Privacy policy

This policy explains which personal data Meu Cartão Fidelidade processes, why, whom it is shared with in order to work, and how long it is kept. It distinguishes two groups of people: you, who subscribe to the service, and your end customers, whose data you enter. Our role differs in each case, and that difference is the first thing this document deals with.

1. Who processes your data

This policy is issued by EMBLEMMA TECNOLOGIA LTDA, CNPJ 68.144.255/0001-61, Av. Advogado Horácio Raccanello Filho, 6326, Sala 7, CEP 87020-035, Maringá – PR. For anything to do with personal data, including to reach our data protection officer, write to the address at the end of this document.

Two different roles

• For your account data — your name, your e-mail address, your business's name, your billing — we are the controller. We decide why we process it and we answer to you for it directly.
• For your end customers' data — the people you register so they can take part in your loyalty programme — you are the controller and we are the processor. You decide what to collect; we process it only to make the service work and only as you instruct.

In practice: if an end customer wants to know what your business holds about them, or asks for it to be deleted, you are the one who answers. If the request reaches us directly, we pass it to you and help with the technical side.

2. Data we process about you, the subscriber

Registration and account data

• Your name and sign-in e-mail address.
• Your password, held in encrypted form by our authentication provider. We cannot see it and cannot recover it.
• A profile picture, if you upload one.
• Your business's name, country of operation and logo, if you upload one.
• The plan subscribed, the state of the subscription, its start and expiry dates, and a billing identifier generated by our payment processor.

Usage data

• Technical access logs, with IP address, date and time, generated by the infrastructure services we use.
• Aggregated monthly counters for your account — customers registered, points awarded, rewards given, messages sent — used to draw your dashboard and to enforce plan limits.

We do not ask for and do not want your card number. Payment happens in our processor's environment, which returns only the subscription identifier and whether it is paid.

3. Data you enter about your end customers

As processor, we handle whatever you enter about each end customer. The system has fields for:

• name and loyalty card number;
• date of birth;
• tax identification number, where you choose to record it;
• e-mail address, mobile number and landline, each with its country;
• address: postal code, street, number, district, city and state;
• points balance, rewards received, number of visits, date of last visit and a VIP marker;
• a history of movements, with date, points, balance, type of operation and whatever note you write.

Which of those fields to fill in is your decision. We recommend collecting only what your programme needs: a programme that works with a name and a mobile number needs neither a tax number nor a full address.

The platform must not be used for sensitive personal data — health, biometrics, religion, racial origin, political opinion, or children's data without a guardian's consent. There are no fields for it, and using it that way breaches the Terms of Use.

4. Where the data comes from

• From you: everything typed into the system, by you or by whoever operates the account.
• From your device, automatically: the technical access logs described above.
• From our payment processor: the state of your subscription.
• From a public postal code lookup service: when you use address autofill we send only the postal code typed and receive the matching street. No customer data is sent in that lookup.

5. Why we process it, and on what legal basis

• To create and maintain your account, authenticate access and deliver the features subscribed — performance of the contract.
• To charge the subscription and enforce plan limits — performance of the contract.
• To send operational notices: billing, password reset, failed payment, trial ending, changes to these documents — performance of the contract and legal obligation.
• To provide support when you contact us — performance of the contract.
• To keep the platform secure, investigate abuse and prevent fraud — legitimate interest.
• To send, on your behalf, the balance, birthday and virtual card messages to your end customers — performance of the contract with you, with you responsible for the lawful basis towards the end customer.
• To meet tax, accounting and record-keeping obligations — legal obligation.
• To share product news, where there is any — legitimate interest, with the option to unsubscribe at any time.

We do not profile you, we make no automated decisions about you, and we do not use your data or your customers' data to train artificial intelligence systems.

6. Whom we share it with

We do not sell personal data, do not pass it to advertisers and do not share it with other subscribers. We share only with the providers the service needs in order to work, and only as far as needed:

• Google (Firebase): account authentication, the database holding your settings and your end customers, and storage for the files you upload.
• Amazon Web Services: the servers running the system's functions, e-mail sending, SMS sending and application hosting.
• Stripe: payment processing and subscription management.
• A public postal code lookup service: only the postal code typed, for address autofill.

We may also share data where there is a court order or a request from a competent authority, and on a corporate reorganisation, merger or sale of the business — in which case the acquirer takes on the commitments in this policy, and you will be told.

7. International transfer

The providers above run servers outside Brazil, mainly in the United States, where the data is stored and processed. The transfer is made to enable performance of the contract with you, under article 33 of the LGPD, and to providers offering contractual clauses and protection safeguards compatible with the applicable law.

8. How long we keep it

• Account and end customer data: while the subscription is active.
• After the account is closed: up to 90 days, so it can be reactivated, and then deleted. You may ask for immediate deletion.
• An end customer you delete: the record is removed from the database at the moment of deletion.
• Uploaded files — profile picture, logo: deleted along with the record they belong to.
• Aggregated monthly counters for the account: kept as statistics, identifying no end customer.
• Tax documents and access logs: for the period the law requires, even after the rest has been deleted.

Closing the account in the system requires your password, cancels the subscription at the payment processor, and removes your registration details, your settings, your end customers and the files you uploaded.

9. How we protect it

• All traffic between your browser and the platform is encrypted.
• Passwords are held by the authentication provider, encrypted, and are inaccessible to us.
• Each account is isolated: the database rules let an account read and write only its own data, and that check happens on the server, not in the browser.
• Calls to our API require a valid session token, verified on every request, and the token is sent only to our own address.
• Uploaded images are re-encoded before being stored, which strips metadata — including a photo's location — and discards anything hidden inside the file.
• You choose, when signing in, whether the session survives closing the browser.

No system is immune. If a security incident occurs with material risk to the people concerned, we will notify you and the Brazilian data protection authority within the time and in the manner the law requires.

10. Cookies and local storage

We use no advertising cookies, have no third-party audience analytics, and do not track you outside the platform.

We use your browser's local storage for what the service needs to work and to remember preferences:

• keeping your session signed in, according to the choice you made when signing in;
• remembering the e-mail address in the sign-in field, if you tick that option;
• storing interface preferences: language, light or dark theme, list ordering and collapsed cards.

Clearing your browser data removes all of it. The platform still works, it simply does not remember your preferences.

11. Your rights

The law gives you, over your own data, the right to confirm that processing takes place, to access the data, to correct data that is incomplete or out of date, to ask for anonymisation, blocking or deletion of unnecessary data, to ask for portability, to know whom we share it with, to withdraw consent, and to object to processing based on legitimate interest.

Much of this is in the platform itself: you edit your registration details, change your sign-in e-mail address, reset your password, export your customer base and close the account without speaking to anyone. For the rest, write to the address at the end of this document — we answer within 15 days, and may ask for information to confirm your identity first.

If you are an end customer of a business that uses the platform, your rights should be exercised with that business, which is the controller of your data. We can point you to whom to ask, but we cannot change or delete data on our own initiative.

You may also complain to the Brazilian data protection authority. We would rather resolve things with you first.

12. Children and young people

The platform is intended for businesses and is not offered to under-18s as subscribers. A loyalty programme may have end customers who are minors, and in that case it is the subscriber's responsibility to obtain the specific consent of a guardian before registering them, in the best interests of the child.

13. Changes to this policy

This policy may change. Material changes — new purposes, new providers with access to data, changes to retention periods — are notified to your registered e-mail address at least 30 days in advance. Wording changes take effect on publication, and the date at the top shows when it was last changed.

Questions, requests about your data, or to reach our data protection officer: contato@meucartaofidelidade.com.