Privacy
This is a translation. The Portuguese version prevails. Política de privacidade (in Portuguese).
Anêmona does not track visitors. There is no advertising cookie, no social media pixel, and nothing that happens on this site is cross-referenced with other sites. This policy describes what is collected here, for what purpose and for how long, and what Anêmona guarantees when it processes data on behalf of clients.
Identification and scope
This policy is published by ANEMONA SERVICOS EM TECNOLOGIA DA INFORMACAO LTDA, registered under CNPJ No. 45.897.364/0001-54, headquartered in São Paulo, SP, referred to here as Anêmona. The company qualifies as a small-scale processing agent under ANPD Resolution CD/ANPD No. 2/2022.
It describes three situations, and Anêmona's role is different in each:
- Visitors to this site. Anêmona is the controller and is responsible for the processing described in the following sections.
- Contract contact persons. The professional contact data of the people designated by clients and suppliers is processed by Anêmona as controller, on the basis of legitimate interest (Art. 7, IX), to enter into, perform and account for the contract. It is limited to name, job title, corporate email address and work phone number, and is kept in the contract records for the duration of the relationship and for five years after it ends (Art. 16, I).
- Data subjects whose data is processed in systems built for clients. In this case the client defines the purposes and means of the processing and acts as controller, and Anêmona acts as processor. The privacy notice applicable to the data subject is the client's. What Anêmona guarantees to the client is in the section "Processing on behalf of clients".
This policy does not cover data of Anêmona's own staff.
What is measured
Visits are counted by Cloudflare Web Analytics, with no cookie and no browser fingerprinting. For each visit the following is recorded:
- the page visited
- where the link came from
- the country
- the device type, the browser and the operating system
- the time the page took to load
Anêmona does not use this data to identify visitors, does not cross-reference it with other databases and does not sell it. Even so, the set is treated as personal data, and the legal basis is stated below.
The detail of each visit is retained for 7 days. After that period only a sampled aggregate remains, which does not describe individual visits. The site also generates a technical request log, used to debug defects, retained for at most 7 days and discarded automatically.
Who delivers this site
The site is delivered by Cloudflare. Every request passes through it, and the visitor's IP address is received to deliver the response and to contain abuse. This address is not part of the measurement figures described above. In this delivery Cloudflare acts as processor. For network security and threat prevention it processes data on its own account, as controller, under its own policy.
International transfer
Cloudflare, Google Workspace and Meta, the company responsible for WhatsApp, process data outside Brazil, which constitutes international transfer (Art. 5, XV), permitted in the cases of Art. 33. The instrument applicable to each supplier is set out in the contract signed with it and is provided on request to privacidade@anemona.tech.
In client projects the choice of suppliers belongs to the client, as controller, and the contract of each project records which they are and what supports the transfer.
Correspondence
Anêmona's email is handled on Google Workspace. Messages received are used to reply to the sender and, in commercial matters, to carry the negotiation through to a proposal. The legal basis is legitimate interest (Art. 7, IX) and, when the contract is entered into with the data subject, the performance of preliminary procedures (Art. 7, V). In contact initiated by Anêmona, the address comes from a public source or from a referral, disclosed on request. Messages are not sold or passed on to third parties beyond the provider that hosts the mailbox.
Email messages and WhatsApp conversations are kept, with no fixed period, while there is a negotiation or contract with the person who sent them, and are deleted at that person's request, except where retention is required by law.
Résumés received by email are used for the position they refer to and, at the candidate's request, for future positions.
Contact form
The contact page has a form with four fields: name, email address, phone number and message. The phone number is optional and the form says so; the others are required so that the reply has somewhere to go. Filling in the form is voluntary, and the email address published on the same page serves the same purpose for those who prefer not to use it.
Submitting it produces an email message addressed to Anêmona, with these fields and the indication of the language of the page on which the form was filled in, Portuguese or English, and nothing beyond them. The purpose is to reply to the person who wrote and, in commercial matters, to carry the negotiation through to a proposal. The phone number provided is used for this same purpose, by phone call or on WhatsApp, as described in the section "WhatsApp", and not for marketing. The legal basis is legitimate interest (Art. 7, IX) and, when the contract comes to be entered into with the data subject, the performance of preliminary procedures (Art. 7, V).
The site does not store the message. It is transmitted at the moment of submission and comes to exist in Anêmona's mailbox, handled on Google Workspace, where what the section "Correspondence" describes applies. Delivery is operated by Cloudflare, through Cloudflare Email Sending, as processor, which keeps a record of the delivery for the period set by its policy. Both the delivery and the mailbox take place outside Brazil, as described in the section "International transfer".
Submission is preceded by an automated check intended to tell a person from a program, run by Cloudflare Turnstile as processor, which for this sole purpose processes the IP address and technical characteristics of the browser. Submission is also subject to a frequency limit per IP address, for the purpose of containing abusive use. In neither case is the address stored by Anêmona or used to identify the visitor, and what Cloudflare keeps to operate the check is governed by its policy.
Pages of the site may carry a button that opens a conversation with Anêmona on WhatsApp. The button is a link: the page loads no resource from Meta, the company responsible for WhatsApp, and nothing is transmitted to it before the click. The click opens WhatsApp with an opening message already written, which indicates the page of the site the person came from and can be changed or deleted before sending.
The conversation is opened by the visitor and takes place in Meta's app, outside this site, which stores nothing of it. Anêmona receives the phone number, the profile name and the content of the messages, and uses them to reply and, in commercial matters, to carry the negotiation through to a proposal. The legal basis is legitimate interest (Art. 7, IX) and, when the contract comes to be entered into with the data subject, the performance of preliminary procedures (Art. 7, V). Retention of the conversation follows what the section "Correspondence" describes.
Meta processes the data of the conversation as controller, for its own purposes described in the WhatsApp privacy policy, and processes it outside Brazil, as described in the section "International transfer".
Proposals
Commercial proposals are protected by a password. The password field does not ask for a name, email address or any identifying data.
The IP address of whoever submits the password is processed to contain abuse, immediately and without storage. It appears in the technical request log described above and is discarded with it.
Once the password is accepted, a session cookie lasting eight hours is stored, restricted to the proposal accessed. It is the authentication's own cookie.
Legal bases
Visit counting relies on legitimate interest (Art. 7, IX): knowing the volume, the origin and the performance of access is necessary to maintain the site and fix what fails. Only the data necessary for this purpose is processed (Art. 10, §1), with no profiling and no advertising. A visitor who prefers not to be counted can block the measurement script, without affecting how the site works, and can object in writing through the channel indicated below.
The containment of abuse relies on the same legitimate interest: on the proposal page, in keeping closed a document that belongs to a client; on the contact form, in preventing the channel from being used for automated submissions. The proposal session cookie relies on legitimate interest and, when the data subject is a party to the contract, on the preliminary procedures of Art. 7, V.
No processing on this site relies on consent, and for this reason there is no consent banner. Should a cookie come to exist that is not necessary for the site to work, consent will be requested.
Processing on behalf of clients
Anêmona builds and maintains systems for clients. In them the client is the controller and Anêmona is the processor, processing personal data according to the instructions documented in the data processing annex of each contract. The annex sets out the authorized operations, the categories of data and of data subjects, the authorized subprocessors and the prior notice of ten days for adding new ones, the reference security measures, cooperation in responding to data subjects and the demonstration of compliance on request, at most once every twelve months.
Where client data is kept
Production data resides in accounts and environments owned by the client. When a project does not allow for this arrangement, the contract records where the data resides. At the end of the contract there is nothing to return, and Anêmona's reach ends with the revocation of its access.
During the project there may be a copy of data in an Anêmona development environment, for testing and debugging. These copies are not versioned in a code repository or published, and are deleted within 30 days of the end of the contract, with a written statement of deletion on request. This excludes retention required by law (Art. 16, I) or necessary for the regular exercise of rights in proceedings (Art. 7, VI) and the audit trails of containment actions, whose retention period is set out in the contract.
Inventory of each project
The contract records the categories of data processed, the authorized subprocessors and what happens to the data at the end of the contract. The inventory by repository, indicating which one holds which personal data and for how long, is a project document and is delivered to the client together with the architecture. It is reviewed at every change that affects personal data and at least once every twelve months.
Security incidents
An incident in a client system is reported to the client as soon as it is confirmed and within 2 business days at most. Notifying the ANPD and the data subjects is the controller's responsibility, which has 3 business days from becoming aware of it, under ANPD Resolution CD/ANPD No. 15/2024. Anêmona provides technical support and preserves the available evidence.
An incident affecting data processed by Anêmona as controller is reported by it to the ANPD and to the data subjects, within the same period of 3 business days, where there is relevant risk or harm.
Data protection officer
The data protection channel is privacidade@anemona.tech, intended for requests from data subjects and communications from the ANPD. The designated data protection officer (encarregado) is the partner Yan Nguyen.
As a small-scale processing agent, Anêmona is not required to designate a data protection officer (Art. 11 of ANPD Resolution CD/ANPD No. 2/2022), it being sufficient to maintain a communication channel with the data subject. The designation is voluntary and stands as a good practice and governance policy, under §2 of the same article.
Data subject rights
Art. 18 of the LGPD guarantees the data subject the rights to obtain confirmation that processing exists, access to the data, correction of incomplete, inaccurate or outdated data, anonymization, blocking or deletion of unnecessary data or data processed in breach of the law, portability to another supplier, information about the entities with which data was shared, and objection to processing. There is no profiling by automated means; the existing automated decisions are limited to the password check, the automated check of the contact form and the frequency limits, and can be reviewed on request (Art. 20). The data subject may also petition the ANPD (Art. 18, §1) and turn to consumer protection bodies (Art. 18, §8).
Requests should be sent to privacidade@anemona.tech. When necessary to avoid disclosing data to a third party, additional information may be requested to confirm identity, limited to the minimum and used only for this purpose.
Response times
Receipt of the request is confirmed within 2 business days. Confirmation that processing exists and access to the data are answered within 15 days, under Art. 19, II. Correction, deletion, portability and the other measures of Art. 18 follow the same period, when they depend only on Anêmona. When the measure cannot be taken immediately, or the answer cannot be given within the period, the data subject is told the reason (Art. 18, §4).
A request that depends on a client is forwarded to it within 1 business day, with notice to the data subject, and the response period then runs for the controller. Anêmona carries out the locating, correction or deletion of the record that the controller cannot carry out on its own, within the limits of its technical reach and under the terms of the contract, which provides for a charge for requests that exceed reasonable effort.
ANPD Resolution CD/ANPD No. 2/2022 allows small-scale processing agents twice the period (Art. 14). Anêmona does not make use of this allowance.
Security
Anêmona maintains technical and administrative protection measures compatible with the risk of the data it processes, among them encryption in transit, access control by least privilege and an audit trail of changes in client systems. The measures applicable to each project are set out in the data processing annex of the respective contract, and the details are provided to clients and to supplier assessments on request.
Children and adolescents
This site is not directed at children and adolescents, and Anêmona does not intentionally collect their data (Art. 14 of the LGPD).
Versions
This is version 7, of October 26, 2026. The first version, of August 12, 2026, was not numbered. A change in what this site collects or measures, or in what Anêmona guarantees to clients, is reflected on this page and raises the version. Previous versions can be requested at privacidade@anemona.tech.
Version 7, of October 26, 2026.