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Tony Belleza Bússola

Last updated: October 28, 2026

Legal

Privacy Policy

Effective date: October 28, 2026

This policy explains what personal information Bússola handles, why, who we share it with and the choices and rights people have, including candidates who receive a screening call from Francisca.

1. Who we are and our role

Bússola is a recruiting and onboarding platform created by Tony Belleza and operated through Tony Belleza Consulting ("Bússola", "we", "us"), at https://rh.tonybelleza.com. It is a multi-tenant service: each subscribing company (a "Customer") has its own separate account and data.

  • Candidate and employee data. When you apply for a job, take an assessment, receive a screening call or complete onboarding with a company that uses Bússola, that company is responsible for your information (the "controller" or "business"). We process it only on the Customer's behalf and under its instructions, as a service provider or processor ("operador" under Brazil's LGPD). If you have questions about how a company uses your data, please contact that company first. We will help it respond. Our obligations to Customers as a processor are set out in our Data Processing Addendum.
  • Customer account and website data. For information about our Customers' account holders and visitors to our own website, Bússola is the controller.

2. Information we handle

Customer accounts

  • Company name, the name, email and phone number of administrators and managers, login credentials (passwords are stored only as secure hashes) and account settings.
  • Plan, usage (such as voice minutes and messages) and billing status. Payment card details are collected directly by Stripe and never reach our servers.

Candidates (on behalf of Customers)

  • Profile and application: name, email, phone number, location, preferred language, work history, availability, the job applied to and answers to application questions.
  • Resume: the file you upload and, if the Customer enables it, an AI analysis of it.
  • Assessments: answers to and results of the DISC profile and the B.A.S.E. methodology tests.
  • Screening calls: call recordings, transcripts, facts extracted from the conversation (such as availability, experience, preferred callback time and whether you agreed to the recording), a summary and score, call status and attempt history.
  • Scheduling and communications: interview times you choose, and emails and text messages sent to you through the Service.
  • Pipeline notes: the stage of your application and notes, tags or evaluations added by the Customer's team.

New hires in onboarding (on behalf of Customers)

  • Personal details such as full legal name, address, date of birth and emergency contact.
  • Tax and employment eligibility forms, such as W-4, W-9, I-9 and CT-W4 (Connecticut), which can include Social Security or taxpayer numbers and immigration document numbers.
  • Photos or scans of identity documents and other documents the employer requests.
  • Payment preferences for wages, such as direct deposit bank details.
  • Electronic signatures on offer letters and documents, with a certificate page that records the time and technical details of the signature.

Technical information

  • Server logs and an access history (audit log) that records which user viewed or changed which record, when, and from which IP address.
  • Small items stored in your browser, described in section 9.

3. AI phone screening calls

If a Customer turns on phone screening for a job, Francisca, an AI voice agent, may call candidates who applied to that job, in English, Spanish or Portuguese.

  • Francisca says at the start that it is an AI assistant, not a person, says that the call is recorded and asks for your consent to continue. You may end the call at any time.
  • When you apply on a job page powered by Bússola, the sentence right above the Apply button tells you that applying lets the company call you about your application at the number you provided, including with automated technology and an AI assistant. We keep the exact text you saw, the date and time and your IP address. Text messages need a separate, optional checkbox. If you applied through another site, such as Indeed, you may first get a short email link to confirm the calls.
  • The call is recorded and transcribed. The recording, transcript, extracted facts and summary are made available to the Customer to review your application.
  • You can ask Francisca, or the company, not to call you again. Your record is then marked "do not call" and no more screening calls are placed.
  • By default, calls are made only Monday to Saturday, between 9:00 and 19:30 in the time zone set by the Customer, with a limited number of attempts. If we miss you, we may leave a short voicemail.
  • The Customer is responsible for having the lawful basis and consent needed to call and text you and for complying with the TCPA and state laws.

4. How we use information

  • To provide the Service to Customers: receiving applications, running assessments and screening calls, scheduling interviews, sending messages and handling onboarding.
  • To create and manage Customer accounts, process payments and send service notices, such as trial reminders.
  • To secure the Service, prevent abuse, keep the access history and troubleshoot problems.
  • To comply with law and respond to lawful requests.
  • To improve the Service using aggregated or de-identified information.

We do not use candidate or employee data for advertising, and we do not use Customer Data to train general purpose AI models.

5. AI and automated decisions

Bússola uses AI to hold screening conversations, extract facts, summarize calls, suggest a score or tier and, when enabled, analyze resumes. These outputs support people at the hiring company. They are not automated hiring decisions: the Customer's team reviews the information and decides. If you believe an AI output about you is wrong, or you need an accommodation to complete a screening or assessment, contact the company you applied to. You may also contact us and we will forward your request.

Human review, alternatives and fairness. Each hiring company shows candidates a short notice about the AI before it is used and publishes a "How we use AI" page. By default, an AI result that goes against a candidate (for example "not qualified" or a low score) closes nothing: it waits for a person at the company to confirm or override it, and that decision is recorded with who made it and when. A company can turn this review off, and the platform warns it about the legal risk. Candidates can ask for a person instead of the AI call, for an accommodation, or for reconsideration of a decision, and none of these requests lowers a score or closes an application. Candidates may also answer an optional, voluntary self-identification form (sex, race or ethnicity, veteran status, disability). Those answers are encrypted, never shown to the people who evaluate the candidate, never sent to the AI and never used in scoring; the company only sees anonymous totals (groups under 5 people are hidden) to support an independent bias audit.

6. Legal bases

Where a law requires a legal basis (for example, Brazil's LGPD), the Customer, as controller, is responsible for choosing the basis for candidate and employee data. In the way the Service is designed to be used, the bases are usually:

  • Steps before a contract and performance of a contract: receiving and reviewing applications, scheduling interviews and preparing the offer and onboarding of a new hire.
  • Legitimate interests: screening applicants for the job they applied to, including the assessments and the screening call, with safeguards such as human review and the right to object.
  • Consent, where required: for recorded AI screening calls and text messages, where the law requires consent. Consent can be withdrawn at any time, for example by asking not to be called.
  • Legal obligation: tax and employment eligibility forms, such as W-4, W-9 and I-9, and records the employer must keep.

For our own Customer account and website data, we rely on performance of our contract with the Customer, our legitimate interests in running, securing and improving the Service, compliance with legal obligations and, where required, consent.

7. Service providers (subprocessors)

We share information with providers that help us run the Service, under contracts that limit their use of it to providing their services to us.

ProviderPurposeData involvedLocation
Oracle Cloud InfrastructureHosting, storage and daily backupsAll data stored in the ServiceUnited States
ElevenLabsVoice AI agent for screening calls and call recordingsCall audio and recordings, transcripts, candidate name, job and call variablesUnited States
TwilioTelephony and SMSPhone numbers, call metadata, text message contentUnited States
Google Workspace (Gmail SMTP)Transactional email, such as confirmations, reminders and noticesName, email address and message contentUnited States
Anthropic (optional)Resume analysis, only when the Customer enables itResume content and related application answersUnited States
Stripe (when enabled)Subscription paymentsBilling contact and payment details (entered directly with Stripe)United States

We will update this list and notify Customers at least 30 days before adding or replacing a subprocessor, as described in our Data Processing Addendum.

8. Other sharing and no sale

  • With the Customer: candidate and employee data is available to the company you applied to or work for, and to the Users it authorizes.
  • Legal reasons: when required by law, to respond to valid legal process, or to protect rights, safety and the Service.
  • Business transfers: in a merger, acquisition or sale of assets, subject to this policy.

We do not sell personal information and do not share it for cross-context behavioral advertising, as those terms are defined in US state privacy laws.

Text messages (SMS): mobile information and SMS opt-in consent will not be shared with third parties or affiliates for marketing or promotional purposes. Text messages are sent only to people who opted in, are about their own application, and can be stopped at any time by replying STOP. Message frequency varies. Message and data rates may apply.

9. Cookies and local storage

We use one cookie, and it is strictly necessary:

  • bussola_gcal: set only while a manager connects Google Calendar. It ties the Google sign in back to the browser that started it, lasts about 10 minutes and is removed when the connection finishes.

Everything else stays in your browser's local storage, not in cookies:

  • your login session (a session token), so you stay signed in;
  • your language preference;
  • your light or dark theme and, on the candidate page, the company or referral link you arrived from.

We do not use analytics, advertising or tracking cookies, our own or from third parties. If that ever changes, we will show a consent banner first and ask before setting any of them.

You can clear cookies and local storage at any time in your browser settings. If you do, you will need to sign in again. Stripe (on its checkout pages) and Google (on its sign in page) may set their own cookies, governed by their own privacy policies.

10. Retention and anonymization

  • Customer Data is kept while the Customer's account is active and as configured by the Customer, unless a longer period is required by law.
  • Candidates. The platform has a retention setting that can automatically anonymize candidate records after a set number of months. It is currently turned off, so candidate records are kept until the Customer deletes or anonymizes them. Customers can anonymize an individual candidate at any time.
  • Onboarding. Each company sets a number of retention days for completed onboarding. After that period, the sensitive onboarding data (such as tax forms, identity documents and bank details) can be purged.
  • Anonymization or deletion removes identifying details (such as name, email, phone and resume) and clears call transcripts, extracted facts and summaries, keeping only statistics that do not identify the person. The Service also asks our voice provider, ElevenLabs, to delete the call recordings.
  • Employers may be legally required to keep some records, such as Form I-9, for a minimum period. The Customer is responsible for setting retention to meet those obligations.
  • AI decision records. Records of AI use in hiring (the notice shown to the candidate, with version and time; AI scores and results; human review decisions; and candidate requests) are kept separately from call transcripts, for a period each company sets, by default 4 years (some rules, such as California's regulations on automated-decision systems, require at least four years). These records do not contain call transcripts or recordings and stay even if the candidate record is anonymized. Voluntary self-identification answers follow the same period. At the end of the period they are deleted automatically.
  • Trials and closed accounts. If a trial ends without a subscription, the data is kept for 30 days so the Customer can reactivate. After cancellation, the Customer can export its data for 30 days. We delete or anonymize Customer Data within 60 days after an account is closed. Backups are kept on a rolling basis for 14 days and then expire. Records we must keep by law are kept only as long as required.

11. Security

  • Each company's data is logically separated from other companies' data.
  • Sensitive onboarding fields (such as Social Security and document numbers, dates of birth and bank details) and onboarding files are encrypted at rest.
  • Connections use HTTPS encryption in transit, and passwords are stored only as secure hashes.
  • Access is role based, and an access history records who viewed or changed records.
  • We keep 14 daily backups that then expire, and we limit access by our own staff to what is needed to run and support the Service.

No system is completely secure. If we learn of a security incident affecting personal information, we will notify the affected Customers without undue delay and within 72 hours, as described in our Data Processing Addendum, and, where required, authorities and individuals.

12. Your rights and choices

Candidates and employees

You may ask to access, correct or delete your information, or to stop receiving calls. Because the company you applied to controls your data, it is best to contact that company directly. You may also write to us and we will forward your request and help the company respond. To stop screening calls, tell Francisca during a call or contact the company.

US state privacy rights

Depending on where you live, and where applicable US state privacy laws apply (for example the California Consumer Privacy Act as amended by the CPRA), you may have the right to know what personal information is collected and how it is used, to access and get a copy of it, to correct it and to delete it. We do not sell or share personal information, as those terms are defined in those laws, and we do not use it for targeted advertising. We will not discriminate against you for exercising your rights. You may use an authorized agent, and we may need to verify your identity before acting on a request. We respond within 45 days, and may extend that once by another 45 days when reasonably necessary, with notice. If we deny your request, you may appeal by replying to our decision. When we hold your information on behalf of a Customer, we will forward your request to that Customer and help it respond.

Brazil (LGPD)

If you are in Brazil, under article 18 of the LGPD you have the right to confirmation that your data is processed, access, correction, anonymization, blocking or deletion of unnecessary or excessive data, portability, information about the entities your data is shared with, information about the option not to consent and its consequences, withdrawal of consent, and review of decisions made solely by automated processing. You may also file a complaint with the ANPD (Autoridade Nacional de Proteção de Dados).

How to make a request

Email privacy@tonybelleza.com, the contact for privacy questions, data requests and our LGPD encarregado. We respond within 45 days, or sooner when the applicable law requires (for example, within the deadlines set by the LGPD for requests from Brazil).

13. International transfers

The Service is hosted in the United States, and all of the subprocessors listed in section 7 process data in the United States. If you use the Service from outside the United States, including from Brazil, your information will be transferred to and stored in the United States. We protect these transfers with contractual safeguards with our providers, including data protection terms and standard contractual clauses where the provider offers them, and with the security measures described in section 11.

14. Children

The Service is not directed to children. Account Users must be at least 18 years old, and candidates must be at least 16. We do not knowingly collect personal information from anyone under 16. If you believe a child has provided information through the Service, contact us at privacy@tonybelleza.com and we will help the Customer delete it.

15. Changes to this policy

We may update this policy. We will change the "last updated" date and, for material changes, notify Customers by email and in the app at least 30 days before the changes take effect. Translations are provided for convenience; if there is a conflict, the English version prevails.

16. Contact

Bússola is operated by Tony Belleza Consulting.
Website: https://rh.tonybelleza.com
Privacy contact and data requests: privacy@tonybelleza.com
Data protection officer for Brazil (LGPD "encarregado"): Tony Belleza, privacy@tonybelleza.com
Support: support@tonybelleza.com
Mailing address available on request at privacy@tonybelleza.com.

17. Waitlist and newsletter

Before public signups open, our website offers a waitlist. Bússola is the controller for this information.

  • What we collect. Your name, work email, company, phone number (optional), how many people you hire per month, your preferred language, whether you asked for product news, and a record of your consent: the notice you saw, the date and time, your IP address and your browser's user agent.
  • Purpose. To confirm your email (we send a confirmation link first), to email you when Bússola opens for signups and, only if you checked the box, to send product news and launch updates. We do not sell this information or share it for others' marketing; emails are sent through the email provider listed in section 7.
  • Unsubscribe anytime. Every email has a one-click unsubscribe link, and you can also reply or write to privacy@tonybelleza.com.
  • Deletion on request. Ask at privacy@tonybelleza.com and we will delete your waitlist record. Otherwise we keep it until the waitlist is no longer needed after launch.

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