Data Processing Annex

This annex applies when Resto processes personal data on the customer's behalf: the data that enters the apps installed for them and the third-party systems they connect.

In that processing the customer is the controller and COSMOBOTS DESENVOLVIMENTO DE SISTEMAS LTDA is the processor. For the account itself and platform usage, Resto is the controller and the Privacy Policy applies.

• Nature and purpose: hosting and operating the customer's apps and automations, including tasks carried out by the agents.
• Data and subjects: whatever the customer enters or connects, typically their own customers, contacts and staff.
• Duration: for the term of the agreement, plus the retention periods in the Privacy Policy.

The customer decides whether to process sensitive personal data (LGPD art. 5, II) in the apps and systems Resto operates, and answers for the legal basis of that processing (art. 11), for informing the data subjects and for their sector's rules.

Resto applies the same measures of this annex to that data and uses it for no other purpose.

For automated customer service, Resto offers an instruction template that keeps the AI agent to administrative matters, has it introduce itself as an AI and hands any sensitive subject to a person. Adopting it is the customer's decision.

We process the data only on the customer's instructions, which are their use of the platform, their autonomy settings and the tasks they request, and as the law requires.

If an instruction appears to breach the LGPD, we tell the customer before carrying it out.

Everyone at Resto with access to this data is under a duty of confidentiality, holds the minimum access their role needs, and their access is logged.

• A dedicated server and network per organization, isolated from the others.
• Encryption in transit, and credentials encrypted at rest with AES-256-GCM.
• Daily backups, with rehearsed restores.
• Continuous monitoring, self-hosted error tracking and alerts over two channels.
• Version updates for the apps Resto operates.

The sub-processors are those listed in the Privacy Policy. Before adding one we notify the customer; if they object, they may terminate the agreement with no penalty for the remaining term.

We require each sub-processor to take on protection obligations equivalent to this annex.

We help the customer answer data-subject requests, with the export and deletion tools and with whatever information we hold. If a request reaches us directly, we forward it to the customer.

We also help the customer with any ANPD demand related to this processing.

We notify the customer of any security incident involving this data without undue delay, within 48 hours of confirming it, with what we know at that point, and we support notification to the authority and to data subjects where it is due.

At the end of the agreement we hand over an export and delete what we hold within 30 days, except what the law requires us to keep. Backups expire on their own cycles.

We give the customer the documentation and answers needed to show compliance with this annex. An on-site audit is possible with reasonable notice, without exposing other customers' data or environments.