Privacy Policy

Version 1.1 · effective 24 September 2026

The short version. SplitChat JM runs entirely on your computer Your conversations, your contacts and your attachments never reach us, not encrypted, not aggregated, not by accident: there is no code path in the program that sends them anywhere. Only two things talk to a server of ours: the activation request (your purchase email and a random code for the computer) and support (the message you write). The AI, if you turn it on, goes straight to the provider you chose, using your own key.

1. Who is responsible

SplitChat JM is developed and sold by JM PRODUÇÕES MUSICAIS LTDA, registered in Brazil under company number (CNPJ) 53.016.181/0001-00, (legal entity details to be completed), based in Brazil ("we"). This is the controller for the purposes of the GDPR and the Brazilian LGPD. For anything involving personal data, including the rights listed in section 6, write to privacy@appsjm.com.br. We answer within 30 days (15 days under the LGPD).

We do not meet the thresholds that require an EU representative under Art. 27 GDPR or a Data Protection Officer under Art. 37. If that changes, this page changes with it.

2. The distinction that explains everything

This policy covers two very different things:

The application you install. It behaves like a dedicated browser: it opens the official web interface of the messaging service inside its own window and keeps each session separate. Everything it stores lives on your computer's disk, under your operating-system user account.
The website and the purchase. Here third parties genuinely are involved - whoever hosts the page and whoever processes the payment, and personal data is processed by them.

With respect to the content of your conversations we are neither controller nor processor: that data never passes through us. We are a controller only for the purchase, activation and support data described in sections 4.3 and 5.

3. What the app stores on your computer

What	Where	How
Sessions for the connected accounts (cookies, cache, the service's local database)	The app's data folder, one isolated subfolder per account	In the service's own format, inside your OS user account
Conversation colour tags	Inside each account's own session	In the same protected area the service uses for its own data
Notes from the side panel	The app's data folder (`notas.enc`)	Encrypted via the macOS Keychain, Windows DPAPI or the system keyring on Linux (GNOME Keyring or KWallet). On Linux with no keyring configured, the file is written with owner-only permission and no cipher
Your AI API key	The app's data folder (`ai-key-*.enc`)	Encrypted by the same operating-system mechanism
The photos you set for each account	The app's data folder (`avatars/`)	A copy of the file you uploaded, owner-only permissions
Language, theme, pane proportions	The app's data folder (`prefs.json`, `layout.json`)	Plain text, no personal data here
Files received in conversations	The folder you chose for each account	Like any other download of yours

The encryption above uses a key managed by the operating system and bound to your user account. In practice: copying those files to another computer does not make them readable. It does not protect against someone already logged in as you on your own machine, that is what your account password and full-disk encryption (FileVault on macOS, BitLocker on Windows, LUKS on Linux) are for, and we recommend keeping both on.

How to erase everything

Inside the app: Settings → Privacy → Erase everything. It disconnects both accounts and deletes notes, tags, photos, layout and the AI key from that computer. It is irreversible and it does not go through us, you never need anyone's permission to exercise that right.

4. When something does leave your machine

4.1 The messaging service

The app connects you directly to the service's official web interface, exactly as your browser would. Traffic flows between your computer and Meta Platforms, Inc., under their privacy policy, with no intermediary of ours.

4.2 The AI (optional, and only when you press the button)

The AI feature is off until you configure a key. When you press "What still needs a reply" or "Ask your AI", the app sends to the provider you chose, using your key:

the names of the conversations in question and each one's last-message preview;
the text of the request you typed, where applicable.

No attachments, no audio, no images, no phone numbers and no conversation history. The request goes from your computer straight to the provider: there is no server of ours in the path and we have no way of seeing that query.

By default the app also replaces contact names with aliases ("Contact 1", "Contact 2"…) before sending, and restores the real names in the answer on your machine. With that option on, the factory default, the AI provider receives the subject matter without learning who you talk to. The replacement covers each conversation's name and occurrences of that name inside previews; a name written by someone else in the body of a group preview can slip through, so it is fair to call this protection strong rather than absolute.

Before the first request the app shows this explanation and requires your express agreement, this is your consent under Art. 6(1)(a) GDPR / Art. 7, I LGPD. You can withdraw it at any time by deleting the key in Settings. Processing by the chosen provider follows their own policy. Google, OpenAI or Anthropic, and we recommend reading it before enabling the feature.

4.3 Activation by email and support (the only contact with a server of ours)

The app has a single server of ours, and it is only called at two moments:

Activation request. When you type your purchase email, the app sends that email, a random code the app generates itself the first time it opens (not a hardware ID, not the computer's name, nothing that identifies you), the app version and the operating system (for example, "macOS arm64"). We check the purchase on the payment platform and approve it by hand. Once activated, the app checks once a day, when online, that the activation is still valid, sending only the request number and that same code. Offline, it keeps working.
Support. When you use the support form inside the app, it sends the name, email and message you wrote, plus the app version and operating system. The server only forwards this to our email; the message is not stored on it.

The server keeps activation requests (email, computer code, version, system, date and status: open, approved, declined or revoked). An unanswered request is deleted automatically after 60 days; an approved one is kept for as long as the activation is valid. The IP address of whoever calls the server is used only to limit abuse (at most 12 calls a day) and is gone in a little over 24 hours.

4.4 What never leaves

There is no telemetry, no analytics, no automatic crash reporting, no install ping and no usage counting of any kind. Apart from the activation request and support described above, the app opens no connection to any server of ours, and not even those two carry a conversation, a contact, an attachment or anything you do on WhatsApp. Cleartext (http://) requests are blocked inside the app.

5. The website and the purchase

Data	Purpose	Legal basis	Retention
Name, email and payment details entered at checkout	Process the purchase, deliver the file, issue the receipt	Contract (Art. 6(1)(b) GDPR) and legal obligation (Art. 6(1)(c))	As long as tax law requires
Purchase email, random computer code, version and system, sent in the activation request	Check the purchase, activate the app on that computer and be able to revoke it after a refund or fraud	Contract (Art. 6(1)(b) GDPR)	Open request: up to 60 days. Approved: while the activation is valid. You may ask for erasure at any time (the app returns to the trial period)
Messages you send us through the app's support form, by email or WhatsApp	Answer you and provide support	Contract and legitimate interest (Art. 6(1)(f))	Up to 2 years after the last contact
Technical access logs (IP, timestamp, page)	Security and operation of the hosting	Legitimate interest (Art. 6(1)(f))	6 months

This website uses no advertising cookies, no tracking pixels and no analytics tool. There is no profiling and no automated decision-making. We do not sell, rent or share your data with anyone for their own marketing.

Third parties involved

Payment platform (Hotmart or equivalent), processes the card and delivers the file. Acts as our processor and, for payment data, as its own controller.
Website hosting (Vercel, Inc. or equivalent), serves the pages and keeps technical access logs.
Activation and support server (Cloudflare, Inc.), receives and stores activation requests, as described in 4.3.
Email delivery (Resend, Inc.), delivers to our inbox the notice of each activation request and the support messages.
AI provider, only if you enable the feature, and only with your key, as described in 4.2.

Some of these providers are outside the EEA and the UK. Those transfers rely on the Standard Contractual Clauses adopted by the European Commission, together with the providers' own supplementary measures; under the LGPD they rely on Art. 33, I, II and IX. A copy of the relevant safeguards is available on request.

6. Your rights

At any time and free of charge you may:

ask whether we process any data about you and request access to it;
have inaccurate or incomplete data corrected;
request erasure, restriction or anonymisation;
request portability of your data;
object to processing based on legitimate interest;
withdraw consent, for the AI, that is immediate and entirely in your hands: delete the key in the app;
lodge a complaint with your supervisory authority (your national DPA in the EU/UK, or the ANPD in Brazil).

Write to privacy@appsjm.com.br. Bear in mind that the content of your conversations is not with us: to erase it, use the button inside the app, which does it immediately.

7. Children

The product is sold to adults. We do not knowingly collect data from children. If you believe this has happened, write to us and we will delete it.

8. Security

We maintain the measures described in this policy: a server used only for activation and support, activations signed with a key that only the server holds, local encryption of what is sensitive, isolation between accounts, cleartext traffic blocked, a restrictive content-security policy on the application window, and no telemetry whatsoever. No system is perfect; should we identify an incident carrying material risk, we will notify affected individuals and the competent authority within 72 hours (Art. 33 GDPR) and as required by Art. 48 LGPD.

Found a flaw? Write to privacy@appsjm.com.br before disclosing it. We are grateful for, and give credit to, responsible reports.

9. Changes

If this policy changes, the date at the top changes with it and the previous version stays available on request. Any change that widens what leaves your machine will be announced inside the application and will not take effect without your agreement.