Privacy Notice

1. Privacy Commitment

This website is operated by Luby Software. We are committed to ensuring your security when visiting and using our services, including protecting the personal data you provide to us.

Luby Software is committed to protecting the privacy of all individuals whose personal data we process, in compliance with the Brazilian General Data Protection Law (LGPD — Law No. 13,709/2018) and other applicable privacy regulations.

You may choose not to provide certain personal information. However, please be aware that this may limit certain interactions and features available to you on our website.

2. Why Luby Collects Personal Information

Luby collects personal information to conduct its business activities, provide and improve services, and comply with legal and regulatory obligations. We may also collect information at the request of our clients and for analytical purposes to better understand how our website and services are used.

3. What Information We Collect

Depending on how you interact with us, we may collect the following categories of personal information:

• Name, job title, company, and contact details (email, phone number, address)
• Interest in specific services or events
• Business relationships and commercial activities
• Professional data (résumé, education, work history) in the context of job applications
• Browsing data (IP address, browser type, pages visited)
• Voluntary opinions, feedback, and comments

Luby does not intentionally collect sensitive personal data. If such data is voluntarily provided, it will be processed on the basis of your explicit consent.

Our website is not directed to individuals under 18 years of age. If we become aware that personal data has been collected from a minor, such data will be promptly deleted.

4. How Information Is Collected

5. Cookies

A cookie is a small text file stored on your device when you visit a website. Cookies help us recognize your preferences and improve your browsing experience.

On your first visit, a consent banner will be displayed allowing you to manage your cookie preferences. We use the following categories of cookies:

Third-party services that may install cookies on our website include: Google Analytics 4, Google Ads/Tag Manager, Meta Pixel, LinkedIn Insight Tag, and HubSpot.

6. Data Logs

Our servers automatically collect certain information in log files, including IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, and date/time stamps.

We may also use tracking technologies to analyze trends and gather aggregated demographic information. This data is not linked to any personally identifiable information.

7. How Luby Uses Your Information

We use the personal information we collect for the following purposes:

• Providing and delivering our services
• Managing business relationships and responding to inquiries
• Improving our services and user experience
• Sending newsletters, event invitations, and marketing communications (with your consent)
• Evaluating job applications
• Complying with legal and regulatory obligations
• Preventing fraud and ensuring the security of our systems

You may opt out of marketing communications at any time by using the unsubscribe link in our emails or by contacting our DPO at dpo@luby.com.br.

8. Sharing Information with Third Parties

Luby does not sell personal data. We only share personal information when necessary and with appropriate safeguards in place.

We may share your information with the following categories of third parties:

• Infrastructure providers (e.g., AWS, Azure, GCP)
• CRM and marketing tools (e.g., HubSpot, Mailchimp)
• Analytics tools (e.g., Google Analytics)
• Legal and accounting advisors
• Government authorities, when required by law
• Business partners and clients

Sharing is based on your consent or on another legal basis permitted by applicable law.

In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the acquiring entity. We will provide prior notice of any such transfer.

Some pages on our website may contain frames or widgets provided by third-party partners. Information submitted through such features is provided directly to those third parties and is subject to their respective privacy policies.

9. Your Rights as a Data Subject

Under the Brazilian General Data Protection Law (LGPD, Art. 18) and other applicable regulations, you have the following rights regarding your personal data:

• Confirmation of the existence of data processing
• Access to your personal data
• Correction of incomplete, inaccurate, or outdated data
• Anonymization, blocking, or deletion of unnecessary or excessive data
• Data portability to another service provider
• Deletion of data processed with your consent
• Information about entities with whom your data has been shared
• Information about the consequences of withholding consent
• Withdrawal of consent at any time

To exercise any of these rights, please contact our Data Protection Officer at dpo@luby.com.br. Requests will be addressed within 15 days, in accordance with Art. 19, II of the LGPD.

You also have the right to file a complaint with the Brazilian National Data Protection Authority (ANPD) if you believe your data protection rights have been violated.

10. Information Security

Luby implements appropriate technical and organizational measures to protect your personal data, including:

• Encryption in transit (TLS/HTTPS) and at rest
• Role-based access control (RBAC) and multi-factor authentication
• Continuous monitoring and vulnerability testing
• Regular employee training on data protection and security

While we strive to protect your personal data, no system is completely infallible. We recommend adopting good security practices when using our website.

In the event of a security incident that may result in significant risk to data subjects, Luby will notify the Brazilian National Data Protection Authority (ANPD) and affected individuals in accordance with Art. 48 of the LGPD.

11. Other Matters

12. Changes to this Privacy Notice

Luby may update this Privacy Notice from time to time. In the event of significant changes, we will notify you by email or by posting a prominent notice on our website.

Contact Us