This page publicly describes, with no authentication required, the procedure for any data subject to request deletion of personal data processed by Nuvem Corporativa Ltda. within the Xphera platform, including WhatsApp communication data sent through the Platform.
Deletion is one of the rights set forth in article 18, VI of the Brazilian General Data Protection Law (LGPD) and applies to personal data that is unnecessary, excessive or processed in a non-compliant manner, subject to the mandatory retention cases described in our Privacy Policy.
1. Who can request
- Users registered on the Xphera Platform.
- Recipients of transactional WhatsApp messages sent from the Platform.
- Data subjects whose personal data appears in operational records of the Platform (e.g. customers, requesters, employees of a contracting organization).
- Legal representatives or attorneys-in-fact, duly identified, acting on behalf of the data subject.
2. How to request
Submit the request to the DPO channel:
- Email: dpo@xphera.io
- Suggested subject: Data deletion request — LGPD
Include in the message:
- Full name of the data subject.
- Identification document (CPF or equivalent) for identity verification.
- Organization or company, if the data subject is a Platform user acting on behalf of a contracting organization.
- Phone number, if the request involves WhatsApp communication data.
- Contact email for reply.
- Clear description of the request — whether full deletion, partial, or limited to a specific channel (e.g. WhatsApp data only).
3. Response time
Nuvem Corporativa will acknowledge receipt of the request within 5 (five) business days and provide a final response within 15 (fifteen) days, as provided by article 19, §3 of the LGPD. If additional time is needed — for instance, to verify identity or evaluate legal retention grounds — the data subject will be expressly informed of the reason and the new estimated deadline.
4. What is deleted
Once identity is verified and legal requirements are met, the following will be deleted:
- Personal registration data (name, email, phone, role, credentials).
- Identifiable personal records in usage and audit logs that are not indispensable to a legal obligation.
- Content and metadata of WhatsApp communications sent to the indicated phone number, when the request covers this channel.
- Personal data stored in Platform integrations, to the extent it is under Nuvem Corporativa's control.
5. Legal retention cases
In compliance with article 16 of the LGPD, some data may be kept even after a deletion request, exclusively in cases of:
- Legal or regulatory obligation (e.g. tax records during the mandatory period).
- Regular exercise of rights in judicial, administrative or arbitral proceedings.
- Need for prior anonymization for statistical or security purposes, without re-identification.
Where applicable, Nuvem Corporativa will inform the data subject of the legal basis for retention and the period after which full deletion will take effect.
6. Deletion confirmation
Once completed, Nuvem Corporativa will send confirmation to the contact email provided. The confirmation identifies the exact scope of what was deleted and, where applicable, what data remains retained under legal grounds.
7. Alternative channel
If the data subject does not receive a reply or wants to follow up by another means, they can call +55 27 2237-8800 or write to Nuvem Corporativa's physical address: Rua Avencas, 20, Coqueiral, Aracruz/ES, postal code 29199-022, Brazil.
If unsatisfied, the data subject may file a complaint with the Brazilian Data Protection Authority (ANPD).