Politique relative au droit d'auteur et au retrait de contenu

Table of contents#

1. Scope
2. Where to send a notice
3. General rules for all notices
4. United States: DMCA notices
5. United States: DMCA counter-notices
6. Repeat infringer policy
7. Brazil: extrajudicial notices (Marco Civil and STF Themes 987/533)
8. Brazil: intimate images (Marco Civil, art. 21) and content harmful to minors
9. European Union: notice and action under the Digital Services Act
10. Non-consensual intimate images anywhere (48 hours)
11. Voices and likeness (48 hours)
12. Trademark complaints
13. What happens after a decision: statements of reasons and complaints
14. AI-generated content and translations
15. Misuse of this process
16. Records and transparency

1. Scope#

1.1 What this Policy covers. This Policy applies to content that users upload, store, share or generate through SonhoLab's Services. That includes Customer Data and User Content, as defined in the Terms of Service. Examples are:

• files and records in a System;
• messages in public or shared areas;
• voice samples and voices in the Hades shared voice library;
• job postings;
• pages published under an Organization's slug or custom domain;
• AI outputs that a user requested and shared.

1.2 What it does not cover. Other requests have their own channels:

• For requests about your own personal data (access, deletion, correction), use Your Privacy Rights and How to Exercise Them.
• For requests from governments and law enforcement, see Government and Law Enforcement Requests.
• For breaches of the Acceptable Use Policy that do not involve your own rights, use the abuse report channel in Section 17 of that Policy.

1.3 Customer Data held for Organizations. Most Customer Data is private to the Organization that stores it. The Organization is responsible for it. When a notice concerns Customer Data, we may first forward it to the Organization and ask it to act. If the Organization does not act, or the case is urgent or serious, we act ourselves under this Policy.

2. Where to send a notice#

All notices can be sent by email to the addresses above. Accepted languages for notices: English, Portuguese and Spanish.

Postal address for all notices: L. M. PEREZ MONTANA (SonhoLab), Rua Fausto Cabral, 871, Casa A, Vicente Pinzon, Fortaleza-CE, 60181-227, Brazil.

3. General rules for all notices#

3.1 Be specific. Identify the exact content. The best way is the full URL, or the slug, account or agent phone number and the date and time. We cannot act on vague notices, such as "remove everything about me".

3.2 Explain the basis. Explain which right or law the content infringes, and why.

3.3 Show your standing. Tell us who you are and your relationship to the right: the owner, the person depicted, their legal representative or their heir. We may ask for reasonable proof, such as an identity document or a power of attorney. We ask only for what we need, and we delete it when we no longer need it.

3.4 How we handle a notice.

• (a) We confirm receipt.
• (b) A person at SonhoLab reviews the notice. We decide in a timely, diligent, objective and non-arbitrary way. Automated tools may help us sort notices or find copies of content, but a person takes the removal decision.
• (c) If the notice is complete and well founded, we remove or disable access to the content. Where appropriate we also apply the measures in the Acceptable Use Policy, Section 15.
• (d) We tell the notifier what we decided and what options they have.
• (e) We tell the user who posted the content, with a statement of reasons (Section 13), unless the law forbids it or it would endanger someone.

3.5 Timing.

• Intimate images and unauthorized voice or likeness: within 48 hours of a valid request (Sections 10 and 11).
• Other notices: without undue delay. Clear cases usually take less time than cases that need more information.

3.6 Your personal data. We use the personal data in a notice only to handle it, to keep the records the law requires, and to defend legal claims.

• For copyright and trademark notices, we may share the notice, including your name, with the user whose content was removed, because they need it to respond.
• For intimate-image and privacy notices, we do not share your identity with the uploader unless the law requires it.

4. United States: DMCA notices#

4.1 Designated agent. We are registering our designated agent for notices of claimed copyright infringement under the Digital Millennium Copyright Act (17 U.S.C. §512(c)) with the US Copyright Office's DMCA Designated Agent Directory. Until the registration is complete, send notices and counter-notices to contacto@sonholab.com, with the subject "DMCA notice" or "DMCA counter-notice". We will publish the agent's details here once registered.

4.2 What your notice must contain. Under 17 U.S.C. §512(c)(3), a notice must be in writing and include:

• (a) a physical or electronic signature of the copyright owner or of a person authorized to act on the owner's behalf;
• (b) identification of the copyrighted work claimed to be infringed. If several works are covered by one notice, a representative list is enough;
• (c) identification of the material claimed to be infringing, with information reasonably sufficient for us to locate it, such as the URL;
• (d) your name, address, phone number and email;
• (e) a statement that you have a good-faith belief that the use is not authorized by the copyright owner, its agent or the law;
• (f) a statement that the information in the notice is accurate and, under penalty of perjury, that you are authorized to act on behalf of the owner of the right claimed to be infringed.

4.3 Incomplete notices. If a notice substantially complies with items (b), (c) and (d) but misses other items, we try to contact you to complete it.

4.4 What we do. On receiving a valid notice we expeditiously remove or disable access to the material. We take reasonable steps to notify the user who posted it, and we send them a copy of the notice.

4.5 Fair use. Before sending a notice, consider whether the use could be a fair use or otherwise authorized by law. A notice that knowingly misrepresents infringement can lead to liability (Section 15).

4.6 Standard technical measures. We accommodate, and do not interfere with, standard technical measures that copyright owners use to identify or protect copyrighted works, as 17 U.S.C. §512(i) requires.

5. United States: DMCA counter-notices#

5.1 When to send one. If your material was removed because of a DMCA notice and you believe it was removed by mistake or misidentification, you can send a counter-notice to our designated agent (Section 4.1).

5.2 What it must contain. Under 17 U.S.C. §512(g)(3), a counter-notice must include:

• (a) your physical or electronic signature;
• (b) identification of the material that was removed, and the location where it appeared before removal;
• (c) a statement, under penalty of perjury, that you have a good-faith belief that the material was removed or disabled as a result of mistake or misidentification;
• (d) your name, address and phone number;
• (e) a statement that you consent to the jurisdiction of the US Federal District Court for the judicial district in which your address is located. If your address is outside the United States, it must say that you consent to any judicial district in which SonhoLab may be found;
• (f) a statement that you will accept service of process from the person who sent the original notice, or that person's agent.

5.3 What we do.

• We promptly send a copy of the counter-notice to the person who sent the original notice.
• We tell them that we will restore the material in 10 business days.
• We restore the material no less than 10 and no more than 14 business days after we receive the counter-notice.

We do not restore it if, before then, our designated agent receives notice that the complaining party has filed a court action seeking to restrain you from the infringing activity.

5.4 Your personal data. The counter-notice, including your contact details, is shared with the person who sent the original notice. This is how the DMCA process works.

6. Repeat infringer policy#

6.1 Policy. In appropriate circumstances, we terminate the accounts of users who are repeat infringers of copyright or other intellectual property rights, as 17 U.S.C. §512(i)(1)(A) requires. We apply this policy to all users worldwide.

6.2 How we count.

• A "strike" is a valid notice that led to removal and was not successfully countered or overturned on complaint.
• As a general rule, an account that receives three strikes within 12 months is terminated.
• For an Organization, we count strikes per Authorized User. We may also act against the Organization if it tolerates repeated infringement.

6.3 Judgment. We consider the circumstances. For example:

• several notices sent at the same time about the same upload may count as one strike;
• we may terminate after fewer strikes in cases of clear, deliberate or large-scale infringement.

6.4 After termination. A terminated repeat infringer may not open a new account. The Customer Data export rules of the Terms of Service, Section 19, still apply to lawful Customer Data.

7. Brazil: extrajudicial notices (Marco Civil and STF Themes 987/533)#

7.1 The rule we follow. In 2025 the Supreme Federal Court (STF) decided Themes 987 and 533. It held that art. 19 of the Marco Civil da Internet (Lei 12.965/2014) is partially unconstitutional. The decision on the motions for clarification was concluded in June 2026. As a result:

• (a) as a general rule, an application provider becomes liable, jointly with the author, if it fails to remove unlawful content after receiving an extrajudicial notice (the regime of Marco Civil art. 21);
• (b) for alleged crimes against honor (defamation, slander or insult), removal still requires a court order. We may nonetheless remove content that breaches our Acceptable Use Policy;

• (c) providers have a heightened duty of care for certain serious content, including:

  • anti-democratic acts;
  • terrorism;
  • incitement to suicide or self-harm;
  • discrimination;
  • violence against women;
  • crimes against children and adolescents;
  • trafficking in persons.

  We act on such content as soon as we become aware of it, whether or not we receive a notice.

7.2 What your notice must contain.

• (a) your name and contact details, and your relationship to the content or right (the person affected, their legal representative, or the rights holder);
• (b) the specific location of the content (URL, slug, account or other element that allows us to identify it unambiguously);
• (c) a description of why the content is unlawful, and the right or law it infringes;
• (d) for copyright, identification of the work and of your rights over it, under the Copyright Law (Lei 9.610/1998);
• (e) a statement that the information is true.

7.3 Due process for the user. When we remove content following a Brazilian notice, we tell the user who posted it:

• that the content was removed;
• the reason and the notice it was based on, protecting the notifier's identity where appropriate;
• how to contest the decision (Section 13).

If the user shows that the content is lawful, we may restore it and tell the notifier, who can then go to court.

7.4 Court orders. We comply with valid orders of Brazilian courts to remove content or provide data, as described in Government and Law Enforcement Requests.

8. Brazil: intimate images (Marco Civil, art. 21) and content harmful to minors#

8.1 Intimate images. Under art. 21 of the Marco Civil, if someone discloses images, video or other material containing nudity or sexual acts of a private nature without the authorization of the participants, a participant or their legal representative may ask us to remove it. The notice must:

• contain elements that allow us to specifically identify the material; and
• allow us to verify that the person asking has standing.

We remove such material within 48 hours of a valid request (Section 10). This applies whether the material is real or created or altered with AI.

8.2 Content harmful to children and adolescents. Under the ECA Digital (Lei 15.211/2025), we remove content that violates the rights of children and adolescents when we receive a notice from:

• the victim;
• their parent or guardian; or
• a competent authority.

No court order is needed. We report child sexual abuse material to the competent authorities, as described in the Acceptable Use Policy, Section 3.

9. European Union: notice and action under the Digital Services Act#

9.1 Who can send a notice. Any person or entity can tell us about specific content on our Services that they consider illegal content, under art. 16 of the Digital Services Act (Regulation (EU) 2022/2065).

9.2 What your notice should contain. To be treated as a complete notice, it should include:

• (a) a sufficiently substantiated explanation of why you consider the content illegal;
• (b) a clear indication of the exact electronic location of the content, such as the exact URL, and further information where needed to identify it;
• (c) your name and email address. The one exception is notices about child sexual abuse offenses, which may be anonymous;
• (d) a statement confirming your good-faith belief that the information and allegations in the notice are accurate and complete.

9.3 What we do.

• (a) We send you a confirmation of receipt without undue delay.
• (b) We process the notice and decide in a timely, diligent, non-arbitrary and objective way.
• (c) We tell you our decision without undue delay, and inform you of the ways you can seek redress.
• (d) If we use automated means to process or decide on notices, we tell you.
• (e) If the content is illegal, or breaches our terms, we remove it or disable access to it in the EU or everywhere, as appropriate.

9.4 Statement of reasons. We give the affected user a clear and specific statement of reasons for any restriction, as art. 17 of the DSA requires (Section 13).

9.5 Complaints and other redress. Both the notifier and the affected user can use our free internal complaint process (Section 13.3). Nothing prevents either of them from going to court. EU users can also lodge a complaint with the Digital Services Coordinator of their member state.

9.6 Contact points and legal representative.

• Single point of contact for users and for authorities: contacto@sonholab.com.
• EU legal representative: SonhoLab is appointing a legal representative in the European Union (Ireland). Until the appointment is published, you can contact contacto@sonholab.com.

See the Terms of Service, Section 14.5.

10. Non-consensual intimate images anywhere (48 hours)#

10.1 Global rule. Wherever you are, we remove intimate images, video or audio of an identifiable person published on our Services without that person's consent. This includes material created or altered with AI ("digital forgeries").

10.2 How to ask. Send a request to contacto@sonholab.com with the subject "Intimate image removal". Include:

• (a) your physical or electronic signature, or that of a person authorized to act for you;
• (b) information that allows us to locate the content;
• (c) a brief statement of your good-faith belief that the content is an intimate depiction published without your consent;
• (d) contact information we can use to reach you.

You do not need to prove who created the content.

10.3 48-hour removal. We remove the content within 48 hours of receiving a valid request. We also make reasonable efforts to identify and remove known identical copies on our Services. This process implements:

• the US TAKE IT DOWN Act (47 U.S.C. §223a);
• art. 21 of the Marco Civil da Internet (Section 8.1);
• the EU Digital Services Act (Section 9).

10.4 Discretion. We handle these requests confidentially. We do not reveal your identity to the uploader. We may preserve a restricted copy of the material and related records where the law requires it or to support an investigation by the authorities.

11. Voices and likeness (48 hours)#

11.1 Who can ask. Any of the following can ask us to remove a voice clone, synthetic voice, image or other likeness of a person that was created or shared through our Services without authorization:

• (a) the person whose voice or likeness it is;
• (b) their legal representative;
• (c) for a deceased person: the spouse, an ascendant or descendant, another relative with standing under the law that applies (in Brazil, Civil Code arts. 12 and 20, sole paragraphs), or the estate.

This includes voices in the Hades shared voice library and any AI-generated audio or image that imitates a real person.

11.2 What to include. Send a request to contacto@sonholab.com with the subject "Voice or likeness removal". Include:

• the location of the content or the name of the voice in the library;
• who you are and your relationship to the person;
• a statement that the use was not authorized, or that the consent has been withdrawn.

We may ask for reasonable proof of identity or standing. We act on the request while we verify it when the case is urgent.

11.3 48-hour removal. We remove the voice or likeness within 48 hours of a valid request. For Hades:

• (a) we remove the voice for everyone, the user who created it and all other users, including through the shared library, and delete it from all our systems automatically;
• (b) we treat a request by the voice owner, or by a relative with standing for a deceased person, as a withdrawal of consent under the Hades Addendum: Voice, Biometrics, Memorials and Companion AI;
• (c) where another relative objects to the use of a deceased person's voice, we remove it and ask the uploader to resolve the disagreement, if they wish, through the courts.

11.4 Public figures. Our Services do not allow voice or likeness simulation of public figures, politicians or candidates (see the Acceptable Use Policy, Section 6.3). Anyone can report such content, and we remove it on becoming aware of it.

12. Trademark complaints#

12.1 What we review. We review complaints that content, a slug, a custom domain shown on a System, an AI agent's name or an account uses a trademark in a way that is likely to confuse people or that infringes the trademark owner's rights.

12.2 What to include.

• (a) your name and contact details, and your relationship to the trademark;
• (b) the trademark, the countries where it is registered, and registration numbers (or evidence of unregistered rights where the law recognizes them);
• (c) the location of the content, slug, domain or account;
• (d) an explanation of why the use is likely to cause confusion or otherwise infringes;
• (e) a statement that the information is accurate and that you are authorized to act.

12.3 What we do. Trademark disputes often depend on context, such as fair or descriptive use, criticism or resale of genuine goods. We may:

• ask the account holder to respond before we decide;
• remove or disable content;
• change a slug under the Terms of Service, Section 5.3;
• decide that we cannot resolve the dispute and that the parties should resolve it between them.

We do not arbitrate disputes about who owns a domain name. We only act on how the domain is used on our Services.

13. What happens after a decision: statements of reasons and complaints#

13.1 Statement of reasons to the affected user. When we remove or restrict content, or suspend or terminate an account, following a notice or on our own initiative, we give the affected user a statement of reasons. It explains:

• (a) what we did (removal, disabling, restriction of visibility, suspension or termination), its territorial scope and its duration;
• (b) the facts and circumstances we relied on, including whether we acted on a notice. Where appropriate we name the notifier, but never in intimate-image, voice-or-likeness or child-protection cases;
• (c) whether we used automated means to detect the issue or to decide;
• (d) the law we relied on if the content is illegal, or the rule of our terms if it breaches our terms;
• (e) the redress available: our internal complaint process, the courts and, in the EU, out-of-court options where available.

We do not give a statement where the law forbids it, where it would hinder an investigation or endanger someone, or for deceptive high-volume commercial content.

13.2 DMCA cases. In DMCA cases the counter-notice (Section 5) is the specific way to contest a removal. You may also use the complaint process in Section 13.3.

13.3 Internal complaint process. Both the affected user and the notifier can complain about our decision:

• within 6 months after we inform them of it;
• free of charge;
• by writing to contacto@sonholab.com with the subject "Content complaint", or replying to our decision message.

A person who did not take the original decision reviews the complaint. If it shows that the decision was wrong or not justified, we reverse it without undue delay. This includes restoring content or access. We tell the complainant the outcome and the reasons. Complaints are never decided by automated means alone.

13.4 Courts and authorities. This process does not prevent anyone from going to court. In the EU it does not prevent a complaint to the Digital Services Coordinator. In Brazil it does not prevent a claim to consumer protection bodies.

14. AI-generated content and translations#

14.1 User responsibility. When you ask one of our AI features to generate, transform or translate content, you are responsible for having the rights to the input. You must also use the output lawfully. Examples are voice synthesis and text extraction (OCR).

14.2 Translations and derivative works. Translating, adapting or reproducing a protected work may require the rights holder's authorization, even for personal use in some countries. Use our features to translate or adapt only works you own, works you are licensed to use, or works in the public domain. You may not publish or distribute translations or adaptations of works you have no rights to. See the Free Tools and Content Services Terms.

14.3 Notices about AI outputs. Rights holders can report AI outputs shared on our Services under this Policy, in the same way as other content.

14.4 Labels. We label AI-generated voices and other synthetic content as AI-generated. See the AI Transparency Notice. Removing those labels breaks the Acceptable Use Policy.

15. Misuse of this process#

15.1 False notices. Do not send a notice or counter-notice unless you believe in good faith that it is accurate. Under 17 U.S.C. §512(f), a person who knowingly materially misrepresents that material is infringing, or that it was removed by mistake, may be liable for damages, including costs and attorneys' fees. Other laws, including Brazilian civil and criminal law, also apply to false or abusive notices.

15.2 Repeated unfounded notices. If a person or organization frequently sends notices or complaints that are manifestly unfounded, we may, after a prior warning, suspend the processing of their notices for a reasonable period. We decide this case by case. We consider how many unfounded notices were sent, how serious they were, and the notifier's apparent intent.

15.3 Abuse against users. We do not allow notices to be used to harass users or silence lawful speech. We may refuse notices sent for these purposes.

16. Records and transparency#

16.1 Records. We keep records of notices, decisions, counter-notices and complaints. We use them to apply the repeat-infringer policy, to answer authorities and courts, and to defend legal claims. We keep them for the periods in the Data Retention Schedule.

16.2 Transparency report. We publish an annual report with aggregated figures on notices received, content removed, response times, complaints and their outcomes, as part of the report described in Government and Law Enforcement Requests, Section 9. The report contains no personal data.

16.3 Changes. We may update this Policy under the Terms of Service, Section 24.

Version 0.9.0 (preliminary) · Effective 26 September 2026 · © L. M. PEREZ MONTANA (SonhoLab), CNPJ 61.620.014/0001-00. This version is under legal review; we will notify material changes as described in these documents.