Privacy

Who processes the data

The controller of the personal data processed by CommsHarbor is WRP Consultoria e Informática Ltda (Brazilian company registry CNPJ 66.300.125/0001-45), at R. Copaíba, Lote 01, Bloco B, Sala 408, Águas Claras, Brasília/DF, CEP 71919-540, Brazil, which also runs the other products listed in the footer. The channel for personal data matters is eu@wendelmaques.com; requests are answered by e-mail.

What this product keeps

• We process verified account details, organization settings, contacts supplied by customers, consent records, templates, recipient addresses, delivery events, suppressions, API and security audit records, and billing references.
• We use data to verify access and deliver requested messages. We check permission and blocking lists before sending. We also use data to prevent abuse, measure reliability, provide support and meet accounting and security obligations.
• Account: e-mail, password, passkeys, sign-in codes and sessions are kept by the account system shared by our products, in its own database — this product keeps only the account id next to what is yours. Without an account, a signed guest token stored in your browser owns what you create; signing in moves it to your account.
• Pay-per-call payments (x402) settle on the Base network, which is public by design. Here we keep the transaction reference and the amount for reconciliation and accounting. From the request that paid, we also keep the IP address, browser, languages, source site, and approximate country and network, for audit and fraud prevention.
• To recover an x402 response after a connection failure, we keep an encrypted copy of the result that the service's recording policy permits. Disabling content recording does not disable financial records or technical receipts. Only the authenticated payer wallet can retrieve the copy. The payment identifier does not grant access to the content.
• Prepaid credit: the balance and transaction records store the token as a SHA-256 hash. The encrypted x402 response copy can contain the token. Whoever holds the token holds the credit; it cannot be recovered by email.
• Contact: the name, email, message, WhatsApp number and audio you choose to send go through our own mail server to the controller's mailbox. The message includes the source page, language and network (IP) address. We use this data to answer your request.
• Audio recording is optional and requires your microphone permission. You can listen and delete it before sending. Audio stays in your browser until submission, then goes as an attachment without transcription. Contact does not subscribe you to marketing lists.
• Email advertising requires separate permission in account preferences. Where available, it accompanies a requested notice, at most once per day. We keep the choice and delivery receipt. The advertiser does not receive your email. Withdraw permission from the account or message link without stopping essential notices.

Sign in with Google

• When you choose Sign in with Google, you allow access to your Google account identifier, verified email and basic profile. The profile can include your name, given name, family name, photo, language and Google Workspace organisation domain.
• We use this data to identify your account, give you access and display your profile. We store the link and profile fields in the account system. Google confirms your identity. We do not receive your Google password.
• Sign-in requests only openid, email and profile. It does not give access to Gmail, Drive, Calendar, contacts or Search Console. Additional integrations request their own permission when you choose to connect them.
• Sign-in tokens are used on the server to check your identity. We do not keep access or refresh tokens from this sign-in to query other Google services.
• We do not sell data received from Google. We do not use it for personalised advertising or to train general artificial intelligence models. Internal access is limited to service operation, authorised support, security and legal obligations.
• We keep the link and profile while needed for your account. Unlinking Google prevents new access through that link. It does not delete your account, the imported profile, product data or required security and billing records.
• You can remove the connection in your Google Account settings at https://myaccount.google.com/connections. To request access, correction or deletion of data we keep, write to eu@wendelmaques.com. Include the product and account email. Do not send a password or token.
• Our use and transfer of information received from Google APIs follow the Google API Services User Data Policy, including its Limited Use requirements where applicable: https://developers.google.com/terms/api-services-user-data-policy.

Optional Google domain import

Google sign-in does not authorize domain import. Connecting Search Console requests webmasters.readonly. Connecting Analytics requests analytics.readonly. We read authorized site names, Analytics account and property names, and website addresses from selected web streams. We do not read reports, Gmail, Drive or Calendar. Access and refresh tokens stay encrypted on the server, scoped to the product, account and Google service. The browser keeps your setup selection; the server saves only domains you confirm. We do not sell this data or use it for advertising or AI training. Disconnect Google in setup to remove this product's saved tokens and pending consent. You can revoke Google's authorization at https://myaccount.google.com/connections. Disconnection preserves domains already registered and does not cancel a subscription. Choosing PageAudit or HookPulse enables native product access and stores a domain association. It does not transfer your Google tokens to those products.

Control and deletion

Organisation owners can export workspace data and schedule its deletion. You have seven days to cancel the request. We then delete personal content and stored files. We retain only required records, with identifiers instead of names. Your global account and organisation remain active.

Sharing Google user data

• These disclosures cover the Google account data and any Google integration data described in this policy. They also cover raw responses, summaries and aggregated or derived data.
• WRP processes this data to provide the features you request. Our hosting and storage providers supply the servers we operate. They process stored data to provide that infrastructure. Authorised operators can access data when needed for service operation, security or support you request.
• Google receives the requests and credentials needed to confirm your identity or read a service you connect. The email provider identified in Infrastructure and third parties receives your email address and message contents to deliver account messages and enabled alerts. The integration sections describe any Google metrics included in alerts.
• For a purchase you request, the payment providers identified in this policy can receive the name and email used for billing, including those imported at sign-in. They do not receive your Google access tokens, refresh tokens or imported performance reports.
• We do not sell Google user data or disclose it to data brokers or advertisers. We do not use it for advertising, credit decisions or AI model training. We do not send Google API responses, imported performance reports or tokens to AI providers.
• We disclose data to authorities only when required by applicable law. We limit such disclosure to what is required. Hosting and email providers can process data outside your country. Their role is to supply the services described here.

Protecting Google user data

• HTTPS encrypts data between your browser and our service, and between our service and Google's APIs. This includes Google sign-in, permission requests and imported reports.
• The server checks your session and permission before it returns private data. Account and product identifiers restrict access to the records you are allowed to use. Private responses are not stored in shared public caches.
• For optional Google integrations, access and refresh tokens are encrypted before storage with AES-256-GCM. The encryption binds each token to its product, account and Google service. Server configuration holds the encryption keys separately from the encrypted records.
• Google tokens stay on the server. They are not included in browser storage, public reports or AI requests. Sign-in sessions use Secure and HttpOnly cookies. State validation, short expiry and single-use callbacks protect the Google authorization flow.
• Stored profile fields and report metrics are protected by server access controls and account checks. You can revoke Google access and request deletion as described in this policy.

Purposes and legal basis

• To create and keep your account, sign you in and protect access: performance of a contract (LGPD, article 7, V).
• To charge, deliver what you bought and keep the tax records: performance of a contract and legal obligation (LGPD, article 7, V and II).
• To answer your contact, at your request: steps before a contract (LGPD, article 7, V).
• To limit abuse, prevent payment fraud and protect the service: legitimate interest (LGPD, article 7, IX).
• To measure usage and improve the product, with no advertising profile: legitimate interest (LGPD, article 7, IX). Global Privacy Control or "Do Not Track" turns this measurement off.
• To send the e-mail alerts you turned on: your consent, which you withdraw by turning the alert off (LGPD, article 7, I).

For how long

• Import and export objects expire after seven days. Raw SES feedback objects expire after thirty days.
• Product data remains while the organization is active. Security audit and pseudonymous billing records may be retained when necessary.
• Account data stays while the account exists. Sign-in codes expire within minutes; the session ends when you sign out or when it expires.
• Per-network rate-limit counters (guest, contact, sign-in code) expire on their own within minutes or hours.
• Payment and credit records stay for the legal retention period of tax and accounting records, usually 5 years.
• The x402 response copy is available for 24 hours after completion. We then delete the content in batches. If the payment is pending, the incomplete copy stays encrypted until reconciliation ends.
• Contact messages stay in the controller's mailbox while the conversation and the business relationship last.
• Visit steps stay up to 35 days on the product server; the copy kept for analysis, without IP or account, stays on our data server.
• Web server records, with date, time and IP address, stay for 6 months under confidentiality, as the Brazilian Internet Civil Rights Framework (Law 12,965/2014, article 15) requires. Then we delete them.

Infrastructure and third parties

• Servers we operate run the service and store the account, payment and usage data in Brazil (Vinhedo, São Paulo state). The copy of visit data kept for analysis, without IP or account, stays on our server in Europe.
• Cloudflare provides only the domain's DNS and receives no account or usage data.
• Amazon Web Services (Amazon SES) sends the account e-mails, such as the sign-in code, the invitation and the alerts you turned on. It receives the recipient e-mail and the message text, in the United States.
• Asaas Gestão Financeira Instituição de Pagamentos S.A. processes payments in Brazilian reais (Pix, boleto and card), in Brazil. It receives the payer's name, CPF or CNPJ and e-mail. In the product's card forms, card and billing details pass through our API to Asaas, with the buyer's postal code, address number, phone and IP address. We do not store the card number or security code.
• Stripe processes card payments from outside Brazil, in US dollars, on Stripe's own page. There you type the e-mail, billing address and card details; from us, Stripe receives only the amount, the product and the charge code. Stripe processes this data in the United States.
• Coinbase Developer Platform (CDP) verifies and settles x402 payments on the Base network, in the United States. It receives the wallet address, amount, signed authorization and paid resource URL. The private key is not sent. The wallet address and transaction are public on the network.
• There is no Google Analytics and no advertising tracker.
• Interface libraries (Bootstrap) are served from the product's own domain, not from a third-party CDN.
• We do not sell personal data or share it for advertising.
• Amazon Web Services (AWS) also sends your organisation's email through Simple Email Service (SES). It reports delivery events through Simple Notification Service (SNS). AWS may process that data where it operates, under its applicable safeguards.
• A mail server we operate receives mail addressed to commsharbor.com.

Cookies and browser storage

• When you sign in, the account session lives in an HttpOnly cookie on this domain; without an account, the guest token stays in your browser and identifies what you created.
• Screen preferences (theme, filters) stay in the browser's local storage and never leave it.
• To improve the path through the product, we measure page views, clicks on controls and purchase steps. We keep a random identifier and the session in your browser. These events contain no typed text, page content, IP, e-mail or account data. Global Privacy Control or "Do Not Track" disables this collection.
• There is no advertising cookie and no cross-site tracking.
• The only cookies are the essential ones: the account cookies and the guest cookie. That is why we do not ask for cookie consent.

IP address

To limit abuse, the IP address goes into a hash with a secret salt. The approximate country and city come from a geolocation database (MaxMind GeoLite2) on our server. This lookup does not send the address to third parties. Card payments send the IP address to Asaas to validate the payment. The raw IP is kept in the record of each payment (Pix, card or x402) and in its notice to the controller, for audit and fraud prevention, for the retention period of payment records. Otherwise, it appears only in the contact e-mail and in the web server records, kept for 6 months under confidentiality.

Your rights

The Brazilian data protection law (LGPD, Law 13,709/2018, article 18) gives you the right to confirm the processing and to access, correct, anonymize, block, delete or move your data to another provider, and to know with whom we share it. Where the GDPR applies, it also applies here. In your account, you download your data and close the account. Closing ends access; data deletion is requested by e-mail. For any request, write to eu@wendelmaques.com. We answer within 15 days. Data from public sources (official registries) stays at the source; only the copy here is removed. You can also complain to the Brazilian data protection authority (ANPD).

Data protection officer

The data protection officer (LGPD, article 41) is the management of WRP Consultoria e Informática Ltda. The contact is eu@wendelmaques.com.