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Privacy Policy

Last updated: July 19, 2026

TELECOM TOWER POWER LTDA. ("we") processes personal data in compliance with Brazilian LGPD (Law 13.709/2018) and the Internet Civil Framework.

1. Controller

2. What we collect

Category Data Purpose LGPD legal basis (art. 7)
Account Email, name (optional) API key provisioning, billing Contract performance (V)
Payment Tokenized by Stripe (no PAN stored) Charging Contract performance (V)
API usage IP, User-Agent, endpoint, timestamp, status Anti-fraud, capacity, security Legitimate interest (IX)
Audit logs Key issuance, SSO login, admin actions SOC 2 compliance, incident response Legal obligation (II)
Communications Support tickets, emails Customer service Contract performance (V)

We do not collect sensitive data (race, health, biometrics, political opinion).

3. How we use data

  • Service provisioning and billing.
  • Abuse detection (rate-limit, bot signup, card fraud).
  • Operational notifications (incidents, trial expiry).
  • Aggregated, non-identifying analytics for roadmap.

We do not sell your data. We do not share with third parties for marketing.

4. Subprocessors

We share strictly required data with:

Subprocessor Purpose Country Safeguard
Railway (primary hosting) API, workers, database, Redis, MinIO, observability, self-hosted LLM USA (us-west2) — no Brazil region offered Railway DPA; SOC 2 Type II; encryption in transit/at rest; LGPD Art. 33
Amazon Web Services (AWS) Legacy, being decommissioned: cold S3 backups only Brazil (sa-east-1) AWS DPA, encryption at rest/transit
Stripe Payments Inc. Card processing USA Stripe DPA, PCI-DSS L1
Anthropic / Amazon Bedrock AI models — currently disabled: inference is served by self-hosted Ollama on Railway infrastructure, no customer data sent to a third-party LLM USA (if re-enabled) Zero-retention processing, prompts not used for training
Cloudflare DNS, CDN, anti-bot (Turnstile) Global Cloudflare DPA
Zoho Corporation (Zoho Mail) Corporate email for @telecomtowerpower.com.br (sales@, support@, dpo@, security@ and catch-all) USA Zoho DPA; ISO 27001; SOC 2 Type II
GitHub CI/CD, build, registry USA GitHub DPA; SOC 2

Full public list: Subprocessors.

5. International transfer

Primary processing occurs in the United States (Railway us-west2) since the 2026-06 cutover — Railway offers no Brazil/South-America region. This is a permanent international transfer under LGPD art. 33: standard contractual clauses with each subprocessor and/or ANPD-recognised adequacy. Controllers with a strict Brazil-residency requirement must use the on-prem/self-hosted mode (see DPA §8).

6. Retention

Summary. The full retention matrix by category, with deletion mechanism and legal basis, is in DPA-LGPD §10.1 — in case of conflict, the DPA prevails.

Data Retention Basis
API access logs 6 months Marco Civil Art. 15 §1
audit_log (admin actions) 12 months LGPD Art. 16 II
Operational logs (CloudWatch) 30 days Technical necessity
Account data Term + 5 years CDC Art. 27
Customer-submitted personal data Term; deleted within 90 days after termination LGPD Art. 16 I
Coverage prediction cache 24 h TTL Technical necessity
Encrypted backups 14 days (rolling) LGPD Art. 46
Billing (Stripe) 5 years CTN Art. 173 I
Session tokens 7 d (session) / 30 d (refresh) LGPD Art. 46
ANATEL/IBGE/SRTM/OpenCellID data Indefinite (public) Law 9.472/1997 Art. 19

For DSAR erasure requests (Art. 18 VI): immediate anonymization + physical removal 30 days later (after backup rotation).

Measurements and the global model

If you submit field measurements through the API, they are used to serve your own operation. For a measurement to also train the global coverage model — which serves every customer on the platform, your competitors included — you must say so explicitly, per row, via consent_for_training.

Without that declaration the answer is no. The measurement is stored, it keeps serving you, and it stays out of global training. The response to your own request reports how many rows were admitted and how many refused (granted_for_training / refused_for_training), and the refusal is recorded in your audit log. You can withdraw at any time through support.

7. Your rights (LGPD art. 18)

You may, free of charge, request:

  1. Confirmation of processing;
  2. Access to data;
  3. Correction of incomplete or outdated data;
  4. Anonymization, blocking, or deletion of unnecessary data;
  5. Portability;
  6. Deletion of consent-based data;
  7. Disclosure of sharing;
  8. Withdrawal of consent.

How to exercise them

If you hold an active API key, do it yourself — no intermediary, no 15-day wait. The authenticated key is the proof of identity, and it only ever acts on your own account:

Right How
Access and portability (items II and V) GET /tenant/me/data/export — returns, as JSON, everything we hold about you: account record, audit history, submitted jobs, field observations you contributed, and billing identifiers
Deletion and anonymization (items IV and VI) POST /tenant/me/data/forget with body {"confirmation":"DELETE MY DATA"} 
export TTP_API_KEY="your-key-here"
curl -sS -H "X-Api-Key: $TTP_API_KEY" \
  https://api.telecomtowerpower.com/tenant/me/data/export > my-data.json

Deletion is immediate and cannot be undone through the API. Your personal data is replaced with pseudonyms at once and the key stops working at once. Physical row removal happens 30 days later — a window that exists so backups rotate out and no copy of you survives a restore, and during which you can still reach us if the deletion was a mistake.

Audit records are retained against your pseudonymised identifier: LGPD Art. 16 II requires us to keep certain records to meet a legal obligation, but they no longer point back to you.

Other channels

If you no longer have access to the key, or prefer to write to us, email dpo@telecomtowerpower.com.br. Response within 15 days. We will ask you to prove your identity before acting — the same protection that stops someone else from requesting the deletion of your data.

You may also complain directly to the Brazilian DPA (ANPD, www.gov.br/anpd).

8. Security

  • TLS 1.2+ enforced on all connections.
  • At-rest encryption (AWS KMS) for DB and S3.
  • API keys are hashed (SHA-256) — never stored in cleartext.
  • Per-key and per-IP rate limiting; CAPTCHA on free signup.
  • Immutable audit logs with IP + UA on key issuance.
  • Encrypted backups, quarterly key rotation.
  • SOC 2 Type II programme in progress (gap analysis at /compliance/soc2/).

9. Cookies

The marketing site and portal use only strictly necessary cookies (session, CSRF). No advertising cookies.

10. Children

The service is for businesses and professionals. We do not knowingly collect data from anyone under 18.

11. Changes

Material changes will be announced by email 30 days in advance. Previous versions remain in the public docs repository history.

12. Contact