Privacy Policy

Last updated: October 1, 2026


1. Introduction

PayPosts ("we", "us", or "the Company") values the privacy and protection of our users' personal data. This Privacy Policy describes how we collect, use, store, share, and protect your personal data when you use our platform, in accordance with the Brazilian General Data Protection Law (LGPD — Law No. 13,709/2018) and other applicable regulations.

By using the PayPosts platform, available at payposts.paywallo.com.br, you acknowledge that you have read and understood this Privacy Policy.


2. Data Controller Identification

The controller of the personal data processed by the platform is:

Legal NameVirex Tech LLC
Trade NamePayPosts
Company registration (New Mexico, USA)0008078201
Address412 W 7th St, STE 1164, Clovis, NM 88101, USA
Websitehttps://payposts.paywallo.com.br
Privacy / DPO E-mailcontato@virextech.com.br

The Data Protection Officer (DPO) is responsible for receiving and responding to requests from data subjects and from the National Data Protection Authority (ANPD).


3. What Personal Data We Collect

3.1. Data provided directly by the User

DataPurposeLegal Basis (LGPD)
E-mailAccount creation, authentication, service communicationsContract performance (Art. 7, V)
Password (stored as hash)Account authentication and securityContract performance (Art. 7, V)
Name / Company nameIdentifying the User on the PlatformContract performance (Art. 7, V)
Payment dataBilling processingContract performance (Art. 7, V)

3.2. Data collected automatically

DataPurposeLegal Basis (LGPD)
IP addressSecurity, fraud prevention, audit logsLegitimate interest (Art. 7, IX)
Browsing data (pages visited, clicks, time on site)Improving the Platform and User experienceLegitimate interest (Art. 7, IX)
Device information (browser, operating system)Technical compatibility and supportLegitimate interest (Art. 7, IX)
Session cookies (HttpOnly JWT)Maintaining the authenticated sessionContract performance (Art. 7, V)

3.3. Data obtained from third parties

DataPurposeLegal Basis (LGPD)
TikTok access token (via OAuth)Content publishing authorized by the UserConsent (Art. 7, I) and Contract performance (Art. 7, V)
Instagram professional account data, when the User connects their own account through Instagram Login (see Section 3.4)Publishing, first comment and performance metrics of the User's own accountConsent (Art. 7, I) and Contract performance (Art. 7, V)
Public data from TikTok and Instagram accounts (metrics, posts, engagement)Monitoring and analysis requested by the UserLegitimate interest (Art. 7, IX)

Important note:the data of third-party TikTok and Instagram accounts that the User chooses to monitor (for example, competitors or references) is exclusively publicly available data. Non-public data is only accessed for the User's own Instagram account, after the User connects it and authorizes it on Instagram, as described in Section 3.4. We never access direct messages, private accounts, or passwords.

3.4. Instagram data (Meta Platform)

When the User clicks "Connect Instagram", they are taken to Instagram's official login page (Instagram API with Instagram Login, provided by Meta Platforms, Inc.). PayPosts never sees or stores the Instagram password. After the User authorizes it, Instagram gives PayPosts an access token limited to the permissions below, and only for that professional account (Business or Creator):

PermissionData accessedWhat we use it for
instagram_business_basicAccount ID, username, profile picture, follower and media counts, list of the account's own postsIdentifying which account is connected and showing it in the User's workspace
instagram_business_content_publishMedia and captions created by the User in PayPostsPublishing posts, carousels, reels and stories to the account, when the User publishes or schedules them
instagram_business_manage_commentsComments on the account's own postsPosting the first comment the User wrote for a post (for example, hashtags or a link) right after it is published
instagram_business_manage_insightsMetrics of the account and of its own posts (views, reach, likes, comments, saves, shares, follower changes)Showing the User how their posts perform and suggesting better posting times and formats

4. How We Use Your Data

We use the personal data collected for the following purposes:


5. Sharing Data with Third Parties

PayPosts may share personal data with third parties in the following situations:

5.1. Service providers (data processors)

Third partyPurposeData shared
Apify (scraping infrastructure)Collection of public data from TikTok and InstagramURLs of monitored public profiles (not the User's personal data)
TikTok (via official API / OAuth)Publishing content to the User's accountOAuth token, content to be published
Meta Platforms, Inc. (Instagram API)Publishing content and reading metrics of the User's own Instagram accountAccess token, content to be published, first comment
Hosting / infrastructure providerData storage and processingAll data described in Section 3, encrypted
Payment gatewayBilling processingPayment data

5.2. Other sharing scenarios

5.3. International data transfer

Some of our service providers may be located outside Brazil. In such cases, we ensure that the international transfer of personal data is carried out in accordance with Articles 33 to 36 of the LGPD, adopting the following safeguards:


6. Data Retention

We keep your personal data only for as long as necessary to fulfill the purposes described in this Policy, observing the following criteria:

Data typeRetention periodJustification
Account data (e-mail, name)While the account is active + 6 months after closureContract performance and reactivation
Authentication data (password hash)While the account is activeSecurity
Access logs (IP, timestamps)6 monthsLegal obligation (Brazilian Civil Rights Framework for the Internet, Art. 15)
Payment data / invoices5 years after the transactionTax and fiscal obligation
Anonymized analytics dataIndefiniteService improvement (non-personal data)
OAuth tokens (TikTok, Instagram)Until the User disconnects the account or deletes their PayPosts account, when they are deleted immediatelyContract performance
Instagram metrics and posts of the connected accountWhile the account is connected; deleted together with the PayPosts accountContract performance

After the retention periods, personal data will be deleted or anonymized, unless there is a legal obligation requiring its retention.


7. Your Rights as a Data Subject (Art. 18, LGPD)

In accordance with Article 18 of the LGPD, you have the following rights regarding your personal data:

RightDescription
ConfirmationConfirm whether we process your personal data
AccessAccess the personal data we hold about you
CorrectionRequest correction of incomplete, inaccurate, or outdated data
Anonymization, blocking, or deletionRequest the anonymization, blocking, or deletion of unnecessary or excessive data
PortabilityRequest the portability of your data to another provider
DeletionRequest the deletion of data processed based on your consent
Information about sharingKnow which entities we share your data with
Information about consentBe informed about the possibility of not giving consent and its consequences
Withdrawal of consentWithdraw consent at any time

How to exercise your rights

You can exercise any of these rights in the following ways:

Response time: we will respond to your request within 15 (fifteen) business days, as provided for under the LGPD. If we are unable to meet this deadline, we will explain the reasons.

If you believe the processing of your data violates the LGPD, you have the right to file a complaint with the National Data Protection Authority (ANPD) — https://www.gov.br/anpd.


8. Cookies and Tracking Technologies

8.1. What cookies are

Cookies are small text files stored on your browser when you access the Platform. We use cookies to keep you signed in, improve your experience, and ensure security.

8.2. Types of cookies used

TypePurposeDurationRequired?
Session cookie (HttpOnly JWT)Keeping the User authenticated on the PlatformSession duration (expires when the browser is closed or after a configured time)Yes — essential for operation
Preference cookiesSaving User preferences (language, theme)Up to 1 yearNo
Analytics cookiesAggregated usage metrics for service improvementUp to 1 yearNo

8.3. Managing cookies

Note: we do not use third-party cookies for behavioral advertising or cross-site tracking.


9. Data Security

We adopt technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or improper alteration. Among the measures adopted:

Technical measures:

Organizational measures:

In the event of a security incident that may pose a relevant risk to data subjects, we will notify the ANPD and affected Users within a reasonable time, as required by Art. 48 of the LGPD.


10. Data of Minors

PayPosts is not intended for individuals under 18 years of age. We do not knowingly collect personal data from children or teenagers. If we become aware that data from a minor has been collected, we will proceed with its immediate deletion.


11. Data Protection Officer (DPO)

PayPosts' Data Protection Officer is the point of contact between the Company, data subjects, and the ANPD.

ResponsibleVirex Tech LLC
E-mailcontato@virextech.com.br
Address412 W 7th St, STE 1164, Clovis, NM 88101, USA

The DPO is responsible for:


12. Changes to This Policy

This Privacy Policy may be updated periodically to reflect changes in our practices, Platform features, or legal requirements.

When we make material changes:

Continued use of the Platform after the effective date of the new version constitutes acceptance of the changes.


13. Applicable Law

This Privacy Policy is governed by Brazilian law, in particular:


14. Contact

For questions, requests, or complaints related to this Privacy Policy or the processing of your personal data:


This Privacy Policy is an integral part of PayPosts' Terms of Use. By using the Platform, you acknowledge that you are aware of and agree to the practices described herein.