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Subprocessors and international transfers

Version 1.1.0 · Effective

This English version is provided for convenience; the Portuguese version prevails.

This page lists the providers that process personal data so that Fieli can deliver its services, what each one does, where it is located and on what basis data leaves Brazil, when it does. It is also the international transfer transparency document required by article 17, §2, of the Regulation approved by ANPD Resolution No. 19/2024.

Our rule

Our main hosting is in Brazil. Personal data leaves the country only in the situations disclosedon this page: network edge, e-mail, channels chosen by the customer, artificial intelligence providers and providers still being migrated, always with the basis for each transfer.

The products’ main infrastructure is on Magalu Cloud, in Brazil. Some products are migrating there; that is why the “Status” column shows providers in use, being phased out (being replaced) and being onboarded (being added).

How transfers are grounded

International transfers rely on standard contractual clauses approved by the ANPD (LGPD, art. 33, II, “b”) or on a country whose level of protection the ANPD recognizes as adequate, such as the European Union (art. 33, I, and ANPD Resolution No. 32/2026). Where a provider has not yet incorporated the ANPD standard contractual clauses, the table says so and adoption is in progress. When the transfer is inherent to the channel chosen by the customer — publishing on a social network or sending a WhatsApp message — it also follows that platform’s own terms.

fieli.app website

ProviderRoleDataCountryTransfer basisStatus
Magalu Cloud Ltda.site hostingall service dataBrazil—in use
Cloudflare, Inc.network edge: TLS, caching and attack protectionconnection metadata (IP, host, page address) and, in transit, the content sent through the contact formUnited States and othersLGPD art. 33: provider's contractual clauses; adoption of the ANPD standard contractual clauses (ANPD Resolution No. 19/2024) in progressin use
netcup GmbHe-mail server for the fieli.app domaine-mail messages sent and receivedGermanyart. 33, I: European Union recognized as adequate (ANPD Resolution No. 32 of 01/26/2026)in use
Backblaze, Inc. (B2)e-mail server backupsencrypted copies of e-mail messages (encrypted before leaving the server)United StatesLGPD art. 33: provider's contractual clauses; adoption of the ANPD standard contractual clauses (ANPD Resolution No. 19/2024) in progressin use
Meta Platforms (WhatsApp)published support channelphone number, profile name and messagesdetermined by Metaart. 33, II, b: standard contractual clauses, through the WhatsApp Business Data Transfer Addendumin use

Fieli Posts

ProviderRoleDataCountryTransfer basisStatus
Magalu Cloud Ltda.hosting and databaseall service dataBrazil—being onboarded
Cloudflare, Inc.network edge: TLS, caching and attack protectionconnection metadata (IP, host, page address)United States and othersLGPD art. 33: provider's contractual clauses; adoption of the ANPD standard contractual clauses (ANPD Resolution No. 19/2024) in progressin use
Meta Platforms (WhatsApp Business Platform)sending and receiving WhatsApp messages through the official APIphone number, profile name and message contentUnited States and others (Meta infrastructure)art. 33, II, b: standard contractual clauses, through the WhatsApp Business Data Transfer Addendumbeing onboarded
Meta Platforms (Facebook e Instagram)publishing through the official APIspublished content and metricsUnited States and othersart. 33, inherent to the channel chosen by the customerbeing onboarded
Google LLC (YouTube)publishing through the YouTube Data APIpublished videos, metadata and metricsUnited States and othersart. 33, inherent to the channel chosen by the customerbeing onboarded
TikTok (ByteDance)publishing through the Content Posting APIpublished videos and statusUnited States and othersart. 33, inherent to the channel chosen by the customerbeing onboarded
LinkedIn Corporationpublishing through the Community Management APIpublished posts, comments and metricsUnited States and othersart. 33, inherent to the channel chosen by the customerbeing onboarded
Provedores de IA generativa / Generative AI providersartificial intelligence modelspseudonymized text only: personal data is replaced before sendingUnited Statesthe provider's contractual clauses, with adoption of the ANPD standard clauses in progressin use

Fieli Flow

ProviderRoleDataCountryTransfer basisStatus
Magalu Cloud Ltda.hosting and databaseall service dataBrazil—in use
Cloudflare, Inc.network edge: TLS, caching and attack protectionconnection metadata (IP, host, page address)United States and othersLGPD art. 33: provider's contractual clauses; adoption of the ANPD standard contractual clauses (ANPD Resolution No. 19/2024) in progressin use
netcup GmbHe-mail server for the fieli.app domaine-mail messages sent and receivedGermanyart. 33, I: European Union recognized as adequate (ANPD Resolution No. 32/2026)in use
Backblaze, Inc. (B2)encrypted backupsencrypted database backupsUnited StatesLGPD art. 33: provider's contractual clauses; adoption of the ANPD standard clauses in progressin use
Anthropic, OpenAI, Google (Gemini)artificial intelligence modelspseudonymized text only: personal data is replaced before sendingUnited Statesthe provider's contractual clauses, with adoption of the ANPD standard clauses in progressin use
Meta Platforms (WhatsApp Business Platform)sending and receiving WhatsApp messages through the official APIphone number, profile name and message contentUnited States and others (Meta infrastructure)art. 33, II, b: standard contractual clauses, through the WhatsApp Business Data Transfer Addendumin use

Fieli Tickets

ProviderRoleDataCountryTransfer basisStatus
Magalu Cloud Ltda.hosting, database and attachmentsall service dataBrazil—being onboarded
Cloudflare, Inc.network edge: TLS, caching and attack protectionconnection metadata (IP, host, page address)United States and othersLGPD art. 33: provider's contractual clauses; adoption of the ANPD standard contractual clauses (ANPD Resolution No. 19/2024) in progressin use
Resende-mail deliveryaddresses and e-mail contentUnited StatesLGPD art. 33: provider's contractual clauses; adoption of the ANPD standard clauses in progressin use
OpenAI, Anthropicartificial intelligence modelsconversation text, currently without pseudonymizationUnited Statesthe provider's contractual clauses, with adoption of the ANPD standard clauses in progressin use
Meta Platforms (WhatsApp Business Platform)sending and receiving WhatsApp messages through the official APIphone number, profile name and message contentUnited States and others (Meta infrastructure)art. 33, II, b: standard contractual clauses, through the WhatsApp Business Data Transfer Addendumin use

Fieli Club

ProviderRoleDataCountryTransfer basisStatus
Magalu Cloud Ltda.hosting and databaseall service dataBrazil—being onboarded
RailwayAPI hostingservice dataUnited StatesLGPD art. 33: provider's contractual clauses, until the migration to Brazil is completebeing phased out
Vercelweb dashboard hostingservice dataUnited StatesLGPD art. 33: provider's contractual clauses, until the migration to Brazil is completebeing phased out
Neondatabaseservice dataUnited StatesLGPD art. 33: provider's contractual clauses, until the migration to Brazil is completebeing phased out
Resende-mail deliveryservice dataUnited StatesLGPD art. 33: provider's contractual clauses, until the migration to Brazil is completebeing phased out
Cloudflare R2file storageservice dataUnited StatesLGPD art. 33: provider's contractual clauses, until the migration to Brazil is completebeing phased out
Google (Firebase)app notifications, usage statistics and crash reportsdevice identifiers and usage events, with consentUnited Statesart. 33, II, b: ANPD standard contractual clauses offered by Google Cloudin use
Meta Platforms (WhatsApp Business Platform)sending and receiving WhatsApp messages through the official APIphone number, profile name and message contentUnited States and others (Meta infrastructure)art. 33, II, b: standard contractual clauses, through the WhatsApp Business Data Transfer Addendumin use

Information about transfers

Under article 17, §2, of the International Transfer Regulation:

  • Form: transmission over the internet, through an encrypted connection, to the provider listed in each table.
  • Duration: for as long as the provider delivers the service, subject to the retention periods in each policy.
  • Purpose: as stated in each provider’s “Role” column.
  • Destination countries: as stated in the “Country” column.
  • Controller: identified below; when Fieli acts as processor, the controller is the customer that contracted the product.
  • Responsibilities and security measures: providers process data only on our instructions and with security measures equivalent to those described in each product’s policy.
  • Rights and channel: data subjects may exercise their rights under article 18 of the LGPD through the Data Protection Officer and petition Brazil’s National Data Protection Agency (ANPD).

The full text of the applicable contractual clauses can be requested from the Data Protection Officer and will be sent within 15 days (art. 17, §1).

Fieli Tecnologia Ltda
CNPJ 67.265.180/0001-04
Rua Angelita Oliveira de Souza, 111 · Centro · Delmiro Gouveia/AL · CEP 57480-000, Brazil
(82) 99817-4910 · WhatsApp · contato@fieli.app

José Tenório Abs Jr. · dpo@fieli.app
Channel for data subjects and for Brazil's National Data Protection Agency (ANPD).

Changes to this list

New subprocessors are notified to customers 30 days in advance, by e-mail and on this page. The customer may object to the change or terminate the contract at no cost by writing to dpo@fieli.app.