Privacy Policy
Last updated: 07/30/2026 · Version: 2.0
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).
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 usage, fix errors and improve the service, on aggregated data — legitimate interest (art. 7, IX).
- 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. We do not sell your personal data and do not transfer it for third-party 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) and, where applicable, usage measurement. You may manage cookies in your browser; disabling necessary ones may prevent operation. We do not use third-party behavioural advertising cookies in the logged-in area.
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. Measurement: usage counting and error diagnostics, on an aggregated basis.
20.3. We do not use third-party behavioural advertising cookies in the logged-in area.
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. You may request your data in a structured, commonly used format.
25.2. Portability covers data provided by you and, where technically feasible, relevant derivations — it does not cover trade secrets or third-party data.
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