LGPD — Brazilian Data Protection Law

1. Who is the controller

The controller of the personal data that EtiquetaChef processes for its own purposes — account, billing, support and security — is ETIQUETACHEF DESENVOLVIMENTO DE SOFTWARE CUSTOMIZÁVEL LTDA (CNPJ 69.380.362/0001-51, Rua Pais Leme, 215, Conj. 1713, Pinheiros, São Paulo/SP, CEP 05424-150, Brasil), operator of the EtiquetaChef brand, responsible for processing decisions, technical infrastructure and handling data subject requests. The data of staff and other persons that the Customer registers on the platform (including label location records) is processed on behalf of the Customer, which is the controller; in that case EtiquetaChef acts as processor under the Data Processing Agreement (DPA). General contact: through our contact page.

2. Data Protection Officer (DPO)

The Data Protection Officer (DPO), pursuant to Article 41 of the LGPD, is Jonas R G Filho. The direct DPO channel is our contact page (mention [DPO] in your message). Full details on identity, responsibilities and SLA are on the DPO page.

Learn more about the DPO

3. Legal bases (Article 7 LGPD)

We process personal data only under the legal hypotheses listed in Article 7. The main ones for EtiquetaChef are:

• Contract performance (V): Applied to strictly operational data needed to deliver the service: user and tenant registration, products, labels, prints, billing.
• Legitimate interest (IX): Applied to aggregated product telemetry, fraud prevention and platform security — always with proportionality assessment and respect for data subject rights.
• Consent (I): Applied to non-essential cookies and optional telemetry. The data subject can accept or refuse; refusal does not block service usage.
• Compliance with legal obligation (II): Applied when law, regulation or court order requires the retention or sharing of information.

4. Data categories processed

EtiquetaChef processes the following categories of personal data. We do not process data about restaurants’ end customers; the app is an internal kitchen tool.

5. Data subject rights (Article 18 LGPD)

The LGPD guarantees data subjects the following rights, exercisable at any time:

1. Confirmation of processing: Confirm whether your personal data is being processed.
2. Access to data: Get a copy of your data via the in-app exportUserData callable, in structured format (JSON/ZIP).
3. Correction of data: Correct incomplete, inaccurate or outdated data in-app or by request to the DPO.
4. Anonymization, blocking or deletion: Permanently delete your account via the in-app deleteUserAccount callable — 30-day soft-delete then final removal.
5. Portability: Receive your data in interoperable format (JSON/CSV/ZIP export) for transfer to another provider.
6. Deletion of data processed with consent: Request deletion of data processed under consent (e.g., optional telemetry).
7. Information about sharing: Learn which public and private entities receive your data.
8. Information about the option to refuse consent: Receive clear information about the option to refuse consent and the consequences.
9. Revocation of consent: Revoke consent previously granted, at any time, through an express request.

You can exercise every right directly in the app, under "Account & Privacy" (route /privacy), or through our contact page (mention [DPO] in your message).

6. Subprocessors (Operators — Article 39)

The following operators process personal data on our behalf, under contract and specific instructions. Each is responsible for the security of its own infrastructure.

7. International data transfer (Article 33)

Part of the data is processed on servers outside Brazil — RTDB in us-central1 (United States), as well as operators SendGrid, PostHog, Meta Platforms, Twilio and Stripe, all operating in the United States —, and data may be shared with EtiquetaChef WorldWide, in Italy. These transfers rely on Article 33 of the LGPD: for the European Union, on the ANPD’s recognition of adequacy (Resolution CD/ANPD No. 32/2026); for other destinations, on the standard contractual clauses approved by the ANPD (Resolution CD/ANPD No. 19/2024), mandatory since 23 August 2025, or on another basis of Article 33. Firestore, Storage and Functions remain in southamerica-east1 (Brazil). Asaas processes data in Brazil; Apple, Google Play, Google Places and Vertex AI may process data in the United States and other countries.

8. Data retention

We apply the following retention windows:

• User account deleted by the data subject: 30-day soft-delete before final erasure. The subject can revert the deletion during this window.
• Tenant (establishment) marked as deleted: 90 days in DELETED state before physical removal, to honor residual tax and contract obligations.
• Labels (operational history): up to 12 months after the label expires; after that the record is deleted automatically.
• Audit logs: up to 12 months, unless a longer legal retention duty applies.
• Backups: 30-day cycle; deleted data is purged from subsequent backups.

9. How to exercise your rights

The preferred channel is the "Account & Privacy" section in the app (route /privacy), with self-service export and deletion. Alternatively, use our contact page (mention [DPO] in your message).

Response time: up to 15 (fifteen) calendar days from the date of the request, in accordance with Article 19(II) of the LGPD. If the request cannot be fulfilled within that period, we will inform you within it of the reasons and next steps (Article 18, §4).

10. Brazilian Data Protection Authority (ANPD)

If you believe your rights were not honored, you can file a complaint with the Brazilian Data Protection Authority (ANPD) through the official channel at www.gov.br/anpd. ANPD is the body in charge of overseeing LGPD compliance in Brazil.