Privacy Policy

This Policy explains what data Sistema Seabra collects, why it collects it, who it shares it with, how long it retains it, and what you can require of us. It follows the General Data Protection Law (Law No. 13.709/2018 — LGPD).

Who is responsible for your data (controller): SEABRA SOLUTIONS LTDA, registered under CNPJ No. 50.132.061/0001-80, headquartered in Florianópolis, Santa Catarina, Brazil — referred to herein as "we" and "our".

Service: Sistema Seabra, in its Android, iOS, and web versions, and the sistemaseabra.com.br website.

Privacy contact: sistemaseabra@gmail.com

1. The essentials, on one screen

The rest of this document details every point, but if you read only this section you already know the main ones:

• We do not sell your data, and we do not provide it to third parties for advertising.
• There is no ad tracker inside the app. We do not use Google Analytics, the Facebook SDK, or anything similar.
• The herd you register is yours. You can export it as a spreadsheet or a PDF whenever you want, and request its deletion.
• Voice dictation never leaves your device. Recognition is performed by your phone itself; no audio is sent to any server.
• Camera, microphone, and location are only accessed with your permission, and never in the background.
• The artificial intelligence assistant sends data from your herd to an external provider in order to answer you. If that does not work for you, simply do not use the assistant — section 6 explains this in detail.
• We use aggregated and anonymized data to improve the app and produce benchmarks for the industry — the name of your property and your animals never appears, and you can ask to opt out. See section 8.
• Accepting an association's invitation means sharing your herd with it. Nothing is shared until you accept, and section 7.3 states exactly what the association will be able to see.
• You can request a copy, correction, or deletion of your data by email, and we respond within 15 days.

2. Definitions

• Service or Application: Sistema Seabra and the sistemaseabra.com.br website.
• Personal Data: any information that identifies or makes identifiable a natural person.
• Processing: any operation performed with Personal Data — collecting, storing, using, sharing, correcting, deleting.
• Controller: whoever decides how and why the data is processed.
• Processor: whoever processes data on behalf of the controller, following its instructions — for example, the company that hosts our database.
• Data Subject: the person to whom the Personal Data relates — you.
• User: whoever uses the Service. This can be a producer, a producer's collaborator, a technician, or an association administrator.

3. Who uses Sistema Seabra, and who each piece of data belongs to

Sistema Seabra is used by different types of profiles, and this changes who is responsible for which data:

• Producer: registers the property and the herd. With respect to the herd's own data, the producer is the controller and we act as the processor — we store and process this data in service to the producer.
• Collaborator: a person the producer invites to work on their property. Has their own account and access limited to what the producer authorizes. The producer sees which entries each collaborator has made.
• Technician: a professional who provides services to properties. Sees the data of the properties they serve, in order to perform the contracted services.
• Association administrator: manages the technicians and producers linked to their association, and sees the data necessary to do so.

With respect to each user's registration data — name, email, phone number, CPF (Brazilian individual taxpayer ID) or CNPJ, billing data — we are the controller.

4. Data We Collect

4.1. Data You Provide to Us

• Full name
• Email address
• Phone number, also used for WhatsApp and for the access code
• Password (stored only as a cryptographic hash; we do not have access to it)
• CPF or CNPJ, when necessary for the subscription, for issuing a tax document, or for official pedigree registration documents
• Address: postal code (CEP), municipality, and state
• Profile photo, if you upload one

4.2. Property and Herd Data

• Name, location, and geographic coordinates of the property
• Animal records: number, ear tag, electronic identification, name, breed, coat color, category, species, sex, dates, genealogy, and pedigree registration
• Management, reproduction, weighing, measurement, milk production, health, nutrition, cost, and movement entries
• Photos of animals, ear tags, exams, and documents that you attach
• Technical visits, services performed, and their results

Most of this data concerns animals, not people — but it remains linked to your account and your property, and for that reason we handle it with the same care we give to personal data.

4.3. Data Collected Automatically

• IP address
• Device identifier and notification-delivery token (Firebase Cloud Messaging token)
• Operating system, system version, and device model
• Installed application version
• Browser type and version, on the web version
• Error and synchronization logs, to find out why something failed on your device
• Date and time of access and of entries, with authorship — this is what lets the producer know who entered what

4.4. Device Permissions

None of these permissions is mandatory to use the Service, and every one of them can be revoked at any time in your device settings. What we are unable to do without each one:

• Camera: photographing animals, ear tags, exams, and documents, and using photo-based record reading.
• Photo gallery: attaching images already on your device and saving to it the reports and photos the app generates.
• Precise location: recording the coordinates of the property and of the technical visit. It is only read while the app is open and in use — we do not track your location in the background, and we do not build a history of your movements.
• Microphone and speech recognition: filling in fields by dictation instead of typing. Recognition runs on the device itself; the audio is not recorded or sent to any server, ours or a third party's.
• Notifications: alerting you about expected births, drying-off, vaccination, visits, and billing.
• Install apps (Android only): applying the Sistema Seabra update from within the app itself, without going through the browser. Used only to install Sistema Seabra.

4.5. What We Do Not Collect

• We do not have an advertising SDK or a third-party tracker inside the app.
• We do not use Google Analytics, Firebase Analytics, Meta Pixel, or the equivalent inside the application.
• We do not store credit card numbers — payment processing is handled by Asaas (section 7).
• We do not collect sensitive personal data within the meaning of Article 5, II of the LGPD: racial origin, religious belief, political opinion, union membership, health data, sex life, or genetic or biometric data of individuals.
• We do not record audio or video in the background.

5. Why We Process Your Data (Legal Bases — Article 7 of the LGPD)

5.1. Performance of the Contract (Article 7, V)

Creating and maintaining your account, authenticating access, storing and synchronizing the herd, generating reports, issuing documents, processing the subscription and billing for it, providing support, and notifying you of herd events that the Service has undertaken to notify you about.

5.2. Compliance with a Legal or Regulatory Obligation (Article 7, II)

Issuing tax documents, retaining accounting and access records for the periods required by law, and complying with orders from a competent authority.

5.3. Legitimate Interest (Article 7, IX)

Understanding how the Service is used in order to fix defects and improve the product, prevent fraud and abuse, ensure account security, and administer the Service. Always limited to what is necessary, and always weighed against your rights.

5.4. Consent (Article 7, I)

Access to the camera, gallery, location, and microphone; sending marketing communications; and use of the artificial intelligence assistant. You can withdraw your consent at any time, without affecting what was already done while it was in effect.

5.5. Credit Protection (Article 7, X)

Verifying the status of your subscription and conducting the collection of amounts owed.

6. Artificial Intelligence Assistant

Sistema Seabra has an assistant that answers questions about your herd. It deserves its own section because it is the point at which your data leaves our infrastructure.

• What is sent: your question and the herd data necessary to answer it — for example, the list of animals, lactations, weighings, or management entries related to what you asked.
• Where it goes: to the language-model service Gemini, by Google LLC, on servers located outside Brazil.
• What is stored: the conversation history is kept in our database, linked to your account, so that you can resume it.
• What is not sent: we do not send your password, your CPF, or your payment data to the assistant.
• How to avoid using it: the assistant only receives something when you write to it. If you never open the assistant, none of your data is sent through this channel.

A response from an artificial intelligence assistant may contain errors. It does not replace the judgment of a veterinarian or an animal scientist, and decisions on management, health, and reproduction remain yours.

7. Who We Share Data With

We do not sell personal data, and we do not provide it for third-party advertising. We share only what is necessary, and only with:

7.1. Processors That Provide Services to Us

To operate, Sistema Seabra depends on companies that process data on our behalf, following our instructions and under a contractual obligation to protect what they receive. Today, these are:

• Hosting, database, and authentication — Supabase Inc. This is where your data is stored.
• Mobile notifications — Google LLC (Firebase Cloud Messaging), which receives an identifier for your device.
• Artificial intelligence assistant — Google LLC (Gemini), as described in section 6.
• Subscription and payment — Asaas, which receives your name, CPF or CNPJ, email, phone number, and payment data. The card number is handled by Asaas, not by us.
• WhatsApp messages — a server operated by Seabra Solutions itself. The message travels over the WhatsApp network, operated by Meta Platforms, like any other.

Providers change over time. The always-current list is kept at sistemaseabra.com.br/operadores — if the version of the app you have differs from it, the website prevails.

Aside from these processors, we share data with pedigree registration associations, when you issue or look up an official document, and with public authorities, pursuant to a legal requirement or a court order.

7.2. Other Users of the Service

Sistema Seabra is built to be used by more than one person around the same herd. Therefore:

• The collaborator you invite sees the data of your property that you authorize, and you see what they have entered.
• The technician who serves your property sees the data necessary for the service, and the result of the service is recorded in the animal record.
• The administrator of the association you have agreed to join sees the data of your property — this has its own section right below, because it depends on your acceptance and is the broadest data sharing in the app.
• When you share a report, a record, or a spreadsheet generated by the app, you decide who it goes to — and from that point on, the content is with whomever you sent it to.
• When you transfer an animal to another producer (sale, donation), you generate a single-use code and choose what goes along with it: profile, management records, milk control, production, and complete genealogy. Clinical cases, abortions, and the line-by-line breeding history are never transferred. Nothing happens until the other producer enters the code and confirms — and from that point on, the data sent belongs to them.

7.3. When You Accept an Invitation from an Association

An association can invite you to join it. The invitation arrives as a request within the app, and nothing is shared until you accept. Declining has no consequences at all for your account or your herd.

Accepting the invitation is an act of data sharing. From the moment you accept, the administrator of the association will be able to see:

• your registration data — name, email, and phone number;
• the headcount of your herd and the records of your animals;
• your management, weighing, reproduction, and dairy testing entries, with date and authorship;
• the reports and spreadsheets generated from this data, which the association can export outside of the app.

The association uses this data for its own purposes: technical monitoring of its members' herds, official dairy testing, pedigree registration, herd statistics, and any services it offers you. In this processing, the association is the controller of the data it receives and is accountable for it, and we remain the processor. What the association does with this data is governed by its bylaws and its own privacy policy — it is worth reviewing them before accepting.

When your association contributes to your subscription. It can contribute to the cost in two ways: paying the subscription for you or granting a discount to its members. To apply either one, it informs us who its members are.

When it pays for you, it sees that your account is active and what it is covering. When it is a discount, it sees that you use Sistema Seabra — this is what allows the discount entitlement to be recognized. In neither case does it see your payment data: that is handled by the payment provider indicated in section 7.1.

And in both cases, two things do not change: the data of your herd remains yours, and if you leave the association the account remains yours — you start paying the regular price or return to the free plan, without losing anything you have registered.

To disaffiliate, speak with the association or write to sistemaseabra@gmail.com. Disaffiliation ends the association's access to your data from that point forward, but it does not undo what the association has already exported or recorded while the relationship existed.

7.4. Access by Our Team

Our team is able to access your account's data through an internal administrative panel. This is a processing operation, and for that reason it is disclosed here, not hidden:

• What for: providing support when you report a problem, reviewing and correcting data, administering the subscription and billing, and producing, at your request, reports about your own herd.
• Legal basis: performance of the contract (Article 7, V) and legitimate interest in administering the Service (Article 7, IX), always limited to these purposes.
• Who has access: only authorized Seabra Solutions personnel, each with an individual, named account.
• What is logged: administrative actions on accounts and records — deletions in particular — are logged with author, date, and time.
• What we do not do with this access: we do not use this data for any other purpose, we do not sell it, we do not transfer it, and we do not use it for advertising.

8. Use of Your Data to Improve the System and the Industry

We want to use what Sistema Seabra accumulates to improve the application itself and to produce knowledge useful to the Brazilian goat- and sheep-farming industries — production parameters, growth curves, efficiency benchmarks. This section states exactly how far we go and where we stop, because this is precisely the point where a producer has good reason to be cautious.

8.1. Improving the Application

We analyze how Sistema Seabra is used to find out what fails, what no one can find, and what gets stuck, and to develop new features. The legal basis is legitimate interest (Article 7, IX, of the LGPD), and for this purpose the data does not leave our infrastructure.

8.2. Study and Statistics: Only with Aggregated and Anonymized Data

For study, statistics, and product development we work with aggregated and anonymized data — figures that describe the group as a whole, never your individual property. For example: the average production per lactation for a breed, the weight curve for a category, or the distribution of the interval between births.

Regarding this data we make five commitments:

• The name, brand, location, and identification of your property and your animals never appear in any study, publication, industry report, or comparison.
• No figure is disclosed if it would allow a property to be identified. A result is only released once it combines enough properties that none of them is identifiable, and once no single property accounts for the majority of the result. When this threshold is not met, that particular breakdown is simply not published.
• We do not attempt to re-identify whoever is behind an anonymized piece of data, and we contractually require the same of anyone who receives this data from us.
• We do not sell your data, whether aggregated or not.
• You can opt out. Section 8.5 explains how.

Once anonymized in this way, the data ceases to be personal data within the meaning of art. 12 of the LGPD — and for that reason we can keep and use it even after you close your account. What we will not do is call data "anonymized" when it still allows someone to be identified.

8.3. Benchmarks for You and Reports for the Industry

We may show you how your herd compares to the group as a whole, and we may publish industry reports for associations, universities, research institutions, and the technical press. In both cases, the rule in section 8.2 applies: only the group appears, never the individual property. You see your own position; no one sees your property inside the figures of others.

8.4. Research and Studies with Partners

We may take part in studies conducted by universities, institutes, research bodies, and breeders' associations — for example, a study on the performance of a breed. When this happens:

• We provide only what the study needs. In a breed study, this means animal data: genealogy, production, weight, births, and matings. Your name, CPF, phone number, and the name of your property are not included, because they serve no purpose for the research.
• If the study can be carried out with aggregated and anonymized data, that is how it is done.
• If it needs your herd's data in identifiable form, we ask for your authorization first — for that specific study, in the app (Profile → Research Authorizations), stating who is conducting it, for what purpose, and what data is disclosed. You can decline, and you can revoke an authorization you already gave at any time.
• Declining changes nothing. Not in the app, not in your subscription, not in your association.
• A study may be sponsored by a company — in nutrition, health, or genetics. When it is, we disclose who the sponsor is at the time we request your authorization. Sponsorship does not give the company access to your registration data or your herd beyond what the study covers.
• We are not paid to hand over your data. When there is payment, it is for the work of conducting the study.

8.5. How to Opt Out

Turn it off in the app, under Profile → Research Authorizations → "Industry studies and statistics", or write to sistemaseabra@gmail.com asking that your data not be included in aggregated study datasets. We comply and confirm in writing whenever the request is made by email. You do not lose any functionality of the application as a result.

This same request also serves as an objection to processing carried out on the basis of legitimate interest, as provided for in art. 18, § 2, of the LGPD.

9. Where Your Data Is Processed

Our processors — Supabase and Google — process data on servers located outside Brazil, including in the United States. The LGPD permits this international transfer, and it takes place under the contractual clauses and protection guarantees offered by these providers, at a level equivalent to what Brazilian law requires.

10. Data Stored on Your Device

Sistema Seabra works without an internet connection, and to do so it keeps a copy of your data on the device itself:

• A copy of the herd, of the entries, and of the settings, so you can work in the pen without a signal.
• A queue of entries made without an internet connection, which is uploaded as soon as the connection returns.
• Your access credentials, kept in the secure storage of the device operating system (Keychain on iOS, Keystore on Android), not in an ordinary file.

This data stays on your device and is deleted when you uninstall the application. If the device is shared, sign out of your account when you are done.

11. How Long We Retain Your Data

• While your account exists: we keep the data necessary to provide the Service.
• After the account is closed: we delete or anonymize the Personal Data within 90 days, except for what the law requires us to retain.
• Tax and financial data: 5 years, as required by tax legislation.
• Application access logs: 6 months, pursuant to art. 15 of the Marco Civil da Internet (Law No. 12.965/2014).
• Aggregated and anonymized data that does not allow anyone to be identified may be retained for an indefinite period for statistical purposes and to improve the Service.

12. Your Rights (art. 18 of the LGPD)

At any time and at no cost, you can:

• Confirm that we process data about you;
• Access the data we hold about you;
• Correct incomplete, inaccurate, or outdated data;
• Request the anonymization, blocking, or deletion of unnecessary or excessive data, or data processed outside the law;
• Request portability of the data to another provider;
• Request the deletion of data processed on the basis of your consent;
• Find out who we share your data with;
• Revoke your consent and find out what happens if you do not give it;
• Object to processing carried out on the basis of legitimate interest.

What you already do on your own, within the app: correct your registration data on the Profile screen; correct or delete entries and animals from the herd; and export your herd and your reports as a spreadsheet and as a PDF.

What you request from us: a complete copy of your data, deletion of your account, and any of the other rights listed above. Write to sistemaseabra@gmail.com with the subject line "LGPD". We may ask for additional information to confirm that it is really you — this is a protection for you, not an obstacle. We respond within 15 days.

If our response does not satisfy you, you can file a complaint with the National Data Protection Authority (ANPD), at gov.br/anpd.

13. Security

The measures we have adopted:

• All communication between the application and the servers is encrypted in transit (HTTPS/TLS).
• Passwords are stored only as a cryptographic hash — not even we can read them.
• Access to data is restricted at the database level itself through row-level security rules, so that an account can only reach the data it is entitled to.
• Access credentials are kept in the secure storage of the device operating system.
• Our database provider maintains periodic backups.
• Sensitive administrative actions are logged with author, date, and time.

Even so, no system is entirely immune. If a security incident occurs that could cause you significant risk or harm, we will notify you and the ANPD, as required by art. 48 of the LGPD.

14. Children and Adolescents

Sistema Seabra is a work tool and is not intended for anyone under 18 years of age. We do not intentionally collect data from children or adolescents. If we learn that an account was created by someone under 18 without the specific, prominently given consent of at least one parent or legal guardian, we will delete the data. If you are a parent or guardian and have noticed this, write to sistemaseabra@gmail.com.

15. Links and Third-Party Services

The Service may direct you to third-party websites — associations, suppliers, technical material. We do not control these websites and are not responsible for their privacy practices. Read the policy of each one.

16. Changes to This Policy

We may update this Policy. The "Last updated" date at the top always indicates the version in effect. When a change is material — a new purpose, new data sharing, a change in legal basis — we will notify you by email or through a prominent notice within the app before it takes effect.

17. Contact

• Controller: SEABRA SOLUTIONS LTDA — CNPJ 50.132.061/0001-80 — Florianópolis/SC, Brazil
• Data Protection Officer: Felipe Leal
• Email: sistemaseabra@gmail.com
• Website: sistemaseabra.com.br

This Policy is governed by Brazilian law. The courts of the judicial district (comarca) of Florianópolis, Santa Catarina, are elected to settle any disputes arising from it, except where the law guarantees the consumer the right to the forum of their domicile.