This Privacy Policy explains how NRT Servicos Administrativos LTDA, a Brazilian limited liability company enrolled with CNPJ No. 39.828.030/0001-26, with registered office at Avenida Ayrton Senna da Silva, 200, Sala 310, Gleba Fazenda Palhano, Londrina, State of Parana, 86050-460, Brazil, doing business as Nrtly ("Nrtly," "we," "us," or "our"), collects, uses, discloses and protects personal information when you visit nrtly.com (the "Website") or subscribe to our SMS marketing program (the "SMS Program," together the "Services").
This Policy applies to personal information processed by us as a controller. By using the Services you confirm that you have read and understood this Policy. If you do not agree with our practices, please do not use the Services.
SMS data sharing notice. We do not sell, rent or share mobile phone numbers or SMS opt-in data with any third parties for their own marketing purposes. The information you provide when subscribing to the SMS Program is used only to deliver the SMS Program and related transactional communications, and is shared only with the service providers that help us operate the program (such as our SMS gateway providers).
1. Information We Collect
We collect the following categories of personal information:
| Category | Examples |
|---|---|
| Contact information | First name, email address, mobile phone number |
| Consent records | Date, time, IP address and form used when you opt in to the SMS Program |
| SMS engagement data | Delivery status, opens, click-throughs, opt-out events, replies |
| Device and usage data | Browser type, device type, operating system, pages visited, referring URL, approximate location derived from IP |
| Cookies and similar technologies | Session cookies, analytics cookies, preference cookies |
| Correspondence | Messages, support tickets and inquiries you send to us |
2. How We Use Your Information
We use the personal information we collect for the following purposes:
- To deliver the SMS Program and send you marketing, promotional and transactional messages that you have opted in to receive;
- To verify your identity and your authority to subscribe the mobile number you submitted;
- To respond to your inquiries and provide customer support;
- To operate, maintain and improve the Website and Services;
- To measure the performance of our SMS campaigns and audience segments;
- To comply with legal obligations and enforce our Terms and Conditions;
- To detect, investigate and prevent fraud, abuse and security incidents.
3. Legal Bases for Processing
Where applicable law requires a legal basis to process personal information, we rely on:
- Consent — when you opt in to receive SMS messages or other marketing communications;
- Performance of a contract — to provide the Services you have requested;
- Legitimate interests — to operate our business, prevent fraud and improve the Services, provided those interests are not overridden by your rights;
- Legal obligation — when we are required to retain or disclose information by law.
4. How We Share Your Information
We share personal information only as described below. We do not sell your personal information, and we do not share your mobile phone number or SMS opt-in data with any third parties for their own marketing purposes.
- Service providers. Vetted vendors who help us run the Services — for example, SMS gateway and short-code providers, email delivery providers, hosting providers, analytics providers and customer support tools. These providers may only use your information to perform services on our behalf.
- Legal and safety. Government authorities, law enforcement or other parties when we are required to do so by law or where we believe in good faith that disclosure is necessary to comply with legal process, protect our rights or the safety of others.
- Corporate transactions. In connection with a merger, acquisition, financing, reorganization or sale of all or part of our business, your information may be transferred to the relevant counterparty, subject to confidentiality.
5. International Data Transfers
Nrtly is headquartered in Brazil and the Services are operated from Brazil and the United States. If you are located in another country, please be aware that your information may be transferred to, stored and processed in countries that may have data protection laws different from those of your jurisdiction. When required by law, we put appropriate safeguards in place for such transfers (such as Standard Contractual Clauses or equivalent mechanisms).
6. Data Retention
We retain personal information only for as long as needed to fulfill the purposes described in this Policy, including to comply with legal, accounting or reporting requirements. SMS consent records are retained for the period required by applicable telecommunications laws. After that period, we delete or anonymize the data.
7. Your Rights and Choices
7.1 SMS opt-out
You can stop receiving SMS messages at any time by replying STOP to any message you receive from us, or by emailing [email protected]. You can also reply HELP for help.
7.2 Access, correction, deletion
Depending on your jurisdiction, you may have the right to access, correct, delete or restrict the processing of your personal information, to object to processing, to request data portability, and to withdraw consent at any time without affecting the lawfulness of processing before withdrawal. To exercise these rights, contact us at [email protected]. We may need to verify your identity before responding.
7.3 California residents (CCPA / CPRA)
If you are a California resident, you have the right to know the categories of personal information we collect, to request access or deletion, to correct inaccurate information, to opt out of the "sale" or "sharing" of personal information, and to be free from discrimination for exercising your rights. We do not sell or share personal information as those terms are defined under the CCPA/CPRA. To submit a request, email [email protected].
7.4 Brazilian residents (LGPD)
If you are located in Brazil, you may exercise the rights granted by the Lei Geral de Protecao de Dados (Federal Law No. 13.709/2018), including confirmation of processing, access, correction, anonymization, blocking or deletion, portability, information about sharing, and revocation of consent. Contact our data protection contact at [email protected].
8. Cookies and Analytics
We use cookies and similar technologies to operate the Website, remember your preferences and analyze traffic. You can configure your browser to refuse cookies or alert you when cookies are being sent; however, some parts of the Website may not function properly without them.
9. Security
We use reasonable administrative, technical and physical safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. No method of transmission over the internet or method of electronic storage is fully secure, however, so we cannot guarantee absolute security.
10. Children's Privacy
The Services are not directed to children under the age of eighteen (18), and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us so we can delete it.
11. Changes to This Policy
We may update this Policy from time to time. The "Last updated" date at the top of this page indicates when this Policy was last revised. We encourage you to review this Policy periodically. Your continued use of the Services after any update constitutes your acceptance of the revised Policy.
12. How to Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us:
NRT Servicos Administrativos LTDA (d/b/a Nrtly)
Avenida Ayrton Senna da Silva, 200, Sala 310
Gleba Fazenda Palhano, Londrina, Parana, 86050-460, Brazil
CNPJ: 39.828.030/0001-26
Privacy & data requests: [email protected]
General contact: [email protected]