1. Objective
Establish mandatory guidelines for all employees, contractors, and sub-processors who handle data on behalf of Reverba. This policy defines minimum controls to protect information assets against unauthorized access, loss, improper alteration, or unavailability.
2. Scope
Applies to:
- All systems, databases, and files under Reverba's management.
- Every employee, contractor, or partner with access to personal or sensitive data processed by Reverba.
- All environments (production, staging, development) and devices (servers, workstations, corporate mobile devices) used to deliver the service.
3. Governance and responsibilities
- Oneck Creative LTDA executive board: approves this policy, allocates resources, and is accountable for serious deviations.
- Data Protection Officer (DPO): privacidade@reverba.com.br. Receives communications from data subjects and the Brazilian Data Protection Authority (ANPD); advises on practices; oversees LGPD/GDPR compliance.
- Tech Lead: responsible for technical code controls (hardening, encryption, code review, vulnerabilities) and CI/CD pipeline maintenance.
- Operations: executes backup, monitoring, and incident response procedures per the Incident Response Plan.
4. Data classification
Data processed by Reverba is classified at three levels:
| Level | Examples | Minimum controls |
|---|---|---|
| Confidential | Passwords (hash), marketplace OAuth tokens, encryption keys, payment data (handled by Mercado Pago) | Encryption at rest and in transit; role-based restricted access; mandatory auditing |
| Restricted | Operator and Contact PII (name, email, phone, purchase history), message content | Encryption in transit; multi-tenant isolation; need-to-know access; read logs for sensitive actions |
| Internal | Aggregated operational logs, usage metrics, telemetry with anonymized IP | Authorized employees only; limited retention |
5. Access control
- Least privilege: every employee receives only the permissions strictly necessary for their role.
- Authentication: passwords stored with bcrypt (cost 10), JWT tokens with 15-minute access TTL and 30-day rotating refresh. Credential sharing is prohibited.
- Product roles: OWNER (account administrator), ADMIN (operational manager), SELLER (operator). Every API endpoint validates the minimum required role.
- Administrative access: the production dashboard is accessible only to the technical team via dedicated VPN; production database access requires Tech Lead authorization and is logged.
- Revocation: upon any employee separation, all accesses are revoked within 24 hours (target: 1 hour for incidents involving staff).
- MFA: mandatory implementation for OWNER and ADMIN roles is on the roadmap (Q3 2026); meanwhile, long unique passwords + suspicious login monitoring cover the gap.
6. Cryptography
- In transit: TLS 1.2+ mandatory on all public endpoints. HSTS active. Security headers via
helmet(CSP, X-Frame-Options, X-Content-Type-Options, Referrer-Policy). - At rest:
- Passwords: bcrypt cost 10 (>100ms cost for brute-force).
- TikTok Shop, Mercado Livre, Shopee, and Meta OAuth tokens: AES-256-GCM with 256-bit keys generated via
openssl rand -hex 32, persisted in.env. - Postgres: full disk encryption provided by VPS provider.
- Key management: encryption keys are kept outside version control; stored only in production server
.envand offline vault. Scheduled rotation every 12 months or upon incident. - Webhooks: HMAC-SHA256 mandatory on every inbound webhook (TikTok Shop, Shopee, Mercado Livre, Meta). Invalid signatures yield 401 and an alert log entry.
7. Network security
- Segregation: production environment isolated via VPS firewall, with restricted ingress rules (only 443/HTTPS public, 22/SSH only from team IPs). Database has no port exposed to the internet — listens only on localhost of the application server.
- Anti-DDoS / anti-bot: global throttler on sensitive endpoints; Cloudflare in front of the public website and the API gateway.
- CORS: restricted allowlist of origins (no wildcards) — defined in
.env. - Webhook IP allowlist: optional per integration (applicable when the source platform publishes a stable IP range).
8. Corporate endpoints
- Team workstations run macOS with FileVault enabled, automatic OS updates, and local passwords with minimum complexity.
- Endpoint Detection and Response software (native macOS XProtect + additional monitoring) installed on every workstation with access to production data.
- Private code repositories; password-protected SSH keys; GPG signed commits when feasible.
9. Secure development
- SDLC: feature branching; PRs reviewed by at least 1 other engineer before merge to
main. - Dependencies: recurring
npm audit; critical vulnerabilities addressed within 7 business days. - Input validation: global Nest pipeline with class-validator enforcing whitelisting + Zod on critical payloads. Rejects undeclared fields.
- Injection prevention: Prisma ORM with prepared statements; no manual SQL concatenation.
- Tests: minimum 70% backend coverage; e2e suite validates multi-tenant isolation on every deploy.
- Secret scanning: pre-commit hook prevents committing tokens, AWS keys, or plaintext passwords.
10. Vendor management
Each sub-processor listed in Privacy § 5 undergoes prior assessment, considering:
- Reputation and history of public incidents.
- Existence of a Data Processing Agreement (DPA) and international transfer clauses where applicable.
- Available certifications (SOC 2, ISO 27001, PCI-DSS for payments).
- Data location and legal bases for transfer.
Material changes (provider switch, new regions) are communicated 14 days in advance to account-owning Operators.
11. Vulnerability management
- Monitoring:
npm auditon every CI run; automatic GitHub Dependabot alerts. - Classification: vulnerabilities classified as CRITICAL / HIGH / MEDIUM / LOW per CVSS.
- Remediation SLAs:
- CRITICAL: within 7 business days.
- HIGH: within 30 days.
- MEDIUM: within 90 days.
- LOW: next maintenance cycle.
- Responsible disclosure: researchers who identify vulnerabilities can report via privacidade@reverba.com.br. We do not retaliate against good-faith research.
- Pentest: external pentest is on the 2026 roadmap (after platform stabilization).
12. Business continuity and backup
- Postgres backups: daily full snapshots + continuous WAL streaming. Retention: rolling 30 days.
- Location: backups stored in the same region (Brazil) on a separate volume from the primary server.
- Restore drill: quarterly restore test in an isolated environment; documentation kept current.
- RTO (Recovery Time Objective): 4 hours for a catastrophic incident.
- RPO (Recovery Point Objective): 1 hour.
13. Auditing and logs
- Application logs: every request recorded via Pino (structured JSON) with
request-id; 90-day retention. - Domain audit log: destructive and permission-changing actions recorded in a dedicated table (
AuditLog) with actor, timestamp, IP, sanitized payload; 2-year retention. - Webhook logs: every inbound webhook has an idempotent event ID in
MarketplacePushInbox— enables replay and dedupe.
14. Improvement roadmap
We acknowledge limits and stay transparent about them. Items in development or evaluation:
- Mandatory MFA for OWNER and ADMIN Operators — Q3 2026.
- External pentest with a recognized vendor — evaluation in 2026.
- SOC 2 Type 2 certification — under evaluation for 2027 based on enterprise customer volume.
- Managed HSM for encryption keys (instead of
.env) — under evaluation.
Material updates to this policy are communicated as per § 13 of the Privacy Policy.