversation is possible and delete it when you ask through the contact in section 12.

Who receives it: Anthropic (free text in the demo chat), Cal.com (booking), Meta (lead and booking events, with phone and email only as an irreversible SHA-256 code) and Google Analytics (qualified booking, with no name, email or phone).

Sign-up for the Saturday live session

What: the name, WhatsApp number and email typed into the form on the /live page, the box the person ticks to accept the live session's messages, where the visit came from (the ad, the campaign and the browser identifiers Meta uses: the fbclid and the _fbp and _fbc cookies) and the IP address only as a cryptographic digest. When the person enters the room through our page, we keep the time they entered. The sign-up becomes a contact and a deal in our sales pipeline.

What for: getting the person to the live session, sending the WhatsApp group link and the room link, talking to them before and after the session, and measuring which ads bring sign-ups and who shows up.

Legal basis: the consent ticked on the screen (art. 7, I), which can be withdrawn at any time; for measuring ads and attendance, legitimate interest (art. 7, IX).

How long: there is no automatic deletion today: we keep it while a commercial conversation may still happen and delete it when you ask through the contact in section 12.

Who receives it: Supabase (database); Meta, which receives the sign-up and the attendance with email, phone, name, country, state (from the area code) and a visitor identifier only as an irreversible SHA-256 code, and with the IP address and browser in clear, because Meta requires it; and WhatsApp, where the live session group lives. In a WhatsApp group the participants can see each other's numbers.

Support

What: in the help center chat: name, email, the messages and the page where the conversation started, with a visitor identifier kept in a cookie for up to 1 year; and article ratings.

What for: answering people who ask for help. When a conversation is waiting for an answer, our team gets an alert with the name, email and source page.

Legal basis: performance of the contract for customers (art. 7, V) and legitimate interest for people who are not customers yet (art. 7, IX).

How long: there is no automatic deletion today; we delete it when you ask.

Who receives it: Supabase and Telegram (our team's internal alert).

Prospecting companies (people who are not users)

What: we look for mid-size and large companies that may be interested in Hades Training or Hades Copilot. We collect contact data the company itself publishes (name, address, phone, email, website, social media profiles, size), through Google search run by the Gemini model and through the company's own website, plus research about it, which may include the name and title of a decision maker and a work email. We send at most one introduction message per channel, by email or WhatsApp, and keep the text sent and whether there was a reply.

What for: offering our products to companies, in a business-to-business contact.

Legal basis: legitimate interest in promoting our own service to companies (art. 7, IX, and art. 10), on contact data the company itself made public (art. 7, paragraph 4). Every message says how to opt out: just reply “remover” (“remove”) or write to the contact in section 12.

How long: while prospecting that company is in progress; there is no automatic deletion today. People who opt out are kept only as the minimum record needed not to contact them again.

Who receives it: Google (search through Gemini and email through Gmail) and Uazapi (WhatsApp).

Security and legal obligations

What: security events (attempted unauthorized access, attempted content extraction, usage above the limit), with the IP address, the account and, in some cases, the email; application access logs; and the audit record of our team's administrative actions, including the deletion of an account.

What for: protecting the product and the accounts, complying with Brazil's Internet Civil Framework (the “Marco Civil da Internet”) and complying with orders from authorities.

Legal basis: compliance with a legal obligation (art. 7, II) and legitimate interest in the security of the service (art. 7, IX).

How long: security events, 180 days; access logs, at least the 6 months the Marco Civil requires.

Who receives it: Telegram (internal alerts to our team, which may include an IP address, an account or an email) and the hosting providers.

Improving the product for all customers

What: patterns of objections, sales stage and outcome of meetings, cross-referenced across different accounts. This is done in an identifiable way internally (not anonymized), but it is never exposed, resold or shown in an identifiable way to another customer account. Left out: WhatsApp conversations, tracking leads and Hades Training.

What for: refining the guidance the copilot gives in future meetings.

Legal basis: legitimate interest in continuously improving the service offered to all customers (art. 7, IX, and art. 10). You can object to this use — see section 9.

How long: the same as the meeting content.

Who receives it: no one outside: our team does it.

3. Who sees what

An account's content (meetings, clients, conversations, training sessions) stays isolated in its own space — no other customer account can read it, on any screen of the product. A meeting recording is seen by the salesperson who recorded it and by the account's owner and managers, through a link that is valid for a few hours. This isolation is enforced in the database, not only on the screen. The only exception is Viccari Ads' own team (today: Lucas Sampaio and Yuri, the partners), who can see accounts to provide support, fix bugs, investigate incidents and run the cross-account analysis described in section 2.

Within the account, the business WhatsApp number is seen by the owner, the managers and the salespeople they give access to; a salesperson's personal number is seen only by them, and by the owner and managers only if they choose to share it. In Hades Training, employees see their own sessions, and the department manager and the account owner see the sessions of everyone in the department. The Viccari Ads team only opens WhatsApp conversations and training sessions to provide support when the customer asks, to fix a bug or to investigate a security incident.

The public ad report is only seen by people who have the link (a long secret code the company turns on and off), is not indexed by search engines and contains no lead data.

4. Who we share it with

The providers in section 13 process data on behalf of Viccari Ads, as processors under the LGPD, under contract, only for their part of the service. The AI providers do not use the content of your meetings, conversations or training sessions to train models.

Meta, Microsoft and Google, when measuring our websites, and WhatsApp, in conversations, also handle the data for their own purposes, under their own policies. In the conversion events we send to Meta, on a customer company's behalf or our own, phone and email only leave our systems converted into an irreversible code (SHA-256). Inside the signed-in dashboard, Clarity does not receive the text on the screen, and Meta only receives the page and the click, never what was typed.

Beyond this, we do not sell, rent or hand over personal data to anyone. Sharing outside this list only happens because of a legal obligation or an order from a competent authority — and, where the law allows, we tell you before complying.

5. International data transfers

The main database and the dashboard run in São Paulo, Brazil. Even so, several providers in section 13 are US companies and process or store part of the data outside Brazil: Deepgram, Anthropic, OpenAI, OpenRouter, ElevenLabs, HeyGen, Railway, Expo, Stripe, Cal.com, Google, Meta and Microsoft. The Uazapi servers that serve Hades are in Germany, and Telegram, which carries our team's internal alerts, also operates outside Brazil. Because we are a Brazilian company, this is an international data transfer under article 33 of the LGPD, and it relies on the contractual safeguards agreed with these providers (security, confidentiality and usage-limit commitments equivalent to those in this policy), as set out in the regulations of the ANPD, Brazil's National Data Protection Authority.

We use Deepgram's default global endpoint (not the EU-only processing option it also offers), and Anthropic may process a request — never store it — in data centers in other regions for network performance, while keeping storage in the US.

6. How long we keep it

While the account is active we keep its content: meetings, clients, Business DNA, Commercial Memory, follow-ups, proposals, research, WhatsApp conversations of the current number, leads and ad data, and training sessions. There is currently no period that deletes this content on its own while the account is active.

Closing the account. When the account's plan ends (subscription canceled or expired, or a free trial that has ended), we keep the account for 90 days. Seven days before the end of that period we notify the account owner in the dashboard (and on the phone, for people who use the app), and then the account is deleted automatically: all of its content, conversation, recording and support files, the WhatsApp connection, the Google and Meta authorizations and the access of anyone who belonged only to that account. If the company subscribes again before the period ends, the account stays. Suspension for non-payment does not delete data by itself: the period counts from the end of the plan. Only the audit record that the account was deleted remains, plus what the law requires us to keep (billing records for tax purposes). To delete earlier, or to ask for a copy of the data, the account owner writes to the contact in section 12, and we respond within 30 days of the request. An account that never had a paid plan or a trial with an end date has no automatic period: we delete it when the owner asks.

Automatic periods that already exist: WhatsApp conversations of a number the company replaced, 90 days without messages (with a warning 7 days before); meeting recordings stored by us, once they exceed the plan's recording hours (the oldest, 7 days later, with a notice); the record of website visits, 12 months; security events, 180 days.

No automatic period today (we delete when you ask): leads from the website chats and bookings, support conversations, the one-free-trial-per-person control and prospecting contacts. For people who asked not to be contacted, only the minimum record needed not to contact them again remains.

Because of legal obligations: access logs, at least 6 months (Brazil's Marco Civil); payment data and tax records, for the period tax law requires. What is kept because of a legal obligation is not used for anything else.

On your computer: the local copy of transcripts stays until you delete the app data folder, and meeting recordings stay in your videos folder until you delete the files. The sign-in session is only saved if you tick “Remember me”, protected by Windows encryption, and is deleted when you sign out.

7. How the data is protected

Data travels encrypted between the app, the dashboard and our servers. In the database, each account can only reach its own space, with an isolation rule enforced by the database itself on every content table. The access keys you entrust to us (Meta, Google, WhatsApp) are kept in tables only the server reads, never the browser. Team access is authenticated and logged, and security events (attempted unauthorized access, attempted extraction) create a record and an immediate alert to the team.

No system is invulnerable, and it would be dishonest to promise that here. Our commitment is to the design above and to the conduct in section 8 if something breaks.

8. If a security incident happens

If a security incident creates a relevant risk or harm for you or for the data subjects whose data you handled in the product, we will notify the ANPD and those affected within the regulatory deadline (currently 3 business days from when we learn of the incident), saying what leaked, what has already been contained and what to do. That is what article 48 of the LGPD requires, and it is what we would do anyway.

9. Your rights over your data

The LGPD (art. 18) guarantees you, and any data subject, the right to: confirm whether we handle your data; access that data; correct wrong or outdated data; ask for anonymization, blocking or deletion of anything unnecessary or excessive; ask for portability; know who we share it with; object to handling based on legitimate interest (such as product improvement, website measurement and the prospecting in section 2); and withdraw consent, when the handling depends on it. Under article 20, you can also ask for a person to review a decision made solely by automated means, such as a booking cancelled by the quality score. You also have the right to complain directly to the ANPD.

Requests are made through the contact in section 12 and answered within 15 days. Exercising any of these rights does not change the price or the treatment you receive as a customer.

If you were the prospect in a meeting run by one of our customers — that is, you took part in a call but have no account here — the main channel is to ask the company that held the meeting with you, since it decides whether to keep that business relationship. We also accept requests directly through the contact in section 12; in that case, we confirm the identity of whoever is asking before acting.

If you talked on WhatsApp with a company that uses Hades, became one of its leads through its ads, or trained in Hades Training through your employer, that company decides about this data, and the request should go to it first. If the request reaches us, we pass it on to the company and help with whatever it needs to answer.

If your company received a prospecting message from us, reply “remover” (“remove”) or write to the contact in section 12, and we will not contact you again.

10. Notice during the meeting

We recommend — and in the Terms of Use the user commits to it — that whoever runs the meeting tells the other side, before or at the start of the call, that the conversation is being transcribed and analyzed by an AI assistant and, when recording is on, that the meeting is being recorded.

11. Children and teenagers

The product is a work tool for business-to-business sales and is not intended for anyone under 18. We do not create accounts for minors, and the user agrees not to use the product in a meeting where a child or teenager is the subject of what is discussed.

12. Data protection officer and contact

Our data protection officer (the “encarregado” under article 41 of the LGPD) is Yuri Viccari, a partner at Viccari Ads. Questions, requests for access, correction or deletion: admin@hades-copilot.com.br.

13. Processors and other providers

Who processes personal data so the product works, what they do and where they are:

  • Supabase — database, sign-in, account emails and files (server in São Paulo; US company).
  • Vercel — hosts the dashboard and the websites (functions in São Paulo; US company).
  • Railway — hosts the app server and the scheduled routines (US company).
  • Deepgram — transcription of meetings and of voice in Hades Training (US).
  • Anthropic — the Claude model: suggestions, analysis, follow-ups, proposals, the demo chat and Hades Training (US).
  • OpenAI — the GPT model that, when switched on, does the analysis after the meeting in place of Claude; it receives the transcript and the account context (US).
  • OpenRouter — an intermediary that forwards the analysis request to OpenAI, set to use only providers that neither keep the content nor use it to train models (US).
  • ElevenLabs — the bot's voice in Hades Training; receives only the bot's text (US).
  • HeyGen — optional live face in Hades Training; receives only the bot's audio (US).
  • Uazapi — connection with customer companies' WhatsApp and our own (servers in Germany).
  • Meta — WhatsApp, customer companies' ad accounts, conversion events and the Meta Pixel (US).
  • Google — Google Calendar of users who connect it, email sending through Gmail, prospecting search through Gemini, Google Analytics and Tag Manager (US).
  • Microsoft — Clarity, website usage measurement (US).
  • Expo — delivers notifications to the mobile app (US).
  • Cal.com — meeting booking on the website (US).
  • Stripe — billing in US dollars (US).
  • A Brazilian payment processor — billing in Brazilian reais and invoices, with a Brazilian postal-code lookup (Brazil).
  • BrasilAPI — lookup of public Brazilian company registration data in pre-meeting research (Brazil).
  • Telegram — internal alerts to our team (outside Brazil).

14. Changes to this policy

This is version v2.4, of October 27, 2026. It changed section 6: a closed account is now deleted automatically 90 days after the plan ends, with a notice to the owner 7 days before (before, deletion was only at the owner's request). The data protection officer is now Yuri Viccari (section 12). The Terms of Use did not change in it. v2.3, of October 23, 2026, did not change the text of this policy: the number went up because the Terms of Use gained the section about a WhatsApp number connected to the product, and the acceptance covers both documents together. v2.2, of October 8, 2026, added the meeting recording, which only exists when the salesperson turns it on or the manager makes it mandatory (section 1, the “Meeting recording” processing activity in section 2, and sections 3, 6 and 10): until then the product never recorded the meeting. v2.1 added the minimal copy of Google Calendar events that we use for the meeting notices (section 1 and the “Google Calendar” processing activity in section 2); before it, events were not kept. The previous version, v2.0, was a rewrite: the policy now covers everything the product does with personal data today, taken from the code itself. Added: Hades Training, ad tracking in full (leads, ad account and budget changes), research before the meeting, the website chats and bookings, Google Tag Manager and Google Analytics, sign-up with a free trial, payment in reais and in dollars, notifications and the email summary, the WhatsApp welcome message, support, company prospecting and the local copy of the transcript on the salesperson's computer. Each processing activity now states its legal basis, period and recipients (section 2), and providers have their own list (section 13). We also corrected two passages that did not match the product: deletion after an account is closed is done on request, within 30 days of the request, not on its own; and a company asks for deletion of WhatsApp conversations through the contact in section 12, because the dashboard has no such button.

The first version of this policy in English was v1.8, of September 21, 2026; v1.9, of September 30, 2026, added Google Calendar; v2.0, of October 8, 2026, was the rewrite described above. It follows the Portuguese document of the same version item by item; the version number is shared by the pair of documents, because accepting at sign-up covers this policy and the Terms of Use together.

This policy has not yet been through formal legal review. Relevant changes will create a new numbered version, and anyone who accepted an earlier version will be notified.