Privacy Policy
Last updated: 09/14/2026
This is an English translation provided for convenience. In case of any discrepancy, the Portuguese version prevails.
This Policy explains how Soluções e Sistemas (trade name), registered under CNPJ 40.144.482/0001-78, headquartered at R. Cabo José Benício, 102, Maternidade, Patos/PB, Brazil, ZIP 58701-384 ("we"), processes personal data on the Sorteio Pro platform ("Platform"), available at sorteio.repsys.com.br, in compliance with the Brazilian General Data Protection Law (Law No. 13,709/2018 – LGPD).
1. Who is the controller
The data controller is Soluções e Sistemas. Data Protection Officer (DPO) contact: Heldon José — alinnequele@gmail.com.
2. What data we collect
2.1 Your Instagram account data (when you log in)
With your authorization, through Meta's official API, we receive:
- account ID, username (@), name and profile picture, account type and number of posts;
- access token, stored encrypted;
- data about your posts: ID, caption, thumbnail, type, date, link and number of comments.
2.2 Comments on the selected posts
When you create a giveaway, we read the comments on the selected post: the commenter's username, text, date and replies. This data belongs to third parties who publicly commented on your post and is used only to run the giveaway you requested.
2.3 Usage and purchase data
- Giveaway history, configured rules and winners;
- Credit orders and balance;
- Technical data: IP address, browser, date and time of access (logs required by the Brazilian Internet Civil Framework – Marco Civil da Internet).
2.4 What we do not collect
We do not collect your Instagram password, direct messages or follower list, and we never post, reply to, hide or delete anything on your account.
3. What we use the data for
| Purpose | Legal basis (LGPD) |
|---|---|
| Authenticate you and maintain your account | Performance of a contract (art. 7, V) |
| List posts and read comments for giveaways | Performance of a contract (art. 7, V) |
| Keep giveaway history and certificates | Legitimate interest (art. 7, IX) |
| Manage credits and purchases | Performance of a contract (art. 7, V) |
| Keep access logs | Legal obligation (art. 7, II; Marco Civil art. 15) |
| Prevent fraud and abuse | Legitimate interest (art. 7, IX) |
4. Sharing
We do not sell or rent data. We share it only with:
- Meta Platforms (Instagram), as the provider of the API used for login and data reading;
- Infrastructure providers (hosting, database, backup, error monitoring), under confidentiality obligations;
- Authorities, when required by law or court order.
A giveaway's public certificate, when you share its link, shows the post, the rules, the number of participants and the username(s) of the winner(s).
5. How long we keep data
| Data | Retention |
|---|---|
| Access token | While the account is connected; deleted when you disconnect, delete your account or revoke access on Instagram |
| Loaded comments | Up to 90 days after the giveaway |
| Giveaway result (rules, number of participants, winners, hash) | While the account exists |
| Credit orders and transactions | 5 years (tax obligations), anonymized after deletion |
| Access logs | 6 months (Marco Civil da Internet) |
6. Your rights
Under art. 18 of the LGPD, you may request: confirmation of and access to your data; correction; anonymization, blocking or deletion; portability; information about sharing; and withdrawal of consent.
How to exercise them:
- Through the Platform: My account → Delete account;
- Through Instagram: Settings → Website permissions → Apps and websites → Remove Sorteio Pro;
- By email: alinnequele@gmail.com. We respond within 15 days.
See also: Data deletion instructions.
Anyone who commented on a giveaway post and wants their comment deleted from our database can write to alinnequele@gmail.com stating their @ handle.
7. Security
We use HTTPS, encryption of access tokens (Fernet/AES-128-CBC), restricted access control, backups and security updates. No system is 100% secure. In the event of a relevant incident, we will notify data subjects and the ANPD (Brazilian Data Protection Authority) as required by law.
8. Cookies
We use only essential cookies (session and CSRF protection). We do not use advertising cookies or third-party tracking.
9. Minors
The Platform is intended for people aged 18 or over, or for professional accounts managed by legal guardians.
10. Changes
We may update this Policy. The date at the top indicates the latest version. Relevant changes will be announced on the Platform.
11. Contact
Soluções e Sistemas — Contact: Heldon José — alinnequele@gmail.com — WhatsApp +55 (83) 99627-9632
Sorteio Pro is not affiliated with, sponsored or endorsed by Instagram or Meta Platforms, Inc.