Security
Information Security and Data Protection Policy
1. Purpose and scope
This policy defines how Netfy protects the information it processes, including personal data received from e-commerce platforms such as TikTok Shop, Mercado Livre and Shopee. It applies to all Netfy systems, in particular the Netfy Fábrica ERP (product catalog, production, inventory, orders and shipping), to all servers, workstations and cloud accounts used to operate it, and to every person with access to them (partners, employees and contractors).
2. Roles and responsibilities
- Managing Partner / Security Officer and Data Protection Officer (Encarregado under LGPD): Michael Cavalcante Nogueira — michael@netfy.com.br. Approves this policy, grants and revokes access, leads incident response and answers data subject and platform requests.
- Infrastructure operator: maintains servers, network, reverse proxy, backups and updates under the Security Officer's direction.
- All users: follow this policy, protect their credentials and report any suspected incident immediately.
3. Data classification and handling
| Class | Examples | Handling rules |
|---|---|---|
| Public | Product listings, prices, website content | No restriction. |
| Internal | Production plans, costs, stock levels | Only Netfy users; not shared outside. |
| Confidential | API keys, app secrets, OAuth access/refresh tokens, passwords | Encrypted at rest; never sent by e-mail or chat; never written to logs; access limited to the application and the Security Officer. |
| Personal data | Buyer name, shipping address, phone, order details | Used only to fulfil the order and legal obligations; least-privilege access; encrypted in transit; retained only as long as needed (section 11). |
4. Encryption
- All traffic between users, platforms and Netfy systems uses HTTPS (TLS 1.2 or higher), terminated at Netfy's reverse proxy.
- Confidential data (API keys, secrets and tokens) is stored encrypted at rest with authenticated symmetric encryption (Fernet: AES-128-CBC with HMAC-SHA256), in files readable only by the application account (permission 600).
- Encryption keys are stored separately from the encrypted data and are never committed to source code.
5. Access control (least privilege)
- Access is granted only to people who need it for their role, with the minimum privileges required, and is approved by the Security Officer.
- Every user has an individual account; shared accounts are not allowed.
- Administrative access to the Netfy Fábrica admin panel requires authenticated login; platform consoles (TikTok Shop, Mercado Livre, Google, government portals) require multi-factor authentication where available.
- Server administration is done over SSH with key-based authentication only; password login is disabled.
- Access rights are reviewed every three months and removed immediately when a person leaves or no longer needs them.
6. Network security and monitoring
- Application servers run on a private, segregated network without public IP addresses. The only service exposed to the Internet is the reverse proxy on HTTPS (port 443).
- A default-deny firewall at the virtualization host filters all traffic to the application servers, allowing only the specific ports required from authorized internal and office addresses.
- Brute-force protection (fail2ban) bans an address after 5 failed SSH logins within 10 minutes; access and error logs are kept and reviewed when alerts occur.
7. Endpoint and daily security baseline
- Workstations run a supported operating system with automatic updates and active antivirus (Microsoft Defender or equivalent).
- Screen lock after at most 5 minutes of inactivity; strong passwords (at least 12 characters, unique per service) kept in a password manager; multi-factor authentication on e-mail and platform accounts.
- Clean desk: no credentials or personal data on paper or visible screens; printed shipping labels are kept in the work area and destroyed after use.
8. Vulnerability and threat management
- Security updates for server operating systems are installed automatically (unattended upgrades).
- Application dependencies and container images are reviewed and updated at least monthly; critical vulnerabilities are fixed within 7 days of publication.
- Before each production change, a backup is taken and a rollback procedure is prepared.
9. Backup and recovery
Servers are backed up daily at the virtualization layer (snapshot mode, compressed), with one copy on the server's local RAID10 storage and one off-site copy in Netfy's Google Drive account (Google-managed data centers), both with restricted access. Application data is also backed up before every production change. Restore tests are performed at least every six months on an isolated temporary machine; the last test (4 November 2026) restored the production server from the daily backup successfully in 26 minutes.
10. Incident response
- Report: anyone who suspects an incident (unauthorized access, data leak, lost device, leaked credential) reports it immediately to michael@netfy.com.br.
- Contain: revoke or rotate affected credentials and tokens, isolate affected systems.
- Assess: determine what data and which customers or sellers were affected.
- Notify: affected sellers and platform partners (including TikTok Shop) are notified without undue delay and in any case within 24 hours of confirmation; the Brazilian Data Protection Authority (ANPD) and data subjects are notified as required by the LGPD.
- Recover and learn: restore service, record the incident and corrective actions, and update this policy if needed.
11. Personal data protection (LGPD)
- Personal data received from platforms is processed only to provide the service the seller authorized (listing, orders, shipping, after-sales) and to meet legal obligations (e.g., invoices). It is never sold or used for unrelated purposes.
- Production data is stored and processed on Netfy's own server in Imperatriz, Maranhão, Brazil; the only copy outside that server is the encrypted-in-transit daily off-site backup in Netfy's Google Drive account.
- Netfy assists sellers and TikTok Shop with data subject requests (access, correction, deletion, portability) within 15 days.
- When an authorization or contract ends, Netfy deletes the related platform data and tokens within 30 days, except data that must be kept by law (for example, tax records).
12. Review
This policy is reviewed at least once a year or after any significant incident or change, and approved by the Managing Partner.
Approved by: Michael Cavalcante Nogueira — Managing Partner — 4 November 2026