Unotela Privacy Policy
This is an English translation of the Portuguese privacy policy, published at /privacidade. If the two versions differ, the Portuguese version prevails.
This policy explains which personal data Unotela processes, what for, for how long, with whom it is shared and how you exercise your rights, under the Brazilian General Data Protection Law (LGPD, Law 13,709/2018).
Unotela is a platform for screens, kiosks, LED panels and smart lockers: businesses set up their devices in a web panel, and the devices show content, run apps and report on their own operation to the panel.
Who we are: Unotela is developed and operated by Sudden Soft LTDA, a company registered in Brazil under CNPJ 59.080.862/0001-14, São Paulo/SP. Contact: [contact e-mail to be defined].
Data protection officer (encarregado): [data protection officer to be defined].
In short
- We process what Unotela needs to work. We do not sell data and do not use it for advertising.
- We use no advertising or browsing analytics cookies.
- In the lockers, the deposit code is never readable: it is kept only scrambled, and on current devices it never leaves the device.
- The satisfaction survey is anonymous, and audience counting keeps only numbers, never images.
- Payments go through Asaas. We neither receive nor store your card number.
1. Who decides about the data
The LGPD distinguishes the controller, who decides about the processing of the data, from the processor, who processes data on the controller's behalf.
| Data | Controller | Our role |
|---|---|---|
| Panel accounts, acceptance of these documents, billing, contact requests, our own support, activity history and security | Sudden Soft | controller |
| Data of the people who use the screens and lockers, survey answers, audience counts, records kept by apps, media, devices and support provided by the customer through the Unotela support desk | the customer who owns the screens | processor: we process this data only to provide the service, following the customer's instructions |
The customer is the organisation that subscribes to Unotela (a gym, a shop, a clinic, a chain). The reseller or supplier is the company that sells, installs and maintains the equipment and may manage the panel on the customer's behalf; in that role, it also processes the data on the customer's behalf.
If you used a Unotela screen or locker in a shop or gym and have a question about your data, contact that business first. We help the business answer.
2. What data we process
Panel accounts
- Account: name, e-mail, password (kept only as a hash, a scrambling that cannot be undone), the organisations you belong to and your role in each.
- Sign-up on the website: besides the account, the company name, which becomes your organisation.
- Sessions: IP address and browser of each open session, to keep you signed in and protect the account.
- API keys created by the customer: the last IP that used each key.
- Activity history: who created, changed or deleted something in the panel or through the API, when, on behalf of which organisation and from which IP. Reads and sign-ins are not recorded, and the content of personal data that was changed is not copied into it.
- Acceptance of the terms of use and this policy: which version was accepted, by whom, on behalf of which organisation, when, at which moment (sign-up, payment or a new version) and from which IP.
Billing
- Name or company name, CPF or CNPJ (Brazilian tax ids) and e-mail of the payer, and the e-mail for billing notices, if given.
- Statements, charges and payments: amounts, due dates, status and the payment link or Pix code.
- Saved card: only the identifier issued by Asaas (stored encrypted), the brand and the last 4 digits. The card number and bank details stay with Asaas.
- Developers and suppliers paid through the platform: the data Asaas requires to open the payout account (name or company name, CNPJ, e-mail, mobile phone, revenue and address).
- Locker rental paid by Pix: we ask for no data about the renter. We keep the amount, the payment status and the Pix code; the payer is identified only by their own bank.
Contact requests
Whoever fills in "talk to sales" on the website gives their name, company, e-mail, phone, number of screens and a message. We also keep the IP and the browser, to prevent abuse.
Support
When someone contacts support, ours or that of a customer using the Unotela support desk, by WhatsApp, e-mail, website chat or from a device's screen, we process the name, phone or e-mail given, the messages, the attachments and the rating of the support. Voice messages are transcribed into text and the audio is not kept.
Devices
- Identification: name, model, serial number, MAC address, public key and the last public IP of each device.
- Technical data (telemetry): temperature, memory, disk, versions, network (local IP, MAC address, Wi-Fi network name and signal), the address of the page on screen, peripherals and the state of the locker doors.
- Wi-Fi networks set up from the panel: name and password, the password stored encrypted.
- Logs of the device's system. In the Unotela system, passwords, keys and access codes are hidden before they leave the device.
- Events and alerts: door opened or closed, updates, errors, device offline, and what each screen showed.
- Commands sent to the devices: which, by whom, when and the result.
- Screenshot: only when someone in the panel asks for one.
- Remote support: who watched a device's screen and when. The live image is not kept.
This data is about the device, not about the people passing by it. A screenshot shows what was on the screen at that moment.
Lockers
The locker asks for no name, phone or document. For each deposit we keep:
- the locker and the device;
- when the item was stored and retrieved, and whether it was retrieved with the code or from the panel;
- how many times a wrong code was entered, to block guessing.
The code chosen by the person (and, when the customer uses them, the badge or the second factor, such as the date of birth or phone digits) is kept only scrambled (a hash), never readable. On current devices, this hash stays on the device only. Devices with older versions of the system send the code to our server, which keeps only its hash.
Satisfaction survey
It is anonymous: we keep the answer chosen, the time and the screen where it was given. No data about who answered.
Audience counting
When the customer turns on audience counting on a device with a camera, the images are analysed on the device itself, in memory, and discarded at once. Only numbers leave the device: how many people passed by and for how long, every 15 minutes. No image is kept or sent, and there is no facial recognition.
App usage
How many times and for how long each app was used, and a map of touches on the screen (how many touches in each area). No data about who touched it. The customer's own apps may also send reports to the panel, with the content the customer defines.
Records kept by apps
An app installed by the customer may keep records in Unotela, for instance a form with a name, phone or e-mail. The customer decides what to collect and for how long to keep it, and must inform people on the screen itself. From the panel, the customer finds and deletes a person's records.
Marketplace
Quote requests and messages exchanged between customers and suppliers through the marketplace, with their attachments and each supplier's contact details.
Media
Videos, images and pages the customer publishes on the screens. If a media item shows people, the customer is responsible for having permission for it.
3. What we use it for, and on which legal basis
| Use | Legal basis (LGPD, art. 7) |
|---|---|
| Creating and keeping accounts, signing in, sending invitations and access and new password links | performance of a contract (item V) |
| Providing the service subscribed: screens, devices, lockers, apps, remote support, support | performance of a contract (item V); for the customers' data, the basis is set by the customer, as controller |
| Protecting the accounts and the service: sessions, attempt limits, activity history, device logs and alerts | legitimate interest (item IX) |
| Keeping the proof of acceptance of these documents | regular exercise of rights (item VI) |
| Billing and keeping tax and accounting records | performance of a contract (item V) and compliance with a legal obligation (item II) |
| Answering contact requests | preliminary steps to a contract, at the person's request (item V) |
We do not use personal data for advertising, we do not sell data and we do not make automated decisions about people.
4. Who we share it with
Only with those we need for the service to work:
| Who | What for |
|---|---|
| Hosting and file storage providers | the servers where Unotela, its database and the media are kept |
| Asaas | billing and collection (card, Pix, boleto) and payout accounts of developers and suppliers; Asaas sends no billing notices to payers on our behalf |
| Mercado Pago | when the customer uses the integrated card machine: it receives the amount and the payment reference, with no data about the payer |
| E-mail delivery provider | sending account e-mails and support replies |
| Meta (WhatsApp) | support through WhatsApp, when used |
| Artificial intelligence providers (such as Anthropic, OpenAI and Groq) | when these features are on: suggesting support replies (with the messages of the conversation, without the writer's name or phone), transcribing voice messages, generating speech, reviewing the code of apps submitted to the store and helping the customer build apps |
| The customer's reseller or supplier | managing the panel and maintaining the devices on the customer's behalf; a supplier with partner access sees only the health of the devices granted to it |
| Developers of store apps | only what the app installed by the customer sends; the app's page shows who the developer is and where it sends data |
| The customer's own systems | automatic notifications (webhooks) to the addresses the customer sets up |
| Authorities | when the law or a court order requires it |
Asaas and Mercado Pago are also controllers of the payment data they receive, and follow their own privacy policies.
Some of these providers, such as the artificial intelligence ones and WhatsApp, are outside Brazil, mainly in the United States. In those cases, the international transfer is made to perform the contract or at the data subject's request (LGPD, art. 33, IX), and we send only what each function needs.
5. How long we keep it
| Data | How long |
|---|---|
| Device telemetry | 24 hours; after that, only an hourly summary (minimum, average and maximum of a few numbers), for 30 days |
| Device logs | 14 days |
| Events, closed alerts and what each screen showed | 90 days |
| Screenshot | until the next screenshot, or until the device leaves the account or is paired again |
| Locker deposits | while the item is stored, and 1 year after it is retrieved |
| Survey answers, app usage and reports sent by apps | 1 year |
| Touch map | 90 days, or the period the customer chooses, from 30 days to 1 year |
| Audience counts | 13 months |
| Records kept by apps | the period the customer sets for each collection (1 year unless changed) |
| Media | until the customer deletes them; media not in any device's schedule for 180 days are deleted automatically |
| Activity history | 1 year, or the period the customer chooses, from 90 days to 5 years |
| Sessions | until you sign out or about 2 hours without use; with "remember me", the browser keeps you signed in for up to 400 days |
| Invitations | until accepted or expired, after 7 days |
| Support conversations | anonymised after 12 months without any new message |
| Automatic notifications (webhooks) sent | 30 days |
| Panel account, contact requests, commands sent to devices, remote support and partner access history, marketplace requests and messages | no automatic deletion; until a request for deletion |
| Acceptances of the terms and this policy | no automatic deletion, as proof of acceptance |
| Billing data and statements | at least for the periods required by tax and accounting law |
Database backups may keep data for longer than the periods above. They are kept in a restricted environment and used only to restore the service.
When the contract ends, the periods for retrieving what was left in the lockers and for the customer to download its data are those of the licence agreement. After them, the customer may ask for the organisation's data to be deleted, and we keep only what the law requires us to keep.
6. Security
- Connections always encrypted (HTTPS).
- Passwords and locker codes kept only as hashes; Wi-Fi passwords and saved card data stored encrypted.
- Each device signs what it sends with its own key.
- Each customer sees only its own data, and each person can do only what their role allows.
- At Sudden Soft, only those who need it, for support and security, access the customers' data.
- If a security incident may cause significant risk or harm to anyone, we notify the Brazilian National Data Protection Authority (ANPD) and those affected, as the law requires.
7. Cookies and browser storage
The panel uses only necessary cookies: the session one, the one protecting forms and, if you tick "remember me", the one that keeps you signed in. The browser also keeps panel preferences (theme, chosen organisation, notices already seen) and, in the website's support chat, the conversation's identifier for 30 days. We use no advertising, browsing analytics or third-party cookies.
8. E-mails
We send e-mails only when needed: invitations, links to create or change your password, and support replies and ratings. We send no advertising.
9. Your rights
You may ask, at any time (LGPD, art. 18):
- confirmation that we process your data, and access to it;
- correction of incomplete, wrong or outdated data;
- anonymisation, blocking or deletion of what is unnecessary, excessive or processed against the law;
- portability of the data to another provider;
- information on whom we share your data with;
- information on the possibility of not giving consent, and withdrawal of consent, when it is the basis;
- deletion of the data, except what the law requires us to keep.
To ask, contact the data protection officer: [data protection officer to be defined]. We answer within 15 days. If the data comes from a screen or the support of one of our customers, we forward the request to them and help them answer.
You may also lodge a complaint with the Brazilian National Data Protection Authority (ANPD), at gov.br/anpd.
10. Children and teenagers
The panel is meant for businesses and is not intended for anyone under 18. The lockers, the survey and audience counting may reach anyone, children included, and collect no name, image or other data that identifies who uses them.
11. Changes to this policy
If we change this policy, we publish the new version with its date, and the earlier versions remain available on this page. When the change is relevant, we ask those responsible for each organisation to accept it in the panel.
This policy is also available in Portuguese. If the two versions differ, the Portuguese version prevails.