Privacy Policy

This policy is issued by CCX Digital Solutions LTDA, CNPJ 24.329.191/0001-06, which operates the CCX Messages platform. Whenever "we" appears here, it refers to that company.

The platform is a communications infrastructure used by other companies to talk to their own customers. This creates two distinct roles, and the difference between them determines almost everything that follows in this policy.

As controller, we process only what is necessary to operate the service, bill for it, and comply with legal obligations. We do not buy databases, we do not enrich data with third parties, and we do not use advertising tracking on the website.

On the public website we use only cookies strictly necessary for operation — such as keeping your session active and remembering display preferences. We do not use advertising cookies, we do not run remarketing, and we do not share identifiers with ad networks.

To understand page performance we use aggregate measurement, without building an individual profile and without cross-referencing registration data. You do not need to accept a banner to browse because there is nothing beyond the essential to consent to.

Message content, contact lists, and conversation history belong to the customer that hired the platform. We process this data only to deliver the contracted service, following the instructions documented in the contract and in the data processing agreement.

When the customer enables the AI agent, its messages and knowledge base documents are sent to model providers to generate the response for that interaction. Our contracts with these providers prohibit retaining content for model training.

No conversation on the platform trains a model — neither ours nor a third party's. Knowledge base documents only serve to retrieve context for the customer's own responses, and the interaction record masks sensitive personal data while preserving the traceability of the decision.

We share data only with parties necessary for the service to exist, always under a data processing contract and with a limited purpose. The complete, up-to-date list of sub-processors is available on request, and relevant changes are communicated as set out in the contract.

Platform data is stored in Brazil, including replicas and backups. International transfer happens only in specific, defined situations: message delivery by a channel provider with global infrastructure, and AI inference when the chosen model operates outside the country. In these cases we apply contractual protection clauses equivalent to those required by the LGPD.

The retention period depends on the nature of the data. Message content is retained on a schedule the customer configures, from 30 days to 5 years; tax records follow the statutory period, which cannot be negotiated by contract.

The LGPD grants you a set of rights, and we respond to all of them within 15 days — usually well before. We do not charge for the response and do not require justification for the request.

We apply encryption in transit and at rest, role-based access control, mandatory two-factor authentication for administrative profiles, and action audit logs. The technical details and the responsibility model are described on the security page.

In case of a security incident with material risk to data subjects, we notify the affected customers within the timeframe set in the contract, covering the scope of what happened, the data potentially involved, the containment measures taken, and the recommended action. This exists so the customer can meet its own obligations before the ANPD and the data subjects.

When we amend this policy, we update the effective date at the top and keep prior versions available on request. A change that reduces rights or expands purposes is communicated to customers by email at least 30 days in advance, so there is time to evaluate and, if appropriate, terminate the contract at no cost.