SINERGIA OS · CONTROLLED BETA

SINERGIA OS Privacy Policy

Controlled beta privacy policy

Effective Date: July 21, 2026
Last Updated: October 11, 2026

Overview

This Privacy Policy explains how Sigue Tu Imaginacion LLC, doing business as SINERGIA OS ("SINERGIA," "we," "us," or "our"), collects, uses, discloses, and retains personal information through the SINERGIA OS websites, authenticated artist studio, Artist DNA, PULSO / PULSE, FANBASE, SUBELO! / UPLOAD!, .WAVES, GIA Context, Gia, and related services (collectively, the "Service").

This Policy is intended to function as our general privacy notice and, where applicable, our notice at collection. It does not cover a third party’s independent practices.

Privacy Commitments

• Unreleased music and Artist Content are private by default.
• We use uploaded content only to provide the workflows you request, secure and support the Service, and comply with law.
• We do not sell personal information or share it for cross-context behavioral advertising.
• We do not use private songs, lyrics, metadata, Artist DNA, or reports to train general-purpose AI models or SINERGIA models without a separate affirmative opt-in.
• Under the current beta design, raw audio is not sent to general-purpose language models.
• You may request access, correction, export, or deletion of your personal information, subject to lawful exceptions.

1. Information We Collect

Account and authentication information. Email address, name, authentication method, internal account and studio identifiers, authentication-provider and connected-login identifiers, session information, and account-security events.

Artist and studio information. Artist or team name, profile image, location or market, biography, genres, links, external music-profile and catalog identifiers, social profiles, Artist DNA, preferences, goals, creative direction, catalog history, collaborators, and other context you choose to provide.

Artist Content. Audio files, masters, lyrics, artwork, metadata, release details, notes, tags, reports, approval information, private share links, reviewer and collaborator responses and comments, and messages or attachments submitted to Gia. Artist DNA can include private drafts, finalized transcripts, approved entries, snapshots, and revision history. GIA Context can include public-source summaries, corrections, and artist-approved memory.

FANBASE audience and contact data. When an artist imports a list, we collect submitted rows and source information, such as names, email addresses, phone numbers, wallet addresses, location, list/source labels, purchase or spending history, engagement information, and any consent or preference fields the artist includes. We also create source records and derived, deduplicated FANBASE records needed to present the feature within that artist’s studio.

Usage and device information. IP address, browser and device type, operating system, pages or features used, dates and times, diagnostic events, performance data, security logs, and cookies or local-storage identifiers needed for authentication, preferences, and operation.

Applications and communications. Waitlist or Imagine application information, support requests, survey answers, feedback, and communications with us. In-studio feedback includes the message and current studio page, but does not automatically attach your music, lyrics, or conversation. Applications, support messages, and feedback may also be delivered to our restricted email inbox.

Billing information. When you buy a membership, our payment processor collects your payment details directly; we do not receive or store full card numbers. We keep your billing email, payment-customer and subscription identifiers, plan, subscription status, and records needed to administer charges, refunds, and billing support.

Information from integrations and public sources. When you connect or identify an artist profile, we may receive profile, catalog, audience, streaming, social, or activity information from connected music-data services, login providers, and other sources you direct us to use. Identifying a public music profile is separate from authorizing access to a private third-party account. After you confirm a matching public artist profile, we may also automatically search and read up to three public web pages—such as interviews, press coverage, and public artist profiles—to prepare source-backed artist-context suggestions. Choosing to continue with an entered name without a matching public profile does not start this automatic discovery. Public-source suggestions remain editable and removable and are excluded from GIA and shared studio intelligence until you confirm them.

We do not use uploaded recordings to identify you through biometric voice recognition. Please do not submit government identifiers, full financial-account credentials, health records, or other highly sensitive information unless a feature specifically requests it and provides an appropriate notice.

2. Sources of Information

We collect information directly from you and authorized team members, automatically from your use of the Service, from providers that support the Service, and from integrations or public artist sources you connect or identify.

3. How We Use Information

We use personal information to:

• create and authenticate accounts;
• establish internal artist and studio identities;
• provide Artist DNA, catalog, release-preparation, analytics, sharing, approval, and assistant features;
• store, transcode, transcribe, analyze, and organize Artist Content at your request;
• provide FANBASE by storing, organizing, analyzing, deduplicating, and privately displaying imported audience and contact data within the importing artist’s studio;
• personalize the Service using artist-approved context;
• retrieve and normalize connected artist, catalog, audience, and activity signals;
• discover, summarize, and suggest editable artist context from a bounded set of public sources after a matching public profile is confirmed;
• generate editable lyrics, metadata, descriptions, reports, and suggested next steps;
• operate, test, monitor, troubleshoot, secure, and improve the beta;
• respond to support, privacy, and legal requests;
• send account, security, billing, and beta communications;
• send weekly studio summaries to your verified sign-in email while that preference is enabled, and application or waitlist updates you requested;
• prevent fraud, abuse, infringement, and unauthorized access; and
• comply with law and enforce our Terms.

We may use aggregated or de-identified information for product analytics, reliability, research, and planning where it cannot reasonably be linked back to you. We do not attempt to re-identify de-identified information.

We keep limited first-party studio journey events for 90 days to understand whether artists reach useful outcomes. These events contain controlled feature and milestone names rather than music, lyrics, or fan-contact records. When our limited external product-measurement pilot is enabled, the measurement service receives selected milestones, a pseudonymous studio ID linking visits over time, and a random session ID used to prevent duplicate events. We do not send names, email addresses, music, lyrics, filenames, or page URLs in that pilot. Studio-linked measurement is pseudonymous, not anonymous. We enable the pilot only after verifying its deletion workflow.

Weekly studio summaries use saved studio signals, approved Artist DNA focus, aggregate FANBASE counts, catalog or preparation counts, and available recording-revenue estimates. They do not contain fan contacts, lyrics, private audio, or conversation transcripts. You are enrolled when a verified sign-in email is available; you can turn summaries off in Settings or through the unsubscribe link. Your email service may fetch public brand or profile images from their hosts when displaying a message. Essential account, security, billing, and privacy messages may still be sent after you opt out of optional updates.

4. Legal Bases Where Applicable

Where European Economic Area, United Kingdom, or similar law requires a legal basis, account setup, requested storage, analysis, and studio tools are processed to perform our contract with you. Our legitimate interests include proportionate security, fraud prevention, reliability, support, and product evaluation, subject to your rights and reasonable expectations. We process billing and legal-request records where necessary to comply with legal obligations. We rely on consent for optional processing where required, including any separately offered model-training permission. You may withdraw consent at any time without affecting earlier lawful processing, and may object to processing based on legitimate interests. Providing information required for an account or requested feature is necessary to provide it; optional fields can be left blank.

We act as the controller for account information and our own service operations. For personal information you import into FANBASE, the importing artist or organization determines the purposes and acts as controller, and SINERGIA processes it on their behalf to provide the feature. Applicable data-processing arrangements are separate from this general privacy notice.

5. Audio Processing and AI Assistance

Uploaded songs and artwork use private storage. Audio-processing and speech-to-text services receive recordings needed for the feature you request, including song transcription and short voice notes. Text, transcripts, metadata, selected artist context, and prompts may be sent to AI services for editable suggestions and Gia replies. Raw audio is not sent to general-purpose chat language models; this does not mean that audio avoids specialized speech or audio-processing services.

Live voice conversations are interactions with AI, not a human. ElevenLabs, its affiliates, and its service providers, including OpenAI for the selected language models, process speech, transcripts, selected studio context, and replies to provide Gia or Artist DNA voice when available. Call audio is not recorded in the current live-conversation configuration. During the prelaunch review period, Gia’s voice processor may retain transcripts and automated conversation summaries for up to 30 days for quality review and troubleshooting. The restricted Artist DNA voice-testing configuration may retain provider transcripts for up to one day. These provider periods are separate from finalized text, drafts, and conversation history saved in your SINERGIA studio, which remain while your account is active unless removed through an applicable deletion process. Recorded-and-submitted voice notes are a separate feature; their temporary SINERGIA audio copies are deleted after processing, with a 24-hour cleanup backstop for abandoned uploads.

SINERGIA does not use private Artist Content to train its models or general-purpose AI models, or authorize processing providers to do so, without a separate affirmative opt-in. We use applicable no-training settings, contractual protections, or an alternative processing path to honor this commitment. Permission to process a recording for transcription or analysis is not permission to train a model on it. Operational processing and retention for service delivery, safety, and troubleshooting are separate from model training.

Automated analysis may produce estimates and suggestions, but SINERGIA does not use it to make decisions that produce legal or similarly significant effects about you. Important creative and release information remains subject to your review and approval.

6. How We Disclose Information

Service providers. We disclose only information reasonably needed for the following functions: account identifiers and session information for authentication; studio records and private files for hosting, databases, storage, and audio processing; selected prompts, text, and context for AI assistance; billing details for payments; recipient addresses and message content for email delivery and support; and limited device, security, or milestone information for bot prevention, diagnostics, and product measurement. Public-source discovery services receive the artist identity and public links needed for the requested search. These providers process information under applicable service and data-protection agreements. The specific voice-service disclosure is in Section 5. Contact us for recipient information required for a privacy request or applicable data-processing arrangement.

Integrations and user-directed recipients. We disclose information to connected services, authorized team members, collaborators, reviewers, and other people when you direct us to do so. Working review and split-approval links can be opened and forwarded without a recipient account and expire according to the selected period. A .WAVES song-profile link stays active until you stop sharing and displays saved song and composition metadata, artwork, artist identity, and public listening links. It excludes your stored master, private notes, and contact records, but may show contributor names, ownership credits, and composition shares. Messaging services may receive song titles, artist names, and artwork to create link previews. Stopping sharing does not remove copies or previews already obtained.

Legal, safety, and rights protection. We may disclose information when reasonably necessary to comply with law or valid legal process; protect users, artists, rights holders, SINERGIA, or the public; investigate fraud, security incidents, or abuse; or establish, exercise, or defend legal claims.

Business transactions. Information may be transferred as part of a financing, merger, acquisition, reorganization, bankruptcy, or sale of assets. We will require the recipient to honor this Policy for existing personal information and will provide notice where required.

7. No Sale or Targeted Advertising

During the controlled beta, SINERGIA does not sell personal information and does not share personal information for cross-context behavioral advertising. We do not use private Artist Content for targeted advertising. If these practices ever change, we will update this Policy and provide legally required choices before the change applies.

8. Cookies and Similar Technologies

We use cookies, local storage, and similar technologies for authentication, session management, security, and saved preferences. Limited performance, diagnostic, and product measurement is described in Section 3 and is assessed separately from storage essential to sign-in and security. The controlled beta does not use third-party targeted-advertising cookies. You can control cookies through your browser, but disabling essential storage may prevent login or core features from working. We do not currently change these essential operations in response to a browser’s Do Not Track signal. We do not authorize advertising partners to track your activity across other sites through the Service. Global Privacy Control is an opt-out signal for sale or sharing where applicable; we do not sell or share personal information for those purposes. Any future non-essential tracking must be assessed for applicable notice, consent, and opt-out requirements before it is enabled.

9. Retention and Deletion

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including providing the Service, maintaining security, resolving disputes, and meeting legal obligations.

The beta retention periods and criteria are:

• Account, Artist DNA drafts and revision history, saved Gia conversations, approved memory, catalog, sharing and approval history, and other studio records: while your account is active unless an applicable deletion process removes them sooner. Re-recording or restarting Artist DNA can archive previous material rather than erase it.
• Public-source URLs, concise summaries, provenance, review state, and bounded discovery-operation records: while your account is active, unless removed sooner through an available feature.
• Private masters and artwork, including archived catalog songs: while your account remains active, unless removed through a verified deletion request. Archiving and removing a song from the upload queue are not permanent deletion. Reports and delivery archives are generated on demand rather than kept as a separate report history.
• FANBASE audience and contact data: while the imported source remains in the artist’s studio, until the source is removed or the account is closed. Removing a source removes its associated source data and FANBASE views that are no longer supported by another active source, subject to the backup, security, legal, and dispute-retention periods below.
• Verified deletion requests: active copies removed within 30 days where technically feasible.
• Temporary SINERGIA voice-note audio: deleted after processing, with a 24-hour cleanup backstop for abandoned uploads. Other temporary processing files and routine analysis artifacts: normally removed within 30 days after the job completes. Live-voice provider transcript periods are described in Section 5.
• First-party beta journey events: 90 days. Weekly email delivery records: a 90-day purge window while the delivery worker is enabled; disabling it pauses that purge. Pending email content is cleared after acceptance or opt-out, or when the enabled worker next abandons an expired attempt.
• Short-lived catalog candidates and provider caches: applicable seven-, 30-, or 90-day reuse windows; expiry prevents reuse but may precede physical cleanup. These caches are separate from saved artist catalog records.
• Other residual provider backup copies: may remain for up to 90 days before routine overwrite or expiration.
• Terms acceptance records: retained while your account is active and for up to 24 months after account closure. Live AI voice consent records: retained for five years after confirmation. These limited records contain an internal account identifier, the notice versions, language, and confirmation time; they do not contain audio or conversation transcripts. We may retain records longer when a documented legal hold or applicable law requires it.
• Other security, support, and legal records: generally up to 24 months after account closure, or longer when reasonably necessary for fraud prevention, disputes, tax, accounting, or legal obligations.

If the external product-measurement pilot is enabled, its event retention is separate from the internal 90-day journey window. The currently evaluated plan retains events and metadata for at least one year; one year is not an automatic deletion deadline. Verified account-deletion requests must also remove the linked external studio profile and request deletion of its events, subject to asynchronous processing.

Deletion may not immediately remove information already shared with recipients at your direction. We may retain de-identified information that can no longer reasonably identify you.

10. Security

We use reasonable administrative, technical, and organizational safeguards designed for the nature of the beta, including access controls, private storage, server-side credentials, encrypted network connections, logging, and provider security controls. No method of storage or transmission is completely secure, so we cannot guarantee absolute security.

You can help by protecting your devices, login methods, and private share links and by notifying us promptly of suspected unauthorized access.

11. Your Choices and Privacy Rights

Depending on your location, you may have the right to request access to, correction of, deletion of, or a portable copy of your personal information; object to or restrict certain processing; withdraw consent; and appeal a denied request. You may also edit available profile fields, archive or restore songs, remove FANBASE imports, revoke review or approval links, stop song-profile sharing, disconnect supported integrations, and turn off weekly studio emails. Song archiving is reversible and does not delete the stored files. Request permanent content deletion through support when no in-product deletion control is available.

For personal information an artist imports into FANBASE, the importing artist remains responsible for their relationship with the people in the list and for their own notices and permissions. A person seeking to exercise applicable rights regarding FANBASE data may contact the importing artist or support@sinergiaos.com. We will handle or assist with verified requests consistent with applicable law and our role in providing the Service.

Submit a request to support@sinergiaos.com or use the available privacy controls in your studio. The in-studio export includes your profile, approved Artist DNA, catalog metadata, masters, and artwork; for other information, such as Gia conversations, Artist DNA draft history, or FANBASE data, email support@sinergiaos.com. Account deletion is support-assisted during the controlled beta: after you verify the request, a founder reviews the exact account and file manifest before removal. Authorized support access is limited to what is needed to resolve a request or incident and is handled through restricted operator tools. We may verify your identity and authority before acting. You do not need to create an account to email a privacy request. An authorized agent may submit a request where permitted by law. We respond within the deadline required by applicable law; where the EEA or UK one-month response period applies, or a U.S. state provides a different period, that legal deadline governs. We will explain a denial or an allowed extension and how to appeal. To appeal, reply to our decision or email support@sinergiaos.com with “Privacy appeal” in the subject. You may also complain to the privacy regulator responsible for your location. We will not discriminate against you for exercising a privacy right. Some information may be retained or withheld where an exception applies, such as security, fraud prevention, legal compliance, another person’s rights, or establishment of legal claims.

12. California and Other U.S. State Rights

Where applicable, residents of California and certain other U.S. states may have rights to know or access personal information, correct inaccuracies, delete information, obtain a portable copy, opt out of sale, sharing, or targeted advertising, limit certain uses of sensitive information, and appeal a decision.

The categories described in Section 1 may include identifiers; internet or network activity; professional, commercial, and artist-profile information; audio, visual, and creative content; and inferences or preferences supplied through Artist DNA. We use and disclose these categories for the purposes and recipients described in Sections 3 and 6.

We do not sell these categories or share them for cross-context behavioral advertising, do not offer financial incentives in exchange for personal information, and do not use sensitive personal information beyond purposes reasonably necessary to provide, secure, and support the Service.

13. International Users and Transfers

SINERGIA is operated from the United States. Information may be processed in the United States and other countries where our providers operate. Those countries may have different privacy laws from your location.

Where required, we rely on recognized transfer mechanisms, contractual protections, provider commitments, or another lawful basis for international transfers. Residents of the EEA or United Kingdom may also lodge a complaint with their local data-protection authority.

14. Children

The controlled beta is intended only for people who are at least 18 years old. We do not knowingly collect personal information from children. If you believe a child has provided personal information, contact support@sinergiaos.com so we can investigate and delete it where appropriate.

15. Third-Party Services and Links

The Service may link to or integrate with third-party services. Their privacy practices are governed by their own notices, not this Policy. Review those notices before connecting an account or sending information to a third party.

16. Changes to This Policy

We may update this Policy as the Service, processing arrangements, or legal requirements change. We will post the revised Policy and update the effective date. We will provide reasonable notice of material changes and seek separate affirmative consent before using private Artist Content for model training or another materially different purpose that requires consent.

17. Contact

Controller/operator: Sigue Tu Imaginacion LLC, doing business as SINERGIA OS
Privacy email: support@sinergiaos.com
Support email: support@sinergiaos.com
Business location: Osceola County, Florida 34746, United States
Legal notices: support@sinergiaos.com