Privacy Policy

Last updated: 08/21/2026 · Version: 2.1

This Policy explains how we process your personal data under Brazilian Law 13,709/2018 (LGPD). It forms part of the Terms of Use.

Governing version. This is a translation provided for convenience. The Brazilian Portuguese version is authoritative and prevails in case of divergence.

Essential notice: Escute.ai handles intimate accounts that may contain sensitive personal data (health, sexual life, religious belief, political opinion, substance dependency data). Read section 4 before recording that kind of information.

1. Controller and contact

Controller: TICKETBRAS TECNOLOGIA DA INFORMAÇÃO LTDA, CNPJ 54.237.233/0001-31.

Data Protection Officer (DPO): Jor. Gabriel Martiniano.

Data subject and DPO channel: sac [arroba] ticketbras [ponto] com.

2. Who this Policy applies to

It applies to users of the website, PWA and apps, to visitors and to registered Professionals, as applicable.

3. Data we process

3.1. Provided by you

• identification and contact: name, e-mail, phone, country, language;
• registration data and preferences: chosen voice, active mode, settings;
• listening content: voice audio, transcripts, texts, notebook entries;
• billing data processed in the Hub and by payment providers (we do not store full card numbers);
• documents and professional registration, where you are a Professional.

3.2. Collected automatically

• access data: IP, date and time, session identifier, user agent;
• device data: model, system, app version, language, time zone;
• usage data: screens accessed, voice session duration, minute consumption, error events;
• cookies and similar technologies (section 12), including your analytics and marketing choices.

3.3. From third parties

• social login providers, where you choose them;
• payment and Hub providers, as to subscription status;
• app stores, as to installation and purchases.

3.4. Derived

• summaries, recurring themes, emotional state signals and conversation memory, produced automatically from your content to provide continuity of listening.

4. Sensitive personal data

4.1. Accounts of psychological suffering, health, medication, substance use, dependency, sexual life, grief, religion or politics are sensitive data (LGPD, art. 5, II). Sensitive health data requires specific care, which is the subject of this section.

4.2. The legal basis for processing them is your specific and highlighted consent (art. 11, I), given when accepting this Policy and using listening features, revocable at any time.

4.3. You decide what to record. We recommend not recording third parties' sensitive data. If you do, you are responsible for having a legal basis.

4.4. We do not use sensitive data for advertising, commercial profiling, insurance, credit or personnel selection, and we do not sell it.

5. Purposes and legal bases

• Create and maintain your account; authenticate — performance of contract (art. 7, V).
• Operate voice and text listening, transcribe, summarise and maintain conversation memory — performance of contract and, for sensitive data, consent (art. 11, I).
• Process subscription, billing and fraud prevention — performance of contract and legal obligation (art. 7, II and V).
• Send operational and security communications — performance of contract and legitimate interest (art. 7, IX).
• Share summaries with a Professional you authorise — specific consent (art. 7, I, and art. 11, I).
• Measure public pages and acquisition sources — consent (art. 7, I), revocable in privacy preferences.
• Measure ad conversions without revealing the topic visited — specific marketing consent (art. 7, I).
• Comply with judicial, tax and regulatory orders — legal obligation (art. 7, II).
• Exercise rights in proceedings — regular exercise of rights (art. 7, VI).
• Retain access logs — legal obligation (Internet Civil Framework, art. 15).

Where the basis is legitimate interest, we assess necessity, proportionality and your expectations, and you may object through the data subject channel.

6. Who we share with

6.1. AI providers that process audio and text to generate responses and summaries. Transmission is the minimum necessary for the feature to work.

6.2. Hosting, infrastructure and security.

6.3. Payment providers and the Hub, for subscription, billing and antifraud.

6.4. Professionals you expressly authorise, and only what you authorise.

6.5. Authorities, where there is a legal obligation, judicial order or valid request.

6.6. In corporate reorganisation, preserving the guarantees of this Policy.

6.7. Analytics and advertising tools, on non-sensitive public pages, to understand aggregate usage and campaigns. We do not send listening content, Notebook, memory, personal topics, sensitive routes, or URL parameters. You may decline analytics measurement; the signed-in app, native PWA, and admin panel stay outside this scope.

6.8. We do not sell your personal data or allow third parties to use listening content for advertising.

7. International transfer

Some providers are located outside Brazil. In those cases, transfer occurs under the grounds of art. 33 of the LGPD, with contractual clauses and safeguards compatible with the protection level of Brazilian law.

8. Retention periods

• listening content and memory: while the account exists, or until you delete the content;
• registration data: while the account exists and, after closure, for statutory periods;
• tax and payment data: 5 years, or the period required by tax law;
• application access logs: 6 months, under the Internet Civil Framework (art. 15);
• data needed for defence in proceedings: until the end of the applicable limitation period.

After those periods, data is securely deleted or anonymised.

9. Your rights

You may, at any time (LGPD, art. 18): confirm the existence of processing; access your data; correct it; request anonymisation, blocking or deletion of unnecessary data or data processed unlawfully; request portability; obtain information about sharing; be informed about the possibility of withholding consent and the consequences; revoke consent; and object to processing based on legitimate interest.

How to exercise: write to sac [arroba] ticketbras [ponto] com. We may ask for identity confirmation to protect your account. We respond within statutory deadlines.

Revocation of consent is free of charge, free of formality and available at any time, and does not depend on the professional's agreement with whom you may have shared something: revocation stops further sharing on our part, although the professional may retain, under their own responsibility, records their professional council requires them to keep. Revoking consent for sensitive data may render the listening features unusable, as they are the essence of the service.

10. Automated decisions

10.1. We use automation to transcribe, summarise, classify themes and adjust the experience.

10.2. We do not make automated decisions with legal effect over you, such as denying credit, employment or healthcare.

10.3. You may request review and information about the criteria used (art. 20).

11. Security

We adopt appropriate technical and administrative measures, including encryption in transit, credential-based access control, environment segregation, audit logging, periodic backup and least-privilege. No system is infallible; report suspicions to the contact channel. In the event of an incident with relevant risk, we will notify you and the ANPD under art. 48.

12. Cookies and similar technologies

We use strictly necessary cookies and local storage (session, security, preferences such as theme and language). On non-sensitive public pages, we may use analytics cookies (until you decline) and advertising cookies on allowed commercial routes. Conversations, Notebook, memory, signed-in areas, native PWA, and sensitive pages stay outside this measurement. You may decline or revoke without losing product access.

13. Children and adolescents

The service is intended for people aged 18 or over. We do not knowingly collect children's data. Use by an adolescent requires consent and assistance of a legal guardian; if improper processing is identified, the data will be deleted.

14. Third-party data you record

When you mention another person in your accounts, you are processing third-party data. Do so sparingly and only where necessary to your personal process. We act as processor for that portion and may respond to legitimate requests from mentioned data subjects.

15. Changes to this Policy

We may update it. Material changes will be communicated with reasonable notice, and the date and version appear at the top. Continued use after the effective date indicates awareness.

16. Complaints

You may complain directly to us and, if you prefer, complain to the ANPD (Brazilian National Data Protection Authority) or to consumer protection bodies.

17. Voice and audio data

17.1. Audio captured in voice features is processed to transcribe, generate responses and feed conversation memory.

17.2. The microphone is activated only during a session started by you. There is no background listening, and ending the session stops capture.

17.3. Audio excerpts and transcripts may be transmitted to AI providers to the extent necessary for the feature.

17.4. Voice is potentially biometric data. We do not use your voice for biometric identification, authentication, identity verification, voice-cloning training or any person-recognition purpose.

18. Conversation memory and derived data

18.1. To provide continuity between conversations, we automatically produce summaries, recurring themes and emotional state signals.

18.2. Those derivations are inferences, may be wrong, and do not constitute diagnosis, assessment, clinical classification or commercial behavioural profiling.

18.3. You may request deletion of conversation memory; this ends continuity and is irreversible.

19. What we do NOT do with your data

19.1. We do not sell, rent or transfer personal data.

19.2. We do not use listening content for advertising, commercial targeting, credit analysis, insurance, personnel selection or risk assessment.

19.3. We do not share listening content with employers, health plans, insurers, educational institutions or family members, except by legal order.

19.4. We do not use identifiable content to train our own AI models.

20. Cookies — detail

20.1. Necessary: authenticated session, fraud protection, theme and language preference, form drafts. Without them the platform does not work.

20.2. Analytics: pseudonymous source attribution and aggregate statistics on non-sensitive public pages, without URL parameters, until explicit decline. Browser attribution expires within 90 days.

20.3. Advertising: conversion pixel on allowed generic commercial pages, with sanitised events. Thematic or sensitive routes, listening content, and direct identifiers are blocked.

20.4. Local storage may keep onboarding drafts and preferences on your own device; clearing browser data deletes them.

21. Processors and categories of third parties

21.1. We engage processors for hosting, AI processing, e-mail and notification delivery, payments, antifraud and observability.

21.2. Processors act under our instructions, bound by contractual confidentiality and security obligations, and may not use your data for their own purposes.

21.3. The list of current categories may be requested through the data subject channel.

22. Security — detail of measures

22.1. Encryption in transit on all connections; access control by individual credential under least-privilege.

22.2. Environment segregation, audit logging of administrative access and periodic permission review.

22.3. Backups with limited retention, for operational continuity.

22.4. No measure eliminates risk entirely. We do not promise inviolability.

23. Security incidents

23.1. Where an incident with relevant risk or damage is identified, we will notify you and the ANPD within a reasonable period, under art. 48 of the LGPD.

23.2. The notice will describe the nature of the affected data, the risks involved, the measures taken and protective recommendations.

23.3. Incident notification does not imply admission of fault or damage.

24. Exercising your rights — procedure

24.1. Send your request to the data subject channel stating which right you intend to exercise.

24.2. We may request additional information to confirm identity, solely to prevent a third party from accessing or deleting your data.

24.3. We respond within statutory deadlines. Manifestly excessive or repetitive requests may require additional time, with justification.

24.4. A deletion request may be partly refused where there is a legal retention obligation, regular exercise of rights or a remaining legal basis — in which case we will explain what was retained and why.

25. Portability

25.1. The portability right under art. 18, V of the LGPD is honoured upon express request, after verification that you are the data subject.

25.2. It covers the data you provided. It does not cover trade secrets — the models, instructions and derivations that make the service work are ours, not your data —, third-party data appearing in your content, or data already anonymised (art. 18, §7).

25.3. We do not offer open export or a standalone download file, and that is a security decision rather than a convenience one. Listening content is the most sensitive information we hold about anyone: a loose package can leak, be copied by whoever has the device, or be demanded of you under pressure. A file that does not exist cannot be taken from anyone.

25.4. Portability to another provider is performed directly between providers, in an interoperable format and over a secure channel, with no intermediate file — which is how the law itself describes the right when it speaks of porting "to another service or product provider".

25.5. If delivery to you is necessary, it is encrypted, addressed only to the verified data subject, and the key travels through a separate channel.

26. Closed accounts and what happens to the data

26.1. Once the account is closed, listening content is deleted or anonymised, subject to statutory retention periods.

26.2. Tax, payment and access log data remain for the periods in sections 8 and 20, even if the account no longer exists.

26.3. Backups are overwritten according to the retention routine; deletion is not instantaneous across all layers.

27. Inactivity

27.1. Accounts with no access for a prolonged period may be closed, with prior notice to the registered e-mail.

27.2. Closure for inactivity follows the deletion rules in section 26.

28. Professional profiles and public data

28.1. Professionals who opt for a public profile authorise display of the information they themselves publish.

28.2. Professional council registration data is public by nature and may be displayed for verification.

28.3. Users' listening content is never displayed on a public profile.

29. Communications and opting out

29.1. Operational, security and billing communications are inherent to the contract and cannot be refused while the account exists.

29.2. Promotional communications may be refused at any time, without prejudice to operational ones.

30. Legitimate interest — balancing test

30.1. Where we process on the basis of legitimate interest, we consider the concrete purpose, necessity, proportionality, the impact on you and your reasonable expectations.

30.2. We apply minimisation, aggregation and anonymisation wherever the purpose is achievable without identifiable data.

30.3. You may object to processing based on legitimate interest through the data subject channel, and we will assess the request case by case.

31. Anonymisation and statistical use

31.1. Anonymised data that cannot be re-identified by reasonable means is not personal data and may be used to measure and improve the service.

31.2. We will not attempt to re-identify anonymised data, and third parties are prohibited from doing so.

32. Corporate succession and continuity

32.1. In a merger, acquisition, spin-off or transfer of assets, data may be transferred, preserving the purposes and guarantees of this Policy.

32.2. Where there is a material change of purpose, you will be informed and, where the basis is consent, you may revoke it.

33. Jurisdiction, language and precedence

33.1. This Policy is governed by Brazilian law, in particular the LGPD and the Internet Civil Framework.

33.2. In case of divergence between versions in different languages, the Brazilian Portuguese version prevails.

34. Contact

TICKETBRAS TECNOLOGIA DA INFORMAÇÃO LTDA · CNPJ 54.237.233/0001-31

DPO: Jor. Gabriel Martiniano · Data subject channel: sac [arroba] ticketbras [ponto] com