Privacy Policy

1. Who is responsible for your data

CheckPOS INC, with offices at 999 Ponce de Leon Blvd, Suite 1110, Coral Gables, FL 33134, United States, is responsible for processing the data described in this policy.

We distinguish two situations:

• If you visit this site or contact us, we process your data as the direct controller.
• If you are a customer of a company that uses NovaSales and you talk to one of its agents, that company is responsible for your data and we act as a technology provider on its behalf. To exercise your rights in that case, you should contact the company you were talking to.

2. What data we process

• From site visitors: basic browsing data (IP address, device and browser type, pages visited) and, if you write to us on WhatsApp, your phone number and the content of that conversation.
• From our customers' end users: the content of conversations held with the agents, the channel identifier (phone number on WhatsApp and SMS, username on Telegram), and the data the person voluntarily provides during the conversation.

We do not deliberately request or process sensitive data. If a person includes it on their own initiative in a conversation, it is subject to this same policy.

3. What we use it for

• To provide the conversational agent service contracted by our customers.
• To keep the record of conversations available to the customer who originated them.
• To produce aggregate performance metrics.
• To comply with legal obligations and respond to requests from competent authorities.

We do not sell personal data. We do not share it with third parties for advertising purposes.

4. Training of artificial intelligence models

We do not use our customers' conversations or those of their end users to train artificial intelligence models, neither our own nor those of third parties.

NovaSales agents run on language models provided by third parties under commercial agreements that exclude the use of transmitted data for training.

5. How long we keep it

We keep the content of conversations for 12 months from the date of each interaction. After that period, it is deleted from our systems.

This period exists so our customers can review the history of their conversations and so we can respond to claims or legal requests.

Regardless of our retention, the operators of each channel (Meta, Telegram, telephone carriers) keep records according to their own policies, over which we have no control.

6. Who we share data with

We work with providers that process data on our behalf:

• Meta Platforms — operation of the WhatsApp Business API channel
• Telegram — operation of the Telegram channel
• Telephone carriers — sending and receiving SMS
• Microsoft Azure — hosting infrastructure
• Language model providers — conversational processing

Each one processes data according to its own terms, which we suggest you review.

7. International transfers

Our infrastructure is hosted in the United States. If you are in Argentina, Brazil or the European Union, your data is transferred outside your country. We have contractual measures in place with our providers so that those transfers have adequate protections.

8. Your rights

Depending on where you are, the applicable regulation gives you rights over your data:

• Argentina (Law 25.326): access, rectification, updating and deletion. The Agency for Access to Public Information is the supervisory authority.
• Brazil (LGPD): confirmation of processing, access, correction, anonymization, portability and deletion.
• California (CCPA/CPRA): to know what data is collected, to request its deletion, and not to be discriminated against for exercising these rights.
• European Union (GDPR): access, rectification, erasure, restriction, portability and objection.

To exercise any of these rights, write to us on WhatsApp from the Contact page. We will ask you to verify your identity before processing the request.

9. Security

We apply reasonable technical and organizational measures to protect data: encryption in transit, access control and infrastructure on Microsoft Azure. No system is completely secure, and we cannot guarantee absolute security.

10. Minors

NovaSales is not directed at people under 18 and we do not deliberately collect data from minors. If we detect that we are processing a minor's data without authorization, we delete it.

11. Changes to this policy

We may update this policy. When we do, we change the effective date in the header. If the change is substantial, we communicate it to our customers through the usual channels.

12. Contact

For any question about this policy or about the processing of your data, write to us on WhatsApp from the Contact page.

CheckPOS INC — 999 Ponce de Leon Blvd, Suite 1110, Coral Gables, FL 33134, United States