Subprocessors and international transfers
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
| Provider | Role | Data | Country | Transfer basis | Status |
|---|---|---|---|---|---|
| Magalu Cloud Ltda. | site hosting | all service data | Brazil | — | in use |
| Cloudflare, Inc. | network edge: TLS, caching and attack protection | connection metadata (IP, host, page address) and, in transit, the content sent through the contact form | United States and others | LGPD art. 33: provider's contractual clauses; adoption of the ANPD standard contractual clauses (ANPD Resolution No. 19/2024) in progress | in use |
| netcup GmbH | e-mail server for the fieli.app domain | e-mail messages sent and received | Germany | art. 33, I: European Union recognized as adequate (ANPD Resolution No. 32 of 01/26/2026) | in use |
| Backblaze, Inc. (B2) | e-mail server backups | encrypted copies of e-mail messages (encrypted before leaving the server) | United States | LGPD art. 33: provider's contractual clauses; adoption of the ANPD standard contractual clauses (ANPD Resolution No. 19/2024) in progress | in use |
| Meta Platforms (WhatsApp) | published support channel | phone number, profile name and messages | determined by Meta | art. 33, II, b: standard contractual clauses, through the WhatsApp Business Data Transfer Addendum | in use |
Fieli Posts
| Provider | Role | Data | Country | Transfer basis | Status |
|---|---|---|---|---|---|
| Magalu Cloud Ltda. | hosting and database | all service data | Brazil | — | being onboarded |
| Cloudflare, Inc. | network edge: TLS, caching and attack protection | connection metadata (IP, host, page address) | United States and others | LGPD art. 33: provider's contractual clauses; adoption of the ANPD standard contractual clauses (ANPD Resolution No. 19/2024) in progress | in use |
| Meta Platforms (WhatsApp Business Platform) | sending and receiving WhatsApp messages through the official API | phone number, profile name and message content | United States and others (Meta infrastructure) | art. 33, II, b: standard contractual clauses, through the WhatsApp Business Data Transfer Addendum | being onboarded |
| Meta Platforms (Facebook e Instagram) | publishing through the official APIs | published content and metrics | United States and others | art. 33, inherent to the channel chosen by the customer | being onboarded |
| Google LLC (YouTube) | publishing through the YouTube Data API | published videos, metadata and metrics | United States and others | art. 33, inherent to the channel chosen by the customer | being onboarded |
| TikTok (ByteDance) | publishing through the Content Posting API | published videos and status | United States and others | art. 33, inherent to the channel chosen by the customer | being onboarded |
| LinkedIn Corporation | publishing through the Community Management API | published posts, comments and metrics | United States and others | art. 33, inherent to the channel chosen by the customer | being onboarded |
| Provedores de IA generativa / Generative AI providers | artificial intelligence models | pseudonymized text only: personal data is replaced before sending | United States | the provider's contractual clauses, with adoption of the ANPD standard clauses in progress | in use |
Fieli Flow
| Provider | Role | Data | Country | Transfer basis | Status |
|---|---|---|---|---|---|
| Magalu Cloud Ltda. | hosting and database | all service data | Brazil | — | in use |
| Cloudflare, Inc. | network edge: TLS, caching and attack protection | connection metadata (IP, host, page address) | United States and others | LGPD art. 33: provider's contractual clauses; adoption of the ANPD standard contractual clauses (ANPD Resolution No. 19/2024) in progress | in use |
| netcup GmbH | e-mail server for the fieli.app domain | e-mail messages sent and received | Germany | art. 33, I: European Union recognized as adequate (ANPD Resolution No. 32/2026) | in use |
| Backblaze, Inc. (B2) | encrypted backups | encrypted database backups | United States | LGPD art. 33: provider's contractual clauses; adoption of the ANPD standard clauses in progress | in use |
| Anthropic, OpenAI, Google (Gemini) | artificial intelligence models | pseudonymized text only: personal data is replaced before sending | United States | the provider's contractual clauses, with adoption of the ANPD standard clauses in progress | in use |
| Meta Platforms (WhatsApp Business Platform) | sending and receiving WhatsApp messages through the official API | phone number, profile name and message content | United States and others (Meta infrastructure) | art. 33, II, b: standard contractual clauses, through the WhatsApp Business Data Transfer Addendum | in use |
Fieli Tickets
| Provider | Role | Data | Country | Transfer basis | Status |
|---|---|---|---|---|---|
| Magalu Cloud Ltda. | hosting, database and attachments | all service data | Brazil | — | being onboarded |
| Cloudflare, Inc. | network edge: TLS, caching and attack protection | connection metadata (IP, host, page address) | United States and others | LGPD art. 33: provider's contractual clauses; adoption of the ANPD standard contractual clauses (ANPD Resolution No. 19/2024) in progress | in use |
| Resend | e-mail delivery | addresses and e-mail content | United States | LGPD art. 33: provider's contractual clauses; adoption of the ANPD standard clauses in progress | in use |
| OpenAI, Anthropic | artificial intelligence models | conversation text, currently without pseudonymization | United States | the provider's contractual clauses, with adoption of the ANPD standard clauses in progress | in use |
| Meta Platforms (WhatsApp Business Platform) | sending and receiving WhatsApp messages through the official API | phone number, profile name and message content | United States and others (Meta infrastructure) | art. 33, II, b: standard contractual clauses, through the WhatsApp Business Data Transfer Addendum | in use |
Fieli Club
| Provider | Role | Data | Country | Transfer basis | Status |
|---|---|---|---|---|---|
| Magalu Cloud Ltda. | hosting and database | all service data | Brazil | — | being onboarded |
| Railway | API hosting | service data | United States | LGPD art. 33: provider's contractual clauses, until the migration to Brazil is complete | being phased out |
| Vercel | web dashboard hosting | service data | United States | LGPD art. 33: provider's contractual clauses, until the migration to Brazil is complete | being phased out |
| Neon | database | service data | United States | LGPD art. 33: provider's contractual clauses, until the migration to Brazil is complete | being phased out |
| Resend | e-mail delivery | service data | United States | LGPD art. 33: provider's contractual clauses, until the migration to Brazil is complete | being phased out |
| Cloudflare R2 | file storage | service data | United States | LGPD art. 33: provider's contractual clauses, until the migration to Brazil is complete | being phased out |
| Google (Firebase) | app notifications, usage statistics and crash reports | device identifiers and usage events, with consent | United States | art. 33, II, b: ANPD standard contractual clauses offered by Google Cloud | in use |
| Meta Platforms (WhatsApp Business Platform) | sending and receiving WhatsApp messages through the official API | phone number, profile name and message content | United States and others (Meta infrastructure) | art. 33, II, b: standard contractual clauses, through the WhatsApp Business Data Transfer Addendum | in 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 LtdaCNPJ 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.