This Privacy Policy has been structured to comply with Brazil’s General Personal Data Protection Law (LGPD), the European Union General Data Protection Regulation (GDPR), the UK GDPR, and, where applicable, privacy laws of other jurisdictions such as the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), Mexico’s Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP), Colombia’s Law 1581 of 2012, Argentina’s Law 25.326, Chile’s Law 19.628, and Uruguay’s Law 18.331.
The specific application of each law depends on factors such as the data subject’s place of residence, the location where the data was collected, the purpose of processing, WPP Marketing’s role in the operation, and the contractual relationship with our customers.
1. Overview
This Policy explains how WPP Marketing handles personal data on its website, platform, apps, APIs, integrations, forms, support channels, commercial activities, marketing communications, and services related to WhatsApp automation, e‑commerce, campaigns, customer service, sales, and reporting.
Personal data are information that identify or may identify a natural person, directly or indirectly. Depending on applicable law, they may also include online identifiers, browsing data, device information, geolocation and inferences associated with a person or consumer.
By using our services, contracting WPP Marketing, accessing our channels or interacting with our forms, you acknowledge that your personal data may be processed in accordance with this Policy and the applicable contracts, terms of use, specific notices and consent preferences.
2. Who we are
We are WPP Marketing, a platform that provides WhatsApp automation solutions for e‑commerce, including cart recovery, payment reminders, order notifications, campaigns, customer segmentation, inbox, reports, APIs and integrations with third‑party systems.
IN2, LLC
7345 W Sand Lake RD,
STE 210 Office 4761
Orlando, FL 32819 US
You can contact us by email at support@wppmarketing.com. For data protection matters, please use the contacts listed in the “Contact and Data Protection Officer” section.
3. Roles in WPP Marketing
WPP Marketing may act in different roles depending on the context of processing.
3.1. WPP Marketing as controller
WPP Marketing acts as the data controller when it determines the purposes and means of processing, for example in activities such as direct marketing, sales, commercial service, support, billing, customer relationship management, website security, administrative management, compliance with legal obligations, and analysis of the usage of our channels.
3.2. WPP Marketing as operator or processor
WPP Marketing acts as a processor or service provider when it handles personal data on behalf of a client company that uses the platform to run WhatsApp automations, campaigns, messages, inbox, segmentation, reports, APIs, integrations and communications with end consumers.
In these cases, the client company is generally the data controller of its end consumers. WPP Marketing processes this data according to the client’s contractual instructions and the features configured on the platform.
3.3. Customer responsibilities
WPP Marketing customers must inform their end consumers about the use of the platform, obtain the necessary legal bases or consents, maintain their own privacy policies, configure campaign rules lawfully, and respond to data subject requests when they are the data controllers.
4. Processed data
The data processed varies depending on platform usage, the channels used, the client's settings, and applicable law.
4.1. Identification and contact details
- First name, last name, email, phone, WhatsApp, tax ID when required, and professional contact details.
- Company, position, industry, business address, country, language and information required for commercial support.
4.2. Account, contract and billing data
- Registration data, credentials, user permissions, access logs, subscribed plan, support history and contractual information.
- Payment data, billing, invoices, refunds, fraud prevention and compliance with tax and accounting obligations.
4.3. End-customer data processed on the platform
- End-customer data submitted or imported by client companies, such as name, email, phone number, identifiers, conversations, messages, purchases, carts, orders, payments, preferences, support history and interactions.
- Data coming from integrations with WhatsApp, e‑commerce, CRM, ERP, APIs, widgets, spreadsheets, documents, imports and communication channels configured by the customer.
4.4. Technical data, navigation and device
- IP address, device identifiers, browser, operating system, pages visited, traffic source, usage events, security logs and cookies.
- Approximate or precise geolocation when enabled by the user, the customer, or required for a specific feature based on applicable legal grounds.
4.5. Sensitive data
WPP Marketing does not generally request sensitive personal data. If a customer submits sensitive data on the platform or configures processing that involves such data, they must ensure an appropriate legal basis and instructions compatible with applicable law.
5. Purposes and legal bases
We process personal data for specific purposes and on an appropriate legal basis in accordance with applicable law.
5.1. Marketing and prospecting
We may process data to respond to forms, send communications, display products, segment campaigns, measure ad performance, and provide content related to WPP Marketing.
Possible legal bases: consent, legitimate interest, performance of pre-contractual measures, or equivalent bases under applicable law. Where required, promotional communications will depend on consent or an opt-out mechanism.
5.2. Commercial service and contracting
We process data to respond to inquiries, prepare proposals, execute contracts, grant access to the platform, manage plans, perform billing, collections, refunds, support and customer relationship activities.
Possible legal bases: performance of a contract or pre-contractual measures, legitimate interest, legal obligation and the exercise of regular rights.
5.3. Platform operation for clients
We process end-consumer data to provide features configured by customers, such as registration, customer service, inbox, cart automations, payment and order handling, campaigns, segmentation, reports, communications, APIs and integrations.
When we act as a processor, the legal basis is determined by the data controller client. WPP Marketing processes the data in accordance with the contract, the client’s instructions and applicable security measures.
5.4. Security, fraud prevention and improvement
We may process technical data and logs to protect accounts, detect unauthorized access, prevent abuse, maintain platform integrity, monitor availability, fix issues, improve features, and generate aggregated metrics.
Possible legal bases: legitimate interest, legal obligation, contract performance, protection of rights and, where required, consent.
5.5. Legal and regulatory obligations
We may process and retain data to comply with tax, accounting and regulatory laws, court orders, requests from authorities, audits, the prevention of unlawful acts and the defense in administrative, judicial or arbitral proceedings.
6. Cookies and similar technologies
We use cookies and similar technologies for site functionality, security, preferences, usage analytics, campaign measurement and, where applicable, advertising.
6.1. What are cookies?
Cookies are small files stored in the browser or on the device. They can identify a session, remember preferences, measure interactions, or enable essential features.
6.2. Cookie categories
- Essentials: necessary for the website's functionality, security, session management and proper display.
- Preferences: used to remember the user's language, region and choices.
- Analytics: used to understand navigation, performance and usage of the services.
- Marketing: used for campaign measurement, remarketing and ad personalization, when applicable.
6.3. Examples of cookies
- PHPSESSID: used for session and basic website functionality.
- _ga: used by Google tools for analysis and measurement when enabled.
- _fbp: used by Meta/Facebook tools for measurement and advertising, when enabled.
6.4. Consent and preferences
In regions where the law requires prior consent for non-essential cookies, WPP Marketing will seek to obtain consent before enabling analytics or marketing cookies. You can also manage cookies in your browser, block cookies, or delete existing cookies.
7. Sharing and subprocessors
We may share personal data with vendors, processors, subprocessors and partners when necessary to provide, protect, operate, measure, or improve the services.
7.1. Recipient categories
- Infrastructure providers, hosting, cloud computing, storage, backup and security.
- Communication tools, email, WhatsApp, customer service, CRM, automation, artificial intelligence and support.
- Payment providers, billing, fiscal issuance, accounting and legal.
- Analytics tools, ad measurement, fraud prevention, and availability monitoring.
- Integrations configured by the customer, such as e-commerce, CRM, ERP, spreadsheets, documents, gateways, third-party APIs and messaging providers.
- Public authorities, courts or regulators when required by law or necessary to defend rights.
7.2. End-customer data
When WPP Marketing acts as a processor/operator, disclosures related to end-consumer data follow the controller client's instructions, the platform settings, and the applicable contracts.
7.3. Sale or sharing for behavioral advertising
WPP Marketing does not sell personal data in the usual sense of selling it for money. Some laws, such as California’s CCPA/CPRA, may define “sale” or “sharing” broadly, including certain uses of cookies, pixels, and behavioral advertising. Where applicable, WPP Marketing will provide choice, opt-out, or preference-management mechanisms.
8. International transfers
WPP Marketing may process, store, or transfer personal data to countries other than the one where the data subject is located, including due to cloud infrastructure, support tools, analytics, communications, payments, integrations, and international vendors.
When required by applicable law, we will adopt appropriate mechanisms for international transfers, such as standard contractual clauses, contracts with processors/subprocessors, adequacy decisions, technical and organizational safeguards, or other mechanisms recognized by applicable law.
Customers using the platform to process end-customer data should assess their own obligations regarding international transfer, especially when configuring integrations, imports, exports, automations, APIs, campaigns, or their own subprocessors.
9. Retention and security
9.1. Retention
We will retain personal data for as long as necessary to fulfill the purposes described in this Policy, provide services, honor contracts, meet legal obligations, resolve disputes, protect rights, maintain security, prevent fraud, and comply with tax, accounting, or regulatory requirements.
When we act as the processor/operator, data retention on the platform may depend on the controller customer's settings, the applicable contract, backups, technical logs and legal obligations.
Anonymized or aggregated data that cannot reasonably be used to identify an individual may be retained indefinitely.
9.2. Security
We have implemented technical and organizational measures to protect personal data against unauthorized access, destruction, loss, alteration, disclosure or improper processing. These measures may include access controls, logs, incident management, backups, environment segregation, monitoring, encryption where applicable, and internal security procedures.
No system is absolutely secure. If a security incident occurs that may cause material risk or harm, we will assess notification obligations to data subjects, customers, competent authorities and other affected parties in accordance with applicable law.
10. Data subject rights
Depending on the applicable law and WPP Marketing's role in the processing, you may exercise rights related to your personal data, such as:
- Confirm whether we process your personal data.
- Access the processed personal data.
- Correct incomplete, inaccurate or outdated data.
- Request anonymization, blocking, or deletion of unnecessary, excessive, or improperly processed data.
- Request portability, when applicable.
- Withdraw consent and obtain information about the consequences of refusal.
- Object to certain processing, where applicable.
- Request restriction of processing, where applicable.
- Request information about sharing and recipients.
- File a complaint with the competent authority.
When WPP Marketing acts as the operator/processor on behalf of a client, we may forward your request to the client-controller or assist you in responding, in accordance with the contract and applicable law.
11. Rights by region
11.1. Brazil - LGPD
If the LGPD applies, you may exercise the rights provided for in Law No. 13,709/2018, including confirmation of processing, access, rectification, anonymization, blocking, deletion, portability, information about sharing, information on the consequences of refusing consent, withdrawal of consent, and filing a complaint with the National Data Protection Authority (ANPD).
11.2. European Economic Area and United Kingdom - GDPR and UK GDPR
If the GDPR or UK GDPR applies, you may have the right to access, rectify, erase, restrict, port, object to, withdraw consent for, and lodge a complaint with the competent supervisory authority.
When WPP Marketing is subject to the GDPR or UK GDPR in relation to a specific processing activity, we will inform the applicable legal bases, the recipients or categories of recipients, the retention criteria, any relevant international transfers and the applicable safeguards.
11.3. California - CCPA/CPRA
If California law applies to you and the activity in question, you may have the right to know which categories of personal data we collect, the sources, purposes, categories of third parties, the right to access, correct, delete, limit the use of sensitive personal information, opt out of sale or sharing, and not be discriminated against for exercising these rights.
WPP Marketing does not sell personal data for money. If cookies, pixels, or similar technologies are considered “sharing” or “sale” under applicable law, we will provide appropriate opt-out mechanisms when required.
11.4. Mexico - LFPDPPP
If the Ley Federal de Protección de Datos Personales en Posesión de los Particulares of Mexico (LFPDPPP) applies, you may exercise rights of access, rectification, cancellation and objection regarding the processing of your personal data, as well as revoke consent, limit the use or disclosure of the data, and file a complaint with the competent authority, in accordance with applicable law.
11.5. Colombia - Law 1581 of 2012
If Colombia's Ley 1581 de 2012 applies, you may have the rights to know, update, rectify, request proof of authorization, be informed about data use, revoke authorization, request deletion where appropriate, access your data free of charge, and file a complaint with the competent authority.
11.6. Argentina - Law 25,326
If Argentina's Ley 25.326 applies, you may exercise rights of access, rectification, updating, deletion, confidentiality and legal action for the protection of personal data or habeas data, according to applicable law.
11.7. Chile - Law 19,628
If Chile's Ley 19.628 applies, you may request information about your personal data, its source, recipients and purpose, as well as request modification, cancellation, deletion or blocking when applicable, in accordance with applicable law.
11.8. Uruguay - Law 18.331
If Uruguay's Law 18.331 applies, you may exercise rights of access, rectification, update, inclusion, deletion, challenge of personal assessments, information on data disclosure, and habeas data actions, in accordance with applicable law.
11.9. Other jurisdictions
Users in other regions may have additional rights under local privacy and data protection laws. WPP Marketing will assess requests in accordance with the law applicable to the specific processing.
12. Children and adolescents
WPP Marketing services are not directed at children. We do not knowingly collect personal data from children for our own marketing purposes.
When WPP Marketing customers configure programs, campaigns or registrations involving minors, the data controller customer must ensure an appropriate legal basis, obtain parental or guardian consent when required, and comply with applicable law.
13. Automation, segmentation, and profile
The WPP Marketing platform may enable automations, segmentations, communication journeys, profile-based campaigns, inbox, reports and messages configured by customers from events such as cart, order, payment, shipment, cancellation, repurchase and post-sale.
These features may use transactional data, messages, conversation history, purchase behavior, engagement, preferences, and operational events to generate communications, reports, segmentations, or automated actions.
When WPP Marketing acts as the operator/processor, the client company is responsible for configuring these automations in a manner compliant with applicable law, including providing notice to data subjects, establishing legal bases, offering opt-out mechanisms, and conducting a data protection impact assessment when required.
WPP Marketing may also use aggregated, anonymized, or operational data to improve products, security, support, abuse detection, platform quality, and business intelligence.
14. Contact and data controller
For questions, requests, or to exercise rights related to personal data, please contact us.
Support: support@wppmarketing.com
Data Controller: Josué Felipe Garcia
Data protection officer's email: lgpd@josuegarcia.com.br
When you submit a request, we may ask for additional information to verify your identity, locate the data, identify the applicable controller, and prevent unauthorized access to third-party data.
15. Updates
We may update this Privacy Policy periodically to reflect legal, regulatory, operational, technical, contractual or product changes.
When a change is significant, we may communicate it via the website, platform, email, an account notice, or another appropriate channel. The latest version will be available on this page.