Privacy Policy

Last updated: 21 September 2026

This text was drafted in Portuguese; in case of any divergence, the Portuguese version prevails.

1. Controller and contact

Data controller: ESPIRITO SANTO MUSIC PRODUÇÃO E COMÉRCIO LTDA-ME, CNPJ 33.179.602/0001-07, under the VERMUS (vermus.com.br) / Espírito Santo Music brand. Contact for privacy matters and exercise of rights: vermus@thiagoespiritosanto.com.br.

2. Data we collect

• Registration: name, e-mail, CPF, telephone (country code, area code and number) and instrument(s). • Card payment: card details are collected and processed directly by Mercado Pago. We do not store the card number; we receive only the confirmation and the data needed to manage your subscription. • Payment by Pix: we process the payment receipt and the transaction data needed to identify the payment and grant your access, plus a record of when access was granted. • Support: when you contact us on WhatsApp or by e-mail, we process the messages and the data you send through those channels. • Content you submit: chord charts and songs you upload, the analyses generated and, where you choose to share, your name displayed alongside the content in the Users' Library. • Usage and technical data: access logs, device, browser and IP address, for security and operation. • Cookies: used to keep you signed in, remember preferences and measure usage (see section 6).

3. Why we use it and on what legal basis

• To create and maintain your account and provide the service — performance of a contract. • To process subscriptions, payments and access — performance of a contract and legal obligation (tax). • To generate the musical analyses you request — performance of a contract. • To display, where you choose to share, your content and your name in the Users' Library — consent, which you may withdraw by taking the content down. • To send important service notices, including expiry of a Pix-paid subscription — performance of a contract / legitimate interest. • To send news and offers — consent, which you may withdraw at any time. • Security, fraud prevention and improvement of the platform — legitimate interest. • To comply with legal and regulatory obligations — legal obligation.

4. Who we share it with

We share data only with those necessary to operate the service:

• Mercado Pago — payment and subscription processing. • Database and hosting provider (Supabase and infrastructure services) — secure storage of data. • Artificial intelligence service used to generate the analyses from chord charts. That processing handles musical content (chords and charts) and is not aimed at identifying you; we do not send unnecessary sensitive personal data. • Other subscribers, exclusively as to the content you choose to share in the Users' Library and your name displayed alongside it. • Authorities, where required by law or court order.

We do not sell your personal data.

5. International transfer

Some providers (infrastructure and AI) may process data on servers outside Brazil. In those cases we adopt safeguards to ensure protection equivalent to that required by the LGPD.

6. Cookies

We use essential cookies (for login and operation) and, subject to your choice, usage- measurement cookies. You can manage cookies in your browser; disabling the essential ones may impair operation.

7. How long we keep it

We keep your data while your account is active and for as long as necessary to comply with legal obligations (for example, tax and accounting) and to resolve any disputes. Once the account is closed, data is deleted or anonymised, except what the law requires us to keep. Content you have shared goes offline when you remove it or when the account is closed.

8. Your rights

Under the LGPD you may, at any time: confirm the existence of processing; access your data; correct incomplete or outdated data; request anonymisation, blocking or deletion of unnecessary data; request portability; obtain information about sharing; and withdraw consent. To exercise these rights, write to vermus@thiagoespiritosanto.com.br.

9. Security

We adopt technical and organisational measures to protect your data, including access control and visibility restrictions — each student accesses only their own account and their own content, except what they themselves choose to share. No system is 100% infallible; in the event of a relevant incident we will notify you and the competent authority as required by law.

10. Children and adolescents

The platform may be used by students of any age. Processing of data of persons under 18 takes place in the minor's best interest and depends on the consent of a parent or legal guardian, who carries out the registration and the purchase.

11. Changes to this Policy

We may update this Policy. Material changes will be communicated on the platform or by e- mail, with the update date revised at the top.

12. Contact

Questions about privacy or your data: vermus@thiagoespiritosanto.com.br.