[LEGAL REVIEW NEEDED] Unofficial translation for convenience. The Portuguese version prevails in case of conflict.

International availability note: Paid purchases are available only to buyers in Brazil; outside Brazil only the free mode is available (productions carry a watermark). Passages referring to payment, invoicing or purchase-related data apply only to buyers in Brazil. This Notice describes how the Brazilian operator processes personal data under Brazilian law (LGPD); it does not assert compliance with data-protection laws of other jurisdictions.

Partida Privacy Notice

Last updated: July 30, 2026 Version: 1.2 — Brazilian pilot, free phase

This Notice explains how Partida processes personal data during a visit to the site, generation of demos, production, delivery and support.

1. Controller

The controller is Eduardo Lima de Almeida Worrel Consultoria em Tecnologia da Informação, CNPJ No. 51.279.125/0001-33, with its head office at Rua Visconde de Pirajá, 414, room 718, Ipanema, Rio de Janeiro/RJ, ZIP code 22410-905, Brazil.

Privacy channel: [email protected]
General support: [email protected]

2. Data processed

Depending on how the service is used, we may process:

• name, e-mail and contact data;
• account and authentication identifiers;
• IP, date, time, session, browser and security logs;
• PGN, moves, positions, result and game metadata;
• names, usernames, ratings, event and date present in the PGN;
• optional player photos and the record confirming rights and authorizations;
• language, voice and style choices;
• an email address you may optionally provide on the waiting screen, used only to tell you the video is ready: it is deleted from the production record as soon as the message is sent and never becomes a mailing list;
• script, audio, video, thumbnail and intermediate files;
• job status, delivery history and support messages;
• ratings and feedback comments submitted voluntarily;
• encrypted Lichess access token, when you connect your account (deleted upon disconnection);
• consents, document acceptance and rights or removal requests.

3. Purposes and legal bases

We process data to:

• validate the game and produce the requested video;
• deliver the file and provide support;
• limit abuse, protect accounts and investigate failures, on the basis of legitimate interest, fraud prevention, security and the regular exercise of rights;
• respond to requests for access, correction, deletion and removal, to comply with the LGPD (Brazilian General Data Protection Law) and other obligations;
• publish a video in the gallery, only when selected and legitimately authorized or grounded;
• send promotional communication, only when there is an adequate legal basis and a possibility to unsubscribe.

When we rely on legitimate interest, we will limit processing to what is necessary, consider the expectations of data subjects and adopt safeguards.

Optional photos are processed to perform the requested production and add the visual identification selected by the user. The rights and authorization confirmation is recorded to prevent abuse and for the regular exercise of rights. Authorization to use a person's image remains the uploader's responsibility, without prejudice to the depicted person's rights.

4. Visitors without an account

A generation without an account may use IP, session and technical signals to impose limits and prevent spam. These data will not be used for behavioral advertising.

The anonymous project, including video and intermediate files, will normally be deleted within 48 hours. An access record that must be kept due to a legal obligation may remain for the applicable period, separate from the project content.

A temporary link may allow the visitor to associate the video with an account. The token expires with the project or after its first use.

5. Use of artificial intelligence

To create the script, Partida prepares a sanitized version of the game. We seek to remove:

• names and usernames;
• links and game identifiers;
• event, location, date and round;
• federation, club and account IDs;
• comments and data that are not necessary to the narrative.

The players are replaced with "Player A" and "Player B". Mainly moves, positions, evaluations and language and style instructions are sent. The names may be reinserted on Partida's server after the script is returned.

We currently use MiniMax to assist in generating the script. The supplier processes the data according to its own terms and policies. Partida does not use customer content to train a model of its own during the pilot. The updated list of suppliers is available at https://www.partida.live/fornecedores.

To produce the voice, we send ElevenLabs the final narration text and receive the synthetic audio. If the video narrates names or usernames, this information will be in the text sent to ElevenLabs, even if it was removed from the payload previously sent to MiniMax. We do not use this flow to clone the voice of the user or of players.

Player photos are not sent to MiniMax or ElevenLabs. Before storage in the job, they are cropped, reduced, converted to WebP and saved without EXIF metadata. The renderer receives only this normalized version.

6. Sharing

We may share strictly necessary data with:

• Clerk, for account creation, login, session, verification and authentication security;
• MiniMax, for generation of the sanitized script;
• ElevenLabs, to convert the final narration text into audio;
• hosting provider Guará Cloud (region br-gru, São Paulo, Brazil), to run and store jobs and videos;
• chess analysis supplier, which receives board positions without player names;
• TikTok, only when you connect your account and ask for one of your videos to be published: it receives the video and the caption you decided to publish;
• e-mail, support, accounting and security providers, when contracted;
• public authorities, upon a legal obligation or valid order;
• legal and technical advisors, when necessary to the exercise of rights.

We do not sell personal data.

7. International transfer

Clerk, MiniMax, ElevenLabs or other suppliers may process data outside Brazil. In such cases, we will adopt applicable mechanisms and safeguards, limit the content sent and maintain transparency about the recipients.

8. Cookies

During the pilot, we intend to use only cookies and local storage that are strictly necessary for session, security, production progress and essential preferences.

In addition to those, we use local storage for audience measurement: a random browser identifier and a visit identifier, the latter expiring after 30 minutes of inactivity. They are used to count how many distinct people visit the site, which pages are viewed and where traffic comes from. They are not cookies, they do not follow you across other websites and they do not feed advertising.

We will not use advertising or behavioral tracking cookies without updating this Notice and, when necessary, requesting consent. Visitors browsing with the "Do Not Track" signal enabled are not measured.

9. Retention

We initially adopt the following periods:

• anonymous project: up to 48 hours;
• intermediate files of a completed production: up to 7 days;
• normalized photos: follow the retention period of their project and are deleted with it;
• account and library: while the account remains active or until a valid deletion request;
• access records subject to the Marco Civil (Brazilian Internet Framework Act): applicable legal period, as a rule six months;
• records of acceptance and exercise of rights: applicable legal and defense periods;
• record of a security incident involving personal data: at least five years, when required.

Backups may retain copies for a limited technical cycle. During this period, deleted data will not be reused in ordinary operation and will be eliminated or overwritten according to the rotation.

10. Private, unlisted and public videos

• Private: accessible only in an authenticated environment, when available.
• Unlisted: accessible to whoever holds the link or QR code; must not be shared with anyone who should not see it.
• Public: indexable and displayed publicly after a specific decision.

In the pilot, customer videos are private or unlisted by default. The public gallery is administered by Partida. An identified person may request review, correction or removal.

11. Children and adolescents

Account creation is intended for persons aged 18 or older. A legal guardian may request a video referring to a minor's game.

We do not automatically publish a minor's video nor use minors' data for behavioral advertising. Guardians' requests and situations of possible risk to children or adolescents will be prioritized.

12. Security

We adopt proportionate measures, including access control, administrative authentication, protection of secrets, non-sequential links, request limiting, file isolation, logs and scheduled deletion. No system is absolutely immune to incidents.

When an incident may cause relevant risk or harm, we will follow the applicable obligations of assessment, recording and communication.

13. Your rights

You may request:

• confirmation and access;
• correction;
• information about sharing;
• anonymization, blocking or deletion when applicable;
• revocation of consent;
• objection to irregular processing;
• review of a relevant automated decision;
• deletion of account and videos;
• correction or removal of a video that identifies you.

Send the request to [email protected]. To protect data subjects, we may request proportionate information to confirm the identity or legitimacy of the requester. The exercise of rights is free of charge.

14. Changes

This Notice will be updated when suppliers, features, purposes or applicable rules change. Relevant changes will be highlighted on the site. The version history will be preserved.