Privacy Policy

1. INTRODUCTION

SHIFTERS - CONSULTORIA E SOFTWARE LTDA. - EPP ("SHIFTERS", "we", "our" or "us"), registered under CNPJ/MF no. 15.563.090/0001-04, headquartered at Rua Mourato Coelho, 957, Pinheiros, CEP 05417-011, São Paulo, Brazil, operates GOTOMONEY.AI, an Artificial Intelligence engine for generating visual and advertising assets.

This Privacy Policy explains how we collect, use, disclose and protect your information when you use our services, visit our website https://gotomoney.ai, or interact with any of our applications (collectively, the "Services"). As a company based in Brazil, we are governed primarily by the Brazilian General Data Protection Law (LGPD), Law No. 13.709/2018. However, we respect and comply with other applicable data protection regulations to the extent they apply.

IMPORTANT NOTICE - B2B DATA ROLES: GoToMoney is a Business-to-Business (B2B) platform. If you are an Agency, Consultant or Traffic Manager uploading data and URLs on behalf of your clients, you act as Data Controller under applicable privacy laws, and Shifters acts strictly as a Processor. It is your legal responsibility to ensure you have obtained the necessary consents to use third-party brands, logos and links on our Services.

2. DEFINITIONS

• "Personal Data": any information relating to an identified or identifiable natural person.
• "Processing": any operation performed on Personal Data (collection, storage, creation, use, etc.).
• "Controller": entity that determines the purposes and means of Processing. For your billing and account data, Shifters is the Controller. For client links and logos you send us, YOU are the Controller.
• "Processor": entity that carries out data Processing on behalf of the Controller.
• "Input Data and Assets": the information provided to run the AI engine, comprising: (1) website/Instagram URL or descriptive Text, (2) the company Logo provided by the user, and (3) the hyper-realistic visual assets (ads) generated as a result.
• "LGPD": Brazilian General Data Protection Law (Law No. 13.709/2018).
• "ANPD": Brazilian National Data Protection Authority.

3. INFORMATION WE COLLECT

We strictly separate your standard account/payment data from the inputs provided for image generation.

A. Account and Billing Data

• Contact Information: name, email, phone number (e.g. for delivery via WhatsApp).
• Payment Information: billing data required and transaction history. Processing to release the timer ($1) and the final charge is handled by rigorous external gateways such as Stripe. We do not store raw credit card numbers on our servers.
• Usage Data: IP addresses, browser types, session durations and logs about how you navigate the GoToMoney landing page.

B. Input and Creative Generation Data

Information you enter to generate the ads, including URLs, context texts and image files (Logos in PNG/WEBP). This data is processed for the exclusive purpose of feeding the momentary context of our generator and delivering the contracted batch of advertising assets.

4. THE "ZERO TRAINING" GUARANTEE AND AI PROCESSING

Since GoToMoney processes the visual identity and positioning of your business (or your client's), we apply strict data-handling rules regarding Artificial Intelligence:

• No Native Brand Image Training: We do not use your uploaded files (Logos) or the final visual assets generated for your campaign to train, fine-tune or create public databases for other GoToMoney users. The visual asset generated for you is delivered strictly to you.
• Isolation via Image/Text API: We process your input through closed APIs of established partners for image generation and Large Language Models (LLMs). According to our agreements with these vendors, the prompts generated by our "Creative Brain" are not used to train their public models.

5. PROHIBITED DATA (USER RESPONSIBILITY)

For the legal security of our commercial engine, Users are strictly prohibited from submitting the following inputs to GoToMoney for image generation:

• Protected Health Information (PHI) or confidential medical images.
• Logos, trademarks or intellectual property over which you do not hold usage rights or a clear commercial license (e.g. asking the AI to create campaigns simulating official competing brands).
• Sensitive PII, non-consensual nudity or materials that violate global copyright laws.

If you request creative generation with prohibited data, you assume 100% of the legal and financial responsibility resulting from using those images on advertising platforms.

6. HOW WE USE YOUR INFORMATION

We process your data for the following purposes:

• A. Asset Generation and Delivery: We use your URL/Text and Logo exclusively to trigger the AI engine, create the dozens of variations (With text, Without text, With Logo, Without Logo) in the appropriate formats and deliver the final batch to your WhatsApp within the stipulated deadline.
• B. Billing and Guarantee: To operate the validation mechanics with the payment gateway and ensure strict compliance with the "Score 8 Guarantee" set out in our commercial offer.
• C. Communication and Marketing: To send batch updates, provide support on WhatsApp and share news.
• D. Legal Purposes: To comply with applicable Brazilian legislation, prevent credit card fraud and report transactions.

7. LEGAL BASIS FOR PROCESSING (LGPD)

• Contractual Necessity (Art. 7, V): to trigger the creative generation engine, deliver the assets and complete the charge.
• Legal Obligation (Art. 7, II): to comply with tax laws and the Brazilian Internet Civil Framework.
• Consent (Art. 7, I): when you opt in to secondary communications.
• Legitimate Interests (Art. 7, IX): to protect our systems, prevent fraud and improve the Creative Brain's capabilities.

8. ARTIFICIAL INTELLIGENCE AND USAGE RIGHTS

• The Role of AI: GoToMoney uses cutting-edge artificial intelligence engines (e.g. Midjourney, Stable Diffusion, DALL-E, etc. via integrations) to generate visual assets. Although the pieces have photo-realistic quality, they are synthetic constructions and do not replace literal photographic reproductions of exclusive physical products (complex labels that cannot be mapped without 3D input, etc.).
• User Review: By giving a "Score 8" and validating the purchase, the user assumes full responsibility for reviewing the images before their final spend on paid traffic platforms (Meta Ads, Google Ads).

9. DATA PROTECTION AND SECURITY

We implement enterprise-grade technical measures. Our security measures include:

• Encryption: TLS/SSL for data in transit (including secure delivery to your WhatsApp).
• Payment Vetting: Financial processing exclusively managed through Stripe's protected environment, maintaining state-of-the-art PCI compliance.

10. DATA SHARING AND DISCLOSURE

We do not sell your creative formulation data. We only share technically necessary information with:

• Cloud Providers: Servers for temporary storage of the generated images (AWS/Cloudflare).
• Financial Processors: Stripe (and any local partners, if applicable).
• AI Partners / APIs: Rendering tools and providers necessary to transform your textual input into the final visual output (OpenAI, MidJourney, etc.).
• Communications: Commercial WhatsApp messaging and management platforms.
• Legal Authorities: When expressly required by Brazilian law or court order.

11. INTERNATIONAL DATA TRANSFERS

GoToMoney is managed from Brazil, but our server infrastructure, payment gateways (Stripe) and AI model providers are distributed globally. By using the platform, you agree to the strictly technical transfer of these inputs abroad.

12. DATA RETENTION

• Account/Subscription Data: For "Zero Fatigue" and "Scale" plans, we actively keep the identity, brand tone and history stored to feed the next batches without friction.
• Invoices: Kept for 10 years due to Brazilian tax and accounting legislation.
• Generated Assets: Processed batches may be periodically cleared from our storage servers after delivery to the client to reduce heavy graphic infrastructure costs; make sure to save the materials received on WhatsApp.

13. YOUR RIGHTS UNDER BRAZILIAN LAW (LGPD)

You and your company have the right to confirm the existence of processing, access, correct, revoke consent (cancel subscriptions) and request the commercial deletion of contact data. To exercise these rights, contact our team at suporte@shifters.com.br.

14. COOKIES AND TRACKING TECHNOLOGIES

We use essential and performance tags (pixels and analytics associated with conversion on ads) to measure the effectiveness of the GoToMoney page. You can manage these permissions on your device or browser.

15. SECURITY INCIDENTS

In the event of a breach affecting your account information, we will notify users and the ANPD within the applicable legal deadlines.

16. CHILDREN'S PRIVACY

GoToMoney is a professional (B2B) tool. We do not collect or process requests or data from individuals under 18 years of age.

17. CHANGES TO THIS POLICY

We may update this Privacy Policy. Continued use of the services after changes are published on our domain constitutes acceptance of the updated version.

18. DISPUTE RESOLUTION

Any disputes will be resolved under Shifters' corporate guidelines. The chosen jurisdiction will be the Judicial District of São Paulo/SP, Brazil, governed exclusively by Brazilian legislation, with express waiver of class actions.

19. CONTACT

• Support / Privacy Email: support@shifters.ai
• Corporate Portal: https://shifters.ai
• Address: SHIFTERS - CONSULTORIA E SOFTWARE LTDA. - EPP, Rua Mourato Coelho, 957, Pinheiros, CEP 05417-011 - São Paulo / SP - Brazil
• CNPJ/MF: 15.563.090/0001-04