Privacy Policy and Personal Data Protection – Primmo Audio Lab

This Privacy Policy was drafted in accordance with the guidelines of the Brazilian General Data Protection Law (LGPD) and best practices for SaaS (Software as a Service) platforms. Primmo Audio Lab is an AI-powered audio restoration tool that collects and processes data to deliver its services.

1. Introduction

This Policy explains how Primmo Audio Lab ("we") collects, uses, stores, and protects the information of our users ("you"). By using our automatic audio restoration platform for vinyl records, cassette tapes, and other recordings, you agree to the practices described here.

2. Data Collected and How It Is Collected

We collect data necessary to provide the service and improve your experience:

• Registration Data: Name and email address provided during sign-up or early access.
• Audio Files: Digitized recordings (WAV, FLAC, MP3) that you upload for processing by our AI.
• Payment Data: Billing information processed by third-party partners for plan management (e.g., Basic plan at R$ 19/month).
• Usage Data and Cookies: IP address, browser type, pages visited, and platform interactions for security and performance analysis purposes.

3. Purposes of Processing

Your data is used to:

1. Service Delivery: Run the audio restoration pipeline (noise removal, equalization, and normalization).
2. Account Management: Manage your subscription, payments, and provide technical support.
3. AI Improvement: Analyze usage patterns to optimize restoration algorithms, respecting content privacy.
4. Communication: Send service updates, news, and offers (with your consent).

4. Legal Bases for Processing

We process your data based on the following legal grounds under the LGPD:

• Contract Performance: Necessary to provide access to the SaaS platform and process your audio files.
• Consent: For sending marketing emails and beta version updates.
• Legal Obligation: For issuing invoices and maintaining accounting records.
• Legitimate Interest: To ensure network security and prevent fraud.

5. Sharing Data with Third Parties

We may share data with essential partners for operations, such as:

• Cloud Providers: For storage and processing of audio files.
• Payment Processors: For secure financial transactions.
• Analytics Tools: To understand user behavior on the site (e.g., Google Analytics).
• Judicial Authorities: When required by law or court order.

6. Your Rights as a Data Subject

Under the LGPD, you have the following rights, which may be exercised at any time:

• Confirm the existence of processing and access your data.
• Correct incomplete, inaccurate, or outdated data.
• Request deletion of unnecessary data or data processed with consent.
• Data portability to another service provider.
• Withdraw consent for marketing communications.

7. Data Security

We adopt technical and administrative measures to protect your information from unauthorized access and security incidents:

• Encryption: SSL protocols in transit and encryption for sensitive data at rest.
• Access Control: Only authorized and trained employees have access to strictly necessary data.
• Monitoring: Periodic audits of our systems.

8. Data Retention and Deletion

• Audio Files: Uploaded and restored files are retained only for the period necessary for you to download them, being automatically deleted after the deadline defined in the Terms of Use.
• Account Data: Retained while you have an active account or as required by legal obligations (e.g., fiscal record retention for 5 years).

9. International Transfer

As we operate on global cloud infrastructure, your data may be transferred to servers outside Brazil (e.g., USA or European Union). We ensure that these countries have adequate levels of data protection and that our contracts include standard security clauses.

10. Contact and Data Protection Officer (DPO)

To exercise your rights or ask questions about this Policy, please contact our Data Protection Officer by email: primmoaudiolab@gmail.com.

Last updated: May 4, 2026.