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Legal · LGPD

Privacy Policy

Last updated: · Version 1.1

1. Controller

The controller of your personal data is M2HP TECNOLOGIA LTDA, registered under CNPJ 48.498.639/0001-75, headquartered at Av. Osvaldo Reis, nº 3385, Sala 2004, Ed. Riviera Concept, Praia Brava, Itajaí/SC, Brazil.

2. Data Protection Officer (DPO)

Data Protection Officer (DPO) — LGPD art. 41:

3. Data we collect

Registration:

  • Name and email
  • Password (stored only as a bcrypt hash — we have no access to the plaintext)
  • Preferred language and timezone
  • 2FA configuration when enabled (encrypted TOTP secret)

Service use:

  • Data of the monitors you register (URLs, intervals, settings)
  • Check results (status, response time, observed certificates)
  • Security audit findings and their targets
  • Configured notification channels (webhooks, Telegram tokens, etc.)

Operational:

  • Authentication logs (date, IP, user-agent) — for security auditing
  • Internal audit trail of relevant actions (create/edit/delete resources)

What we do NOT collect: data of who accesses your monitors.

On your public status pages we run the same measurement tools described in section 7. They only collect a visitor’s browsing data after that visitor accepts in the consent banner — without acceptance, no third-party script runs.

Card data: when you switch your payment method to card, the number, holder, expiry and CVV pass through our server only to be forwarded, in the same request, to the payment gateway. They are not written to the database, never reach a log, and do not outlive the request. This flow operates under PCI-DSS SAQ-D scope.

4. Purposes of processing

  • Provide the contracted service (run monitors, generate alerts, run audits)
  • Operational communication (incident notifications, requested reports)
  • Technical support
  • Compliance with legal and tax obligations
  • Fraud and abuse detection (rate limits, anomalous usage patterns)
  • Contract performance (art. 7, V): data needed to provide the contracted Service
  • Compliance with legal obligation (art. 7, II): tax and accounting data
  • Legitimate interest (art. 7, IX): security logs and fraud detection
  • Consent (art. 7, I): marketing communications (always optional; clear opt-out)

6. Sharing

We don’t sell data. We share only with:

  • Strictly necessary processors: hosting provider, transactional email gateway and payment gateway. Each under contract with LGPD clauses
  • Measurement processors — only with your consent (see section 7): Google (Tag Manager, Analytics 4, Ads), Microsoft (Clarity) and Cokei (consent management and record, hosted in Brazil). Without acceptance in the banner, nothing is sent to them. Cokei in turn relies on a VPS provider (hosting), RnoPay (billing for its own subscriptions, no visitor data) and MaxMind GeoLite2 (local geolocation database, no external call at runtime)
  • Public authorities: only upon a valid court order or legal request

When you use integrations involving third parties (Telegram, Slack, PagerDuty, webhooks), the data we send them also becomes subject to each one’s privacy policy.

7. Cookies and tracking

Sentinela uses necessary cookies, always on, and — only with your consent — analytics and marketing cookies. Consent is managed by the Cokei platform, and your choice is stored in a first-party cookie on our own domain.

Before you accept, no third-party script runs: the tags leave our server inert (type="text/plain") and only start running once you accept the matching category. Refusing costs one click, same as accepting, and you can change your mind at any time via Cookie preferences in the footer.

Necessary — always on, no consent required:

  • sentinela_session · Identifies your authenticated session. Without it, you can’t stay logged in. Duration: 2 hours. Legal basis: contract performance (LGPD art. 7, V).
  • XSRF-TOKEN · CSRF token that protects against cross-site attacks. Without it, forms are vulnerable. Duration: 2 hours. Legal basis: legitimate security interest (art. 7, IX).
  • cokei_consent · Stores your category choices, so we don’t ask again on every page and so we can evidence the consent. Holds a consent id, the banner version, the date and the per-category decision. It stays in your browser; it is not sent to our server. Duration: 365 days. Legal basis: compliance with a legal obligation (art. 7, II), together with the duty to evidence consent (art. 8, §2).
  • cokei_sid · Written by the consent platform as soon as the page loads, before any choice of yours. Its value is literally 1, with no identifier, and it exists so the platform doesn’t count the same visitor twice in its own usage metering — it is not required for the site to work. Duration: 30 minutes, renewed on each visit. Legal basis: legitimate interest (art. 7, IX).
  • Language preference (via query string + session) · Remembers whether you chose PT-br, EN or ES.

Record of your consent. When you choose in the banner, the Cokei platform stores, on its own servers: a consent id, a pseudonymized identifier derived from your IP, the country, the per-category decision, the action, the banner version, the language and the date. Plaintext IP and user-agent are not stored. Retention: 3 years. We call it pseudonymized rather than anonymous because the identifier is derived from the IP by a known function — whoever holds the key can, in principle, reverse it.

Analytics — only after you accept. Legal basis: consent (art. 7, I):

  • Microsoft Clarity · Heatmaps and session replay: records clicks, scrolling and navigation path, to show us where the interface gets in the way. Processor: Microsoft.
  • Google Tag Manager · Container that loads Google Analytics 4 (audience measurement). Processor: Google.

Marketing — only after you accept. Legal basis: consent (art. 7, I):

  • Google Ads · Campaign conversion measurement pixels, loaded by Tag Manager. They are released only if you accept marketing — accepting analytics does not release them. Processor: Google.

Where these tools run: Google Tag Manager runs across the whole site — marketing pages, landing pages, sign-in and sign-up screens, the authenticated dashboard, and public status pages. Microsoft Clarity runs on the same surfaces EXCEPT the marketing pages (home, product pages, about, contact, blog and legal). On all of them the banner appears before any collection.

What we do not use:

  • Meta Pixel, Facebook Conversions API
  • Device fingerprinting
  • Selling, renting or trading data with brokers

For web fonts we use fonts.bunny.net, a privacy-friendly alternative to Google Fonts that uses no cookies and doesn’t log IP beyond what’s needed to deliver the file. Since it is indispensable to render the page, it isn’t gated by the banner.

8. Retention

  • Account data: kept while the account is active
  • After cancellation: 30 days of read-only retention for export, then deletion
  • Internal audit logs: retained for up to 12 months for security purposes
  • Tax data (invoices, bills): retained for the legal period (5 years)

9. Data-subject rights (LGPD art. 18)

You may, at any time, request:

  • Confirmation that your data is being processed
  • Access to the data we hold about you
  • Correction of incomplete, inaccurate or outdated data
  • Anonymization, blocking or deletion of unnecessary or excessive data
  • Portability of the data to another provider
  • Deletion of data processed based on your consent
  • Information about whom we share your data with
  • Revocation of consent

To exercise any right, write to dpo@m2hp.com.br. We will respond within 15 days.

10. Security

We adopt reasonable technical and organizational measures:

  • Passwords stored with bcrypt
  • 2FA secret and recovery tokens encrypted at rest
  • Client-server communication always over HTTPS (TLS 1.2+)
  • Security headers (HSTS, CSP, X-Frame-Options, etc.)
  • Optional 2FA TOTP available on all plans
  • Internal audit trail of relevant actions
  • Multi-tenant isolation at the query level (each user only sees their own data)

In the event of a security incident that may pose a relevant risk to data subjects, we will notify the ANPD and the affected subjects per LGPD art. 48.

11. International transfer

Our service is hosted in Brazil, and your account and monitor data stay here.

International transfer happens in two cases: the transactional email provider, and — only if you accept in the cookie banner — the measurement processors in section 7, Google and Microsoft, which receive browsing data on infrastructure in the United States. If you refuse, nothing is transferred to them.

The consent platform (Cokei) is not an international transfer: it is hosted in Brazil, and the record of your choice stays here.

All of them occur under specific contractual clauses or to countries offering an adequate level of protection, per LGPD art. 33.

12. Changes to this policy

We may update this policy. Relevant changes will be communicated by email 30 days in advance. The current version is always available at /legal/privacidade with date and version number.

13. ANPD

If you believe your rights have been violated, you may also contact the National Data Protection Authority — ANPD (gov.br/anpd).