Lugui

TERMS OF USE AND PRIVACY POLICY

LUGUI SERVIÇO DE TECNOLOGIA LTDA.

This page establishes the Terms of Use and Privacy Policy (“Document”) applicable to the services provided by Lugui Serviço de Tecnologia Ltda., registered under CNPJ No. 57.148.430/0001-72 (“Lugui”).

By interacting with our Virtual Assistant via WhatsApp or using our services, you declare that you have read, understood, and agreed to the conditions set forth herein.

For any matter related to this document or the exercise of your rights provided for in the Brazilian General Data Protection Law (LGPD), you may contact our Data Protection Officer via email: contato@lugui.ai.

PART I: TERMS OF USE

1. Nature of Services

Lugui is a technology company that develops Artificial Intelligence solutions to optimize real estate processes. We act exclusively as an intermediary technological tool for partner real estate agencies and brokers (“Clients”).

Lugui does not act as a real estate agency, insurance broker, or insurance company. We do not make decisions regarding the approval or rejection of rental proposals, guarantees, or credit granting. Any final decision is the sole responsibility of the real estate agency or insurance company responsible for your proposal.

2. Use of the Virtual Assistant (WhatsApp)

By using our virtual assistant to send data and documents, you commit to:

  • Providing accurate, up-to-date, and truthful information.
  • Responsibility for Third-Party Data: Sending only documents and information of which you are the data subject. If you send third-party data (such as IDs, tax IDs, and proof of income/residence of spouses, guarantors, or co-tenants), you guarantee that you have the express authorization and consent of these individuals to share such information through our channel.
  • Not using the channel to send unlawful or offensive messages, spam, or files containing viruses and malware.

3. Limitation of Liability

Lugui uses its best efforts to maintain the availability and security of the service. However, we are not responsible for instabilities resulting from third-party platforms (such as failures in WhatsApp/Meta), internet interruptions, or third-party actions beyond our control.

PART II: PRIVACY AND DATA PROCESSING POLICY

1. Definitions

For the purposes of this Policy, the following definitions apply under the terms of the LGPD (Law No. 13,709/2018):

  • “Client”: Individual or legal entity (Real Estate Agencies, Brokers) that contracts Lugui.
  • “Controller”: The one responsible for decisions regarding the processing of personal data (In this scenario, the Client/Real Estate Agency).
  • “Processor”: The one who processes data on behalf of the Controller (In this scenario, Lugui).
  • “Data Subject”: The natural person to whom the personal data refers (You, Tenant, Spouse, or Guarantor).

2. How We Collect and Process Your Personal Data

Lugui, as a Processor, always processes your data upon request and on behalf of the real estate agency (Controller) with which you are negotiating. The processing occurs through two main solutions:

A) Lugui Virtual Assistant (Document Collection via WhatsApp)

To expedite your rental process, our virtual assistant collects documents and information directly from you via chat.

  • What we collect:
    1. Files: Images of identification documents (ID, Driver's License, Passport), proof of income (Pay stubs, Bank statements, Tax Returns), proof of residence, civil status certificates, property documents (Deeds), and facial biometrics (Selfie).
    2. Text Data: Information provided during the conversation, such as profession, company, salary, marital status, family composition, pet ownership, email, and phone number.
    3. Feedback: Customer service evaluation scores (NPS).
  • How we process: We use Artificial Intelligence and Optical Character Recognition (OCR) tools to read the images sent, validate quality, extract textual information automatically, and organize a structured dossier (Registration Form).
  • Purpose: To deliver organized and legible documentation swiftly for the real estate agency or insurance company to analyze your rental proposal (Preliminary Procedures to Contract - Art. 7, V, LGPD), as well as to use your feedback for the continuous improvement of our artificial intelligence.

B) Tenant Report (Background Analysis)

To assist real estate agencies in risk analysis and fraud prevention, Lugui generates intelligence reports.

  • What we collect: Data from legal proceedings, corporate information, professional data, and credit restriction information.
  • How we process: We consult public information made available by the Public Administration (according to the Access to Information Law) and receive datasets from partner suppliers and bureaus, always with valid legal bases.
  • Purpose: Measurement of risks in real estate business transactions, compliance, and fraud prevention (Legitimate Interest and Credit Protection - Art. 7, IX and X, LGPD).

3. Sharing of Personal Data

Lugui does not sell your data. Sharing occurs strictly in the following situations:

  • With the Real Estate Agency (Controller): All documents sent via WhatsApp, collected textual information, and generated reports are shared with the Client (real estate agency/broker) who requested the collection, so they can evaluate the rental proposal.
  • Technology Partners: We use cloud infrastructure providers (such as Amazon Web Services - AWS) and Artificial Intelligence APIs to host and process data. We contractually require our suppliers to adhere to the highest information security standards.
  • Public Authorities: Upon judicial order or legal obligation.

4. Storage, Retention, and Disposal

Your data is hosted on high-security servers (e.g., AWS) with encryption and access controls.

  • Report and Registration Data: Stored for the time necessary to fulfill the purpose or for defense in legal proceedings.
  • WhatsApp Files and Images: The original files (photos of IDs, Pay stubs, Selfies) sent to our virtual assistant are treated as temporary. After processing via OCR and the successful consolidation of the dossier for the real estate agency, Lugui commits to disposing of/deleting the images from its active servers, retaining only structured data and audit logs necessary for proof of operation, minimizing leak risks.

5. Your Rights (Data Subject)

You have several rights under the LGPD, such as confirmation of processing, access, correction, deletion, and revocation of consent.

Important: Because Lugui acts as a Processor, requests for data deletion or revocation related to your rental proposal should preferably be directed to the Real Estate Agency (Controller), who is the ultimate decision-maker regarding the retention of documents for the purposes of the rental contract.

If you send a request directly to contato@lugui.ai, Lugui will act as a facilitator, forwarding your request to the responsible Controller for proper deliberation, or deleting the data from the databases under our direct control that do not conflict with legal obligations.

6. General Provisions

This Policy may be updated at any time to reflect improvements in our systems or changes in legislation. The latest version will always be available at this link.

For matters regarding the interpretation of this Document, the parties submit to the Jurisdiction of the District of SĂŁo Paulo/SP.

Last Updated: February 20, 2026.

Lugui is a startup focused on automating real estate processes through artificial intelligence, offering practical and efficient solutions for brokers and real estate agencies.