This Privacy Policy has been structured to comply with the Brazilian General Data Protection Law (LGPD), the European Union General Data Protection Regulation (GDPR), the UK GDPR, and, where applicable, privacy laws from other jurisdictions such as the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Federal Law on Protection of Personal Data Held by Private Parties of Mexico (LFPDPPP), Colombia's Law 1581 of 2012, Argentina's Law 25.326, Chile's Law 19.628, and Uruguay's Law 18.331.
The concrete application of each legislation depends on factors such as the resident's location, collection site, purpose of processing, WPP Marketing's role in the operation, and contractual relationship with our clients.
1. Overview
This Policy explains how WPP Marketing processes personal data on its website, platform, applications, APIs, integrations, forms, contact channels, commercial activities, marketing communications, and related services for automation of WhatsApp, e-commerce, campaigns, customer service, sales, and reports.
Personal data are information that identify or can identify a natural person, directly or indirectly. Depending on applicable law, they may also include online identifiers, browsing data, device information, geolocation, and inferences related to 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 with the contracts, terms of use, specific notices, and consent preferences applicable.
2. Who we are
We are WPP Marketing, a platform that offers solutions for WhatsApp automation in 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 via email at support@wppmarketing.com. For data protection issues, use the contacts listed in the "Contact and Data Protection Officer" section.
3. Roles of WPP Marketing
WPP Marketing may act in different roles depending on the context of processing.
3.1. WPP Marketing as Data Controller
WPP Marketing acts as a controller when determining the purposes and means of processing, for example in activities such as proprietary marketing, sales, customer service, support, collection, customer relationship management, website security, administrative management, compliance with legal obligations, and analysis of our channel use.
3.2. WPP Marketing as Operator or Processor
WPP Marketing acts as an operator, processor, or service provider when handling personal data on behalf of a client company that uses the platform to operate 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 their end consumers' data. WPP Marketing processes this data according to the client's contractual instructions and the resources configured in the platform.
3.3. Client responsibilities
WPP Marketing clients must inform their end consumers about the use of the platform, obtain necessary legal bases or consents, maintain their own privacy policies, legally configure campaign rules, and respond to data subject requests when they are data controllers.
4. Processed data
The data processed varies depending on the use of the platform, the channels used, the client's configurations, and applicable legislation.
4.1. Identification and contact data
- Name, surname, email, phone, WhatsApp, fiscal document when necessary, and professional contact data.
- Company, position, segment, commercial address, country, language, and information necessary for commercial service.
4.2. Account, contract, and billing data
- Registration data, credentials, user permissions, access logs, contracted plan, support history, and contractual information.
- Payment data, billing, invoices, refunds, fraud prevention, and compliance with fiscal and accounting obligations.
4.3. End consumer data processed on the platform
- End consumer data sent or imported by client companies, such as name, email, phone, identifiers, conversations, messages, purchases, carts, orders, payments, preferences, service history, and interactions.
- Data from integrations with WhatsApp, e-commerce, CRM, ERP, APIs, widgets, spreadsheets, documents, imports, and communication channels configured by the client.
4.4. Technical, browsing, and device data
- IP address, device identifiers, browser, operating system, accessed pages, traffic source, usage events, security logs, and cookies.
- Approximate or precise geolocation when enabled by the user, client, or necessary for a specific feature with applicable legal basis.
4.5. Sensitive data
WPP Marketing generally does not request sensitive personal data. If a client enters sensitive data into the platform or configures processing involving such data, they must ensure an appropriate legal basis and instructions compliant with applicable legislation.
5. Purposes and legal bases
We process personal data for specific purposes and based on appropriate legal grounds according to applicable legislation.
5.1. Marketing and prospecting
We may process data to respond to forms, send communications, present products, segment campaigns, measure ad performance, and offer content related to WPP Marketing.
Possible legal bases: consent, legitimate interest, execution of pre-contractual measures, or equivalent bases according to applicable jurisdiction. Promotional communications will depend on consent or an opt-out mechanism when required.
5.2. Commercial service and contracting
We process data to respond to interested parties, prepare proposals, sign contracts, grant access to the platform, manage plans, bill, collect, refund, support, and maintain client relationships.
Possible legal bases: contract execution or pre-contractual measures, legitimate interest, legal obligation, and proper exercise of rights.
5.3. Platform operation for clients
We process end consumer data to enable features configured by clients, such as registration, customer service, inbox, cart automations, payments, orders, campaigns, segmentation, reports, communications, APIs, and integrations.
When acting as operator/processor, the legal basis is defined by the controlling client. WPP Marketing processes data according to the contract, client 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 failures, enhance features, and generate aggregated metrics.
Possible legal bases: legitimate interest, legal obligation, contract execution, rights protection, and when required, consent.
5.5. Legal and regulatory obligations
We may process and retain data to comply with fiscal, accounting, regulatory laws, court orders, authorities' requests, audits, fraud prevention, and defense in administrative, judicial, or arbitration proceedings.
6. Cookies and similar technologies
We use cookies and similar technologies for website operation, security, preferences, usage analysis, campaign measurement, and, when applicable, advertising.
6.1. What are cookies?
Cookies are small files stored in the browser or device. They can identify a session, remember preferences, measure interactions, or enable essential features.
6.2. Categories of cookies
- Essential: necessary for proper functioning, security, session management, and correct display of the website.
- Preferences: used to remember language, region, and user choices.
- Analytics: used to understand browsing, performance, and usage of services.
- Marketing: used for campaign measurement, remarketing, and ad personalization when applicable.
6.3. Examples of cookies
- PHPSESSID: used for session management and basic website operation.
- _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 law requires prior consent for non-essential cookies, WPP Marketing will seek consent before activating analytical 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 providers, operators, subprocessors, and partners when necessary to provide, protect, operate, measure, or improve services.
7.1. Categories of recipients
- Infrastructure providers, hosting, cloud computing, storage, backup, and security.
- Communication tools, email, WhatsApp, support, CRM, automation, artificial intelligence, and support.
- Payment providers, billing, tax issuance, accounting, and legal services.
- Analytics tools, ad measurement, fraud prevention, and availability monitoring.
- Customer-configured integrations, 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 for the defense of rights.
7.2. End user data
When WPP Marketing acts as an operator/processor, data sharing related to end consumers follows the instructions of the controlling client, platform settings, and applicable contracts.
7.3. Sale or sharing for behavioral advertising
WPP Marketing does not sell personal data in the common sense of selling for money. Some laws, such as California's CCPA/CPRA, may broadly define "sale" or "sharing," including certain uses of cookies, pixels, and behavioral advertising. When applicable, WPP Marketing will provide mechanisms for opting out or managing preferences.
8. International transfers
The WPP Marketing may process, store, or transfer personal data to countries different from where the data subject is located, including due to cloud infrastructure, support tools, analytics, communication, payments, integrations, and international providers.
When required by applicable legislation, we will adopt appropriate mechanisms for international transfers, such as standard contractual clauses, contracts with operators/sub-processors, adequacy decisions, technical and organizational safeguards, or other mechanisms recognized by applicable law.
Clients using the platform to process end-consumer 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 outlined in this Policy, provide services, fulfill contracts, comply with legal obligations, resolve disputes, preserve rights, maintain security, prevent fraud, and meet fiscal, accounting, or regulatory requirements.
When acting as a processor/operator, data retention on the platform may depend on the settings of the data controller, the applicable contract, backups, technical logs, and legal obligations.
Anonymized or aggregated data, without a reasonable possibility of identifying a person, may be kept for an indefinite period.
9.2. Security
We adopt technical and organizational measures aimed at protecting personal data against unauthorized access, destruction, loss, alteration, communication, or improper processing. These measures may include access controls, logs, incident management, backups, environment segregation, monitoring, encryption when applicable, and internal security processes.
No system is absolutely secure. Should a security incident occur that could pose a risk or cause significant harm, we will evaluate communication obligations to data subjects, clients, competent authorities, and other affected parties according to applicable legislation.
10. Data subject rights
Depending on the applicable legislation and the role of WPP Marketing in processing, you may exercise rights related to your personal data, such as:
- Confirm whether we process your personal data.
- Access the personal data processed.
- Correct incomplete, inaccurate, or outdated data.
- Request anonymization, blocking, or deletion of unnecessary, excessive, or non-compliant data.
- Request data portability, when applicable.
- Revoke consent and obtain information about the consequences of denial.
- Object to certain processing, when applicable.
- Request restriction of processing, when applicable.
- Request information about sharing and recipients.
- File a complaint with the competent authority.
When WPP Marketing acts as a controller/processer on behalf of a client, we may direct your request to the controlling client or assist them in the response, according to the contract and applicable law.
11. Rights by region
11.1. Brazil - LGPD
If LGPD applies, you may exercise rights provided by Law 13.709/2018, including confirmation of processing, access, correction, anonymization, blocking, deletion, portability, information about sharing, information about consequences of denying consent, revocation of consent, and petitioning the National Data Protection Authority (ANPD).
11.2. European Economic Area and United Kingdom - GDPR and UK GDPR
If GDPR or UK GDPR applies, you may have rights of access, rectification, deletion, restriction, portability, objection, withdrawal of consent, and complaint to the competent supervisory authority.
When WPP Marketing is subject to GDPR or UK GDPR regarding specific processing, we will provide the applicable legal bases, recipients or categories of recipients, retention criteria, relevant international transfers, and 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, 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 opposition to the processing of your personal data, as well as revoke consent, limit use or disclosure of data, and submit complaints to the competent authority in accordance with applicable law.
11.5. Colombia - Ley 1581 de 2012
If Ley 1581 de 2012 of Colombia applies, you may have rights to access, 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 complaints with the competent authority.
11.6. Argentina - Ley 25.326
If Ley 25.326 of Argentina applies, you may exercise rights of access, rectification, update, deletion, confidentiality, and data protection actions or habeas data, in accordance with applicable law.
11.7. Chile - Ley 19.628
If Ley 19.628 of Chile applies, you may request information about your personal data, its origin, recipients, and purpose, as well as request modification, cancellation, deletion, or blocking where appropriate under applicable law.
11.8. Uruguay - Ley 18.331
If Ley 18.331 of Uruguay applies, you may exercise rights of access, rectification, update, inclusion, deletion, challenge of personal valuations, information about data communication, and habeas data actions in accordance with applicable law.
11.9. Other jurisdictions
Users from other regions may have additional rights under local privacy and data protection laws. WPP Marketing will evaluate requests according to the legislation applicable to the specific processing.
12. Children and adolescents
WPP Marketing’s services are not directed at children. We do not intentionally seek to collect personal data from children for our own marketing purposes.
When WPP Marketing clients set up programs, campaigns, or registrations involving minors, the responsible controller must ensure an appropriate legal basis, guardian consent when required, and compliance with applicable law.
13. Automation, segmentation, and profile
The WPP Marketing platform may enable automations, segmentation, communication rules, profile-based campaigns, inbox, reports, and messages configured by clients based on events such as cart, order, payment, shipment, cancellation, re-purchase, and post-sale.
These features may use transactional data, messages, chat history, purchasing behavior, engagement, preferences, and operational events to generate communications, reports, segmentations, or automated actions.
When WPP Marketing acts as a controller/processer, the client company is responsible for configuring these automations in a manner compliant with applicable law, including informing data subjects, legal bases, opt-out, and impact assessments when necessary.
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 protection officer
For questions, requests, or exercising rights related to personal data, contact us.
Support: support@wppmarketing.com
Data Protection Officer: Josué Felipe Garcia
Email of the Data Protection Officer: lgpd@josuegarcia.com.br
By submitting a request, we may ask for additional information to confirm your identity, locate the data, identify the applicable controller, and prevent unauthorized access to data from third parties.
15. Updates
We can update this Privacy Policy periodically to reflect legal, regulatory, operational, technical, contractual, or product changes.
When the change is significant, we may communicate through the website, platform, email, account notification, or another appropriate channel. The most recent version will be available on this page.