LGPD compliance

Controller and processor

For account and billing data, Turrety is the controller (controlador). For the telemetry your apps send, you are the controller and Turrety is the processor (operador), acting only on your documented instructions, as set out in our Data Processing Agreement.

Legal bases (art. 7)

We process personal data on these bases:

• Performance of a contract: to provide the service you signed up for.
• Legitimate interest: to protect the platform and our customers against abuse and attacks, with a documented balancing test.
• Legal obligation: to keep invoices and tax records.
• Consent: only for optional cookies and marketing emails, which you can withdraw at any time.

Data subject rights (art. 18)

As a data subject (titular), you can ask us for:

• Confirmation that we process your data, and access to it.
• Correction of incomplete, inaccurate or outdated data.
• Anonymization, blocking or deletion of unnecessary or excessive data.
• Portability of your data to another provider.
• Information about who we share your data with.
• Withdrawal of consent, and information about the consequences of refusing it.

How to make a request

Write to our Data Protection Officer (encarregado) at [email protected]. We answer within 15 days, as art. 19 requires. If your data reached us through one of our customers, we forward the request to them, since they are the controller.

International transfers (art. 33)

Telemetry is stored in the region where Turrety runs; keeping it in a region of your choice is arranged per Enterprise contract. When data is transferred abroad, for example to a subprocessor, we rely on the standard contractual clauses approved by the ANPD.

Security incidents (art. 48)

If an incident may cause relevant risk or damage to data subjects, we notify affected customers without undue delay and the ANPD within the period set by its regulation, with the nature of the data, the people involved and the measures taken.

Complaints

You can also file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at gov.br/anpd.