Privacy Policy

ZABIX TECNOLOGIA E INOVAÇÃO LTDA, registered under CNPJ No. 29.358.857/0001-60, headquartered at Rua Antônio Farias, No. 657, Piedade, Jaboatão dos Guararapes/PE, CEP 54400-320, Brazil (“ZABIX”, “we”, “us”), values the privacy and protection of the personal data of users of the SALTER platform (“Salter”, “Platform”, or “Service”) and operates in compliance with the General Personal Data Protection Law (Law No. 13.709/2018 - “LGPD”), the Brazilian Civil Rights Framework for the Internet (Marco Civil da Internet), and other applicable regulations.

For the purposes of the LGPD, ZABIX acts predominantly as a controller of the personal data processed within the scope of Salter, and may act as a processor only in specific and delimited circumstances, depending on the nature of the activity performed.

By using Salter, you declare that you have read and understood this Privacy Policy.

1. Scope of this Policy

This Policy describes how ZABIX collects, uses, stores, shares, protects, and treats personal data in the context of using Salter, including features related to:

• registration and authentication;
• musical organization;
• playlists, libraries, and events;
• subscription and billing;
• educational content;
• Marketplace;
• Official Repertoires;
• Community Repertoires;
• repertoire import flows;
• reports, moderation, auditing, and security.

2. Data Collected

We may collect and process the following categories of data:

2.1. Registration data

Name, email, account identifiers, preferred language, profile picture, and other information provided by the User during registration, onboarding, or profile updates.

2.2. Usage data

Information related to the use of the Platform, such as interactions with features, accessed songs, viewed repertoires, imported repertoires, created playlists, performed practices, progress in content, favorites, searches performed, use of internal resources, and navigation in Platform modules, in an aggregated or individual form, as necessary for the operation of the Service.

2.3. Technical data

IP address, date and time of access, browser, operating system, device identifiers, authentication logs, technical events, session records, and information related to Platform security, performance, and stability.

2.4. Transactional and operational data

Information related to subscriptions, plan status, access releases, use of redemption codes, import history, electronic acceptance of terms, report records, moderation, auditing, fraud prevention, and related operational events.

2.5. Financial data

Data related to payments and billing, processed directly by third parties contracted for this purpose, such as Stripe and other partners. ZABIX may receive summary information necessary for payment confirmation, reconciliation, fraud prevention, and support.

2.6. Musical content and materials inserted by the User

Songs, chords, lyrics, notes, metadata, libraries, playlists, links, files, and other content inserted, organized, imported, or shared by the User within the Platform, as well as information associated with such content.

2.7. Data related to repertoires and imports

We may process data related to the viewing, import request, acceptance of responsibility, availability in the User's environment, internal indexing for the User’s own searches, reports, blocks, removals, recidivism (repeat offenses), and auditing of:

• Official Repertoires;
• Community Repertoires;
• Commercialized repertoires, when applicable.

2.8. Service and support data

Information sent by the User in contacts with ZABIX, including support requests, questions, complaints, privacy requests, reports, disputes, and feedback.

We do not collect sensitive personal data without a specific and appropriate legal basis.

3. Purposes of Processing

Personal data may be used for the following purposes:

• to execute, operate, maintain, and improve the Service;
• to authenticate users, manage accounts, and control access;
• to personalize the User experience;
• to process subscriptions, billing, and plan management;
• to enable discovery, viewing, importation, and use of Official Repertoires, Community Repertoires, and commercialized repertoires, when applicable;
• to record electronic acceptance and maintain traceability and audit trails;
• to enable imported content to become part of the User's private environment and be found in searches, filters, and internal mechanisms available to the User themselves, in accordance with the Platform's functionality;
• to organize songs, libraries, playlists, practice sessions, favorites, and other product features;
• to moderate content, analyze reports, and prevent abuse;
• to analyze the recurrence of reports, misuse, and repeat offenses for the application of security, compliance, and moderation measures;
• to communicate with the User;
• to protect the Platform, prevent fraud, and security incidents;
• to comply with legal and regulatory obligations or orders from authorities;
• to exercise or safeguard ZABIX's rights in judicial, administrative, or arbitration proceedings;
• to produce internal analysis, metrics, reports, and product improvements;
• to resolve disputes related to content, access, importation, reports, moderation, and use of the Platform.

4. Legal Bases

The processing of personal data by ZABIX occurs based on the following legal grounds, as applicable:

• execution of a contract and preliminary procedures related to the use of the Platform;
• compliance with a legal or regulatory obligation;
• legitimate interest of ZABIX, including for security, fraud prevention, auditing, moderation, Service improvement, analytics, and defense of rights;
• regular exercise of rights in judicial, administrative, or arbitration proceedings;
• consent of the data subject, when legally required.

5. Community Repertoires, Importation, and Internal Indexing

When the User views, requests an import, or imports Official Repertoires or Community Repertoires, ZABIX may process personal and operational data related to this flow, including to:

• record the acceptance of the Import Responsibility Term;
• link the imported repertoire to the User's account;
• maintain an audit trail;
• enable the imported content to become part of the User's private environment;
• allow this content to be found in searches, filters, and internal mechanisms available to the User themselves;
• adopt moderation, report, removal, deactivation, or restriction measures when necessary;
• identify events of recidivism, misuse, or legal risk related to the content.

Internal indexing of imported content for the User’s own use does not imply automatic public indexing for third parties.

6. Data Sharing

Personal data may be shared, when necessary, with:

• technology, infrastructure, hosting, storage, authentication, and support providers;
• payment processors and intermediaries;
• partners and providers involved in security, analytics, monitoring, moderation, auditing, and technical operation of the Platform;
• administrative, regulatory, police, or judicial authorities, when required by law, order, or valid request;
• third parties involved in the defense of ZABIX’s rights, when necessary.

ZABIX does not sell personal data.

7. International Transfer

Personal data may be stored or processed on servers located in Brazil or abroad, including by international service providers, provided that appropriate safeguards and applicable legal requirements are observed.

8. Information Security

ZABIX adopts reasonable technical and administrative measures to protect personal data, including, as applicable:

• access control;
• segregation of permissions;
• audit records;
• security monitoring;
• mechanisms to protect against unauthorized access, destruction, loss, alteration, or improper disclosure.

Although we adopt security best practices, no system is entirely immune to failures or incidents.

9. Rights of the Data Subject

Under the LGPD and subject to applicable legal limitations, the User may request:

• confirmation of the existence of processing;
• access to personal data;
• correction of incomplete, inaccurate, or outdated data;
• anonymization, blocking, or elimination of unnecessary, excessive, or unlawfully processed data;
• data portability, when applicable;
• elimination of data processed with consent, when applicable;
• information about shared use of data;
• information about the possibility of denying consent and the consequences of such denial;
• revocation of consent, where this is the applicable legal basis.

Requests may be made via https://salterapp.com/PublicContact.

10. Data Retention

Personal data will be kept for the time necessary to fulfill the purposes described in this Policy, including to:

• keep the account active and the Platform functioning;
• provide support;
• comply with legal, regulatory, tax, and accounting obligations;
• exercise or safeguard ZABIX's rights;
• prevent fraud and maintain an audit trail;
• resolve disputes related to content, access, importation, reports, moderation, and use of the Platform.

For free accounts (Freemium), data and content may be deleted after a prolonged period of inactivity, as described in the Terms of Use.

After account deletion or termination, data may be kept for the necessary legal period or for a duration compatible with legal and regulatory obligations, fraud prevention, auditing, moderation, reports, and the regular exercise of rights.

Records related to:

• acceptance of terms;
• repertoire imports;
• reports;
• moderation;
• auditing;
• fraud prevention;
• recurrence of violations;
• regular exercise of rights

may be kept for a period compatible with these purposes and with applicable law.

11. Cookies and Similar Technologies

The Platform may use cookies and similar technologies for:

• authentication;
• session maintenance;
• security;
• performance;
• analytics;
• personalization of experience.

The User may, at any time, manage their cookie preferences through browser settings or, when available, through the Platform's own mechanisms.

12. Changes to this Policy

This Privacy Policy may be updated periodically to reflect legal, regulatory, operational, technical, or product changes.

The most recent version will be available on the Platform with an indication of the update date. When required by law or when the change is material, we may adopt additional notice or acceptance mechanisms.

13. Contact

In case of questions, requests, or the exercise of rights related to personal data, the User may contact the official channel https://salterapp.com/PublicContact.