Privacy Policy
01 Scope
Scope
This policy covers this website, ffast.com.br; the access log of the FFAST license server; and what Dooper receives or sees in an FFAST customer’s billing check. It does not cover the FFAST product installed on a customer’s infrastructure: there, the customer is the controller of the data the product processes and Dooper has no access to the installation.
02 Controller and data protection officer
Controller and data protection officer
Controller: Dooper Tecnologia Ltda., CNPJ 61.197.217/0001-28, owner of the FFAST brand. Contact: [email protected].
Data protection officer (LGPD, art. 41): Dooper Tecnologia Ltda. itself. Contact: [email protected].
03 What the site collects
What the site collects
Browsing: we use Cloudflare Web Analytics to count visits in aggregate. It uses no cookies and no persistent visitor identifier; to work, Cloudflare receives your IP address and browser data, such as the browser type and the page visited. There is no profiling and no cross-site tracking, which is why there is no cookie banner.
Demo form: only what you type, that is, name, work email, company and message. We do not store it in a database: the message goes through our email provider and stays in our mailbox.
Rate limit: each time the form is sent, the server keeps your IP address (for IPv6, the /64 prefix) in memory only, to limit abuse, and discards it about 10 minutes after the last submission. The server log records neither IP addresses nor form content.
04 Legal basis and purpose
Legal basis and purpose
The form and audience measurement rest on legitimate interest (LGPD, art. 7, IX). For the form, the purpose is to answer the contact you started and carry that conversation forward; for browsing, to know in aggregate which pages are read, without identifying who visits.
We carried out the legitimate interest balancing test (LGPD, art. 10): purpose, necessity, the data subject’s expectations and safeguards. The document is available on request at [email protected].
We do not sell, rent or share this data with third parties for marketing.
05 FFAST license check
FFAST license check
An FFAST installation with an online license contacts our license server every 4 minutes and sends the instance identifier, the installation identifier, and a single-use number. The server records the source IP address in its access log.
Purpose: running the license check and protecting it against abuse and misuse of the license. Legal basis: legitimate interest (LGPD, art. 7, IX). The access log is kept for 30 days and then deleted.
The license server runs on Google Cloud, in the United States, and receives its traffic through Cloudflare.
06 FFAST billing check
FFAST billing check
The FFAST agreement is annual, priced by the contracted seat band and invoiced in 12 equal installments. The customer’s installation records a seat reading at the close of each month; the reading does not change the installment. The renewal band comes from the seat forecast the customer declares; the closing readings feed into sizing the renewal and may be used to point out seats above the band ceiling. Seats pointed out above the ceiling do not bind the renewal band: they only support our proposal.
The customer generates, inside its own installation, a counts file for a reading and decides whether to hand it to Dooper. The file may be sent by e-mail. Dooper is the controller of the copy it receives.
The file holds counts and the reading’s data: the number of seats in the reading, the total of people on the list frozen with it, and the number of people per GitLab role; the reading’s month and day, the source of the number, the top-level group or instance read in GitLab, the band ceiling, and the room left under it; the file’s generation date; and the fields that state the basis of each number. A role with 1 or 2 people is not shown with its number. The file holds no name, e-mail, username, or GitLab identifier of any person.
When the customer contests one month’s reading used to point out seats above the ceiling at renewal, which it may do up to 90 days after the end of the contract year, it can show us, in a meeting, that month’s pseudonymized list: one code per person counted, computed with a secret that stays only in the customer’s installation, with no role or other data per line. The list is not sent to Dooper: we receive no copy by e-mail, by file, or by recording. Dooper cannot tell on its own whom a code belongs to; the customer can, and that is how a contested line is discussed. We therefore treat what we see of the list, and any note we make of it, as personal data of the customer’s developers. If we receive the list without having asked for it, we delete every copy within 5 business days and notify the customer.
A person’s code is the same in every contest. Lists from different months, read together with the counts, can reveal the role behind a code, for as long as a record of them exists.
Purpose: checking the contested reading and resolving the contest. Legal basis: legitimate interest (LGPD, art. 7, IX). We use what we see of the list for nothing else, do not combine it with any other source, and delete any record of it within 30 days from the written notice of the contest’s outcome.
The data subjects of the list are the customer’s developers, and the customer is the controller of the source data. A request about this list can be made to us at [email protected] or to the customer; since only the customer can link a code to a person, we answer with the customer’s help.
07 Processors
Processors
These providers process data on our behalf, each only for the function listed.
| Processor | Purpose | What it receives | Where | How long |
|---|---|---|---|---|
| Cloudflare | DNS, tunnel to the server, abuse protection and Web Analytics; proxy for the FFAST license server | IP address, browser data and pages visited; form content only in transit; for the license check, the installation’s source IP and the identifiers sent, in transit | United States, with a global network | Under Cloudflare’s policy; analytics keeps only aggregate numbers |
| MVO.host | Website server hosting | Site traffic in transit, and the IP address in memory for the rate limit | Brazil | Nothing is written to disk; the IP leaves memory about 10 minutes after the last submission |
| Resend | Sends the form email to our mailbox | Name, email, company and message | Sent through the São Paulo region; account data and logs in the United States | 30 days of email data and logs, under the provider’s policy |
| Apple (iCloud+) | The [email protected] mailbox, where the message is kept | Name, email, company, message and any conversation that follows; the FFAST counts file, when the customer sends it by e-mail | Infrastructure of Apple and of providers it contracts, outside Brazil | Messages: up to 12 months without an active negotiation, then deleted. Counts file: 5 years |
| Google Cloud | Hosting of the FFAST license server | The installation’s source IP and the identifiers sent in the license check | United States | Access log with the IP: 30 days |
08 International transfer
International transfer
Cloudflare, Resend, Apple and Google Cloud process data outside Brazil: Cloudflare, the browsing data, site traffic and license check traffic; Resend, account data and the sending logs of the form, in the United States; Apple, the messages in our mailbox; Google Cloud, the license server’s access log, in the United States. The transfer is necessary to provide the service you use when you visit the site and write to us, and to run the FFAST license.
Of the FFAST billing check, only the counts file may travel through our e-mail, and it identifies no one. The pseudonymized contest list does not travel by e-mail, because it is only shown in a meeting, with no copy.
09 Retention
Retention
Contact messages stay in our mailbox while there is an active negotiation. After 12 months without one, they are deleted. You may ask for deletion earlier.
The IP address used for the rate limit stays in memory and is discarded about 10 minutes after the last submission. At the sending provider, email data and logs are kept for 30 days, under its policy.
The license server’s access log, with the source IP address, is kept for 30 days.
FFAST counts files are kept for 5 years, with the invoice’s tax records. Any record we make of a contest’s pseudonymized list is deleted within 30 days from the written notice of the contest’s outcome. A list received without being requested is deleted within 5 business days.
10 Your rights
Your rights
Brazilian data protection law (LGPD, art. 18) grants data subjects confirmation that processing exists, access, correction, anonymization, blocking or deletion of data that is unnecessary, excessive, or processed in breach of the law, portability, and information on who the data is shared with.
Because processing rests on legitimate interest, which does not require consent, you may object to it where the LGPD is breached (art. 18, § 2). Regardless of that, you may ask for deletion of unnecessary or excessive data (art. 18, IV). As our own policy, going beyond what the law requires, we delete your contact messages at any time on request, without you having to point to a breach, through the same channel: [email protected].
To exercise any of them, write to [email protected]. Confirmation of processing and access in simplified form are answered immediately; the full statement is provided within 15 days of the request (LGPD, art. 19).
You may also file a complaint with Brazil’s National Data Protection Authority (ANPD).