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Tony Belleza Bússola

Last updated: October 28, 2026

Legal

Data Processing Addendum

Effective date: October 28, 2026

This Addendum explains how Bússola processes personal information on behalf of the companies that subscribe to it, and the commitments we make to protect that information.

1. Scope and parties

This Data Processing Addendum ("Addendum") is part of the Terms of Service between Tony Belleza Consulting, which operates Bússola ("Bússola", "we", "us"), and the company that subscribes to the Service ("Customer", "you"). It applies automatically whenever we process Customer Personal Data in providing the Service, with no separate signature needed. Capitalized terms not defined here have the meaning given in the Terms.

2. Definitions

  • Customer Personal Data: personal information within Customer Data that we process on the Customer's behalf, such as information about Candidates, new hires and Users.
  • Data Protection Laws: the privacy and data protection laws that apply to the processing, which may include US state privacy laws such as the California Consumer Privacy Act as amended by the CPRA, and Brazil's Lei Geral de Proteção de Dados (LGPD).
  • Data Subject: the person the personal information is about.
  • Personal Data Breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Customer Personal Data.
  • Subprocessor: a third party we engage to process Customer Personal Data.

3. Roles of the parties

The Customer is the controller (a "business" under California law and a "controlador" under the LGPD) of Customer Personal Data. Bússola is the processor (a "service provider" under California law and an "operador" under the LGPD) and processes Customer Personal Data only on the Customer's behalf. Each party will comply with the Data Protection Laws that apply to it. The Customer is responsible for having a lawful basis and any notices and consents required to collect Customer Personal Data and to have us process it, including for recorded AI screening calls and text messages.

As a service provider, we will not sell or share Customer Personal Data, will not retain, use or disclose it for any purpose other than providing the Service, and will not combine it with personal information we receive from other sources, except as permitted by Data Protection Laws.

4. Details of the processing

Subject matterProviding the Bússola recruiting and onboarding platform to the Customer.
DurationThe term of the Customer's subscription, plus the export and deletion periods in section 11.
NatureCollection, storage, organization, analysis with AI tools, transmission (calls, text messages and email), display, export, anonymization and deletion.
PurposeReceiving and reviewing job applications, running assessments and AI phone screening, scheduling interviews, sending messages, onboarding new hires and supporting the Customer's account.
Categories of personal dataContact details; application, work history and availability; resumes; assessment answers and results; call recordings, transcripts, extracted facts, summaries and scores; scheduling and messages; onboarding details, tax and employment eligibility forms, identity documents, bank details for wages and electronic signatures; User account details; access logs.
Sensitive dataSocial Security or taxpayer numbers, immigration and identity document numbers, dates of birth and bank details collected during onboarding. The Customer should not use the Service to collect other sensitive data, such as health information, unless the law requires it for the job.
Categories of data subjectsJob applicants (Candidates), new hires and employees in onboarding, and the Customer's Users (managers and administrators).

5. Customer instructions

We process Customer Personal Data only on the Customer's documented instructions. The Terms, this Addendum and the Customer's configuration and use of the Service are the Customer's complete instructions. We will tell the Customer if we believe an instruction violates Data Protection Laws, and we may suspend that processing until the instruction is changed. If the law requires us to process data in another way, we will tell the Customer first unless the law prohibits it.

6. Confidentiality of personnel

We allow access to Customer Personal Data only to personnel and contractors who need it to provide or support the Service and who are bound by confidentiality obligations.

7. Subprocessors

The Customer gives general authorization for us to use Subprocessors. We impose on each Subprocessor data protection obligations that protect Customer Personal Data at least as much as this Addendum, and we remain responsible for their performance. Our current Subprocessors are:

SubprocessorPurposeLocation
Oracle Cloud InfrastructureHosting, storage and backupsUnited States
ElevenLabsVoice AI for screening calls and call recordingsUnited States
TwilioTelephony and SMSUnited States
Google Workspace (Gmail SMTP)Transactional emailUnited States
AnthropicResume analysis, only when the Customer enables itUnited States
StripePayments, when enabledUnited States

We will notify the Customer by email and in the app at least 30 days before adding or replacing a Subprocessor. The Customer may object on reasonable data protection grounds within that period. If we cannot address the objection, the Customer may end the affected subscription and receive a refund of prepaid fees for the unused period.

8. Security measures

We maintain technical and organizational measures appropriate to the risk, including:

  • Encryption at rest for sensitive onboarding fields (such as Social Security and document numbers, dates of birth and bank details) and onboarding files.
  • Encryption in transit using TLS (HTTPS) for all connections to the Service.
  • Access controls per company: each company's data is logically separated, access is role based, and passwords are stored only as secure hashes.
  • Audit log: an access history records which User viewed or changed which record, when, and from which IP address.
  • Backups: 14 daily backups are kept and then expire automatically.
  • Limited staff access: our own access is limited to what is needed to run, secure and support the Service.

We may update these measures over time, provided the overall level of protection does not decrease.

9. Personal data breaches

We will notify the Customer without undue delay, and in any case within 72 hours after becoming aware of a Personal Data Breach affecting its Customer Personal Data. The notice will describe, as far as we know at the time, the nature of the breach, the data and people affected, the likely consequences and the measures taken or proposed, and we will send updates as we learn more. We will take reasonable steps to contain and remedy the breach and will help the Customer meet its own obligations to notify authorities and individuals. Our notice is not an admission of fault.

10. Assistance with requests and compliance

  • The Service lets the Customer access, correct, export, anonymize and delete Candidate and employee data, and mark people as "do not call".
  • If we receive a request directly from a Data Subject about Customer Personal Data, we will forward it to the Customer promptly and will not respond ourselves except to confirm that the request was forwarded, unless the Customer authorizes us or the law requires it.
  • Taking into account the nature of the processing, we will provide reasonable help to the Customer in responding to Data Subject requests, carrying out data protection impact assessments and consulting regulators, where the Customer cannot do so through the Service.

11. Deletion and return of data

During the subscription, the Customer can export and delete its data through the Service. After cancellation, the Customer may export its data for 30 days. We then delete or anonymize Customer Personal Data within 60 days after the account is closed, including asking ElevenLabs to delete call recordings. Backups expire automatically within 14 days after that. We may keep data only where the law requires, and it remains protected by this Addendum while we keep it. If a trial ends without a subscription, the data is kept for 30 days and then deleted or anonymized on the same basis.

12. Audits

We will make available to the Customer the information reasonably necessary to show compliance with this Addendum, such as written answers to security questionnaires. If that information is not enough, the Customer may audit our compliance once a year, on at least 30 days written notice, during business hours, in a way that does not disrupt the Service or expose other customers' data, and under confidentiality obligations. The Customer bears its own audit costs. Additional audits are allowed when required by a regulator or after a Personal Data Breach.

13. International transfers

Customer Personal Data is stored in the United States, and our Subprocessors process it in the United States. When Customer Personal Data is transferred from another country, including Brazil, we protect the transfer with contractual safeguards with our providers, including data protection terms and standard contractual clauses where the provider offers them, and with the measures in this Addendum. The Customer is responsible for any notices to Data Subjects that the law requires about these transfers.

14. Liability and order of precedence

Each party's liability under this Addendum is subject to the limitations and exclusions of liability in the Terms. If this Addendum conflicts with the Terms on the processing of Customer Personal Data, this Addendum prevails. Translations are provided for convenience; if there is a conflict, the English version prevails.

15. Term, changes and contact

This Addendum stays in effect for as long as we process Customer Personal Data. We may update it to reflect changes in law or in the Service, with at least 30 days notice by email and in the app for material changes, and no update will reduce the overall protection of Customer Personal Data.

Privacy contact and LGPD encarregado: Tony Belleza, privacy@tonybelleza.com
Website: https://rh.tonybelleza.com
Mailing address available on request at privacy@tonybelleza.com.

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