Privacy Policy

1 Data controller

The controller responsible for processing your personal data is:

• Name: WIT (operated by Eclipse Experience LLC)
• Address: Weston, Florida, United States
• Contact email: privacidad@witadvisor.com
• Website: https://witadvisor.com

For any questions related to the processing of your personal data, you may contact us at the email address above.

2 Data we collect

2.1 Data you provide directly

• Registration data: name, email address, phone number, company name.
• Payment data: processed securely through Stripe. WIT does not store credit card data.
• Communications: messages sent through contact forms or WhatsApp.

2.2 Data generated by using the service

• Survey data: NPS, CSAT, CES responses and open comments from your end customers.
• Usage data: pages visited, features used, session times.
• Technical data: IP address, browser type, operating system, device identifiers.
• Review data: Google Business Profile reviews synced with your account.

2.3 Data from your end customers

WIT acts as a data processor with respect to your end customers' data (phone number, survey responses). As a WIT user company, you are the data controller for that data and must have an appropriate legal basis for its collection.

3 Purpose of processing

We use your data for the following purposes:

• Service delivery: creating and managing your account, processing surveys, generating analysis and dashboards.
• AI analysis: WITTY processes your customers' comments to detect patterns, emotions, and generate insights via WITTY IAbot.
• Billing: managing subscriptions and payments through Stripe.
• Service communications: notifications, alerts, weekly summaries, and product updates.
• Technical support: resolving incidents and answering inquiries.
• Service improvement: aggregated and anonymous analysis of platform usage to improve features.
• Legal compliance: responding to requirements from competent authorities when required by law.

4 Legal basis for processing

The processing of your data is based on the following legal grounds:

• Contract performance: processing is necessary to provide the contracted service.
• Legitimate interest: to improve the service, prevent fraud, and ensure security.
• Consent: for sending commercial or marketing communications, where applicable.
• Legal obligation: to comply with applicable legal requirements.

5 Sharing with third parties

WIT shares data only with the following service providers, under strict confidentiality agreements:

Infrastructure and service providers

• Supabase (database and authentication) — USA
• WITTY IAbot (AI analysis) — USA
• Stripe (payment processing) — USA
• N8n (WhatsApp flow automation) — Germany/USA
• Google (Google Business Profile API) — USA
• Meta / WhatsApp Business API (survey delivery) — USA

6 International transfers

Some of our providers are located in the United States. These transfers are carried out with appropriate safeguards under applicable regulations, including Standard Contractual Clauses approved by the European Commission and equivalent protection frameworks.

For users in Brazil (LGPD), international transfers are carried out with the safeguards established in Article 33 of the LGPD.

7 Data retention

We retain your data for as long as necessary to fulfill the purposes described:

• Active account data: while you maintain an active subscription with WIT.
• After cancellation: up to 90 days to allow reactivations and fulfill legal obligations, after which data is deleted or anonymized.
• Billing data: 7 years, in accordance with tax and accounting obligations.
• Backup copies: may persist for up to 30 additional days in backup systems.
• Anonymized data: aggregated and anonymized usage data may be retained indefinitely for statistical analysis.

8 Your rights

Under applicable data protection regulations (GDPR, LGPD, and equivalent local laws), you have the following rights:

• Right of access: to know what personal data we process about you.
• Right of rectification: to request correction of inaccurate or incomplete data.
• Right of erasure: to request deletion of your data ("right to be forgotten").
• Right of portability: to receive your data in a structured, machine-readable format.
• Right to object: to object to processing based on legitimate interest.
• Right to restriction: to request restriction of processing in certain circumstances.
• Right not to be subject to automated decisions: WITTY analyses are support tools; final decisions are always made by a person.

How to exercise your rights

You may exercise any of these rights by sending a request to privacidad@witadvisor.com indicating your identity and the right you wish to exercise. We will respond within a maximum of 30 business days.

Complaints

If you believe that the processing of your data violates applicable regulations, you have the right to file a complaint with the data protection authority in your country.

9 Security

WIT implements appropriate technical and organizational measures to protect your personal data:

• TLS 1.2/1.3 encryption in transit for all communications.
• Encryption at rest for data stored in Supabase.
• Secure authentication with password hashing (bcrypt).
• Role-based access control with the principle of least privilege.
• Automatic and encrypted backups.
• Continuous monitoring of access and suspicious activity.

In the event of a security breach affecting your data, we will notify you within the legally established timeframe (maximum 72 hours for notification to authorities where applicable) and inform you of the measures taken.

10 Cookies

WIT uses cookies and similar technologies for the service to function. You can manage your preferences from your browser settings.

Types of cookies we use

• Strictly necessary cookies: essential for the service to function (authentication, security). No consent required.
• Analytics cookies: help us understand how the platform is used (aggregated and anonymous data). Consent required.
• Preference cookies: remember your user settings. Consent required.

We do not use third-party advertising or tracking cookies for marketing purposes.

11 Minors

WIT is a service directed exclusively at businesses and professionals. We do not intentionally collect data from individuals under 16. If we detect that we have collected data from a minor, we will delete it immediately.

12 Changes to this policy

We may occasionally update this Privacy Policy to reflect changes in the service or applicable regulations. We will notify you of material changes by:

• A prominent notice within the WIT platform.
• Email to the address registered in your account.

The date of the last update will always be visible at the top of this document. Continued use of the service after notification implies acceptance of the changes.