Privacy Policy

Who we are

LUME Hub is a platform for running your business — content, sales, clients, prospecting, organization, finance, data and artificial intelligence — and also for managing mentoring and consulting services, operated by LUME — Hsx Assessoria e Consultoria LTDA, CNPJ 37.374.629/0001-01. Anyone 18 or older can create an account through the website; some accounts are created by whoever administers them (LUME, a mentor or an agency).

For the purposes of Brazil's General Data Protection Law (LGPD, Law No. 13,709/2018), LUME (Hsx Assessoria e Consultoria LTDA) acts as the controller of the data of people who use the platform, and as the processor of the data a mentor records about their own clients — in that case, the mentor decides what goes in and how long it stays.

Data we collect

We collect only what the platform needs to work:

• Registration: name, email, WhatsApp number if you provide it, password (stored encrypted, never in readable form) and profile photo if you upload one.
• Sign-up and free trial protection: the IP address of whoever creates the account goes into temporary counters that limit repeated sign-ups and trials, and the email ensures the trial applies only once per person.
• Subscription and payment: plan, amount, status of charges and the last digits of the card. Payments are processed by Mercado Pago: the full card number is entered in Mercado Pago's form and never reaches LUME Hub and is not stored by us.
• Content you create: diagnostic answers, planning, editorial calendar, tasks, notes, uploaded files and anything else you type or upload to the Hub.
• Business financial data: contracts, installments, cash entries and statements you import. These are records of your operation, which you enter or import.
• Usage data: technical access and error logs, used for security and to fix what breaks.
• Measurement of the website and our ads, only with your permission: the pages visited, where the visit came from and the actions described in Cookies and ad measurement.

Data from connected platforms

When you connect a Google, Meta or LinkedIn account to the Hub, we start reading data from those accounts on your behalf — and, for connections made to publish or reply, acting on them the way you configured. This happens only with your explicit authorization, and you can revoke it at any time in the security settings of the originating platform itself. The ads, website analytics and search connections are read-only.

• Google Ads: campaign performance metrics (spend, impressions, clicks, conversions). We do not create, edit or pause campaigns.
• Google Search Console: performance of your website and your profiles in Google Search (impressions, clicks, average position and search queries).
• Google Analytics: visit metrics for your website (sessions, users, page views, traffic source, region and key events), always aggregated — never data on an individual visitor.
• Meta Ads: performance metrics for Facebook and Instagram ads, with read-only permission.
• Instagram: profile data and metrics for your own posts; the comments and direct messages the account receives, read so they appear in the Hub and for the automatic replies you set up; and the posts you schedule, which the Hub publishes to your account.
• LinkedIn: your profile's name, photo and email, to identify the connected account, and the posts you send to be published or scheduled on your personal profile.
• Google Business Profile: business profile data and metrics (views, calls, directions and search terms), the reviews received, and the replies, updates and profile changes you make through the Hub.
• Google Drive: only the files you upload or pick through the Hub in the Videos module (permission restricted to the files used by the app). The Hub cannot see the rest of your Drive.
• YouTube: channel data (name, photo, number of subscribers and videos), the list of your videos with the public numbers for each one, and YouTube Analytics numbers (views, watch time, subscribers gained and lost per day, and each video's retention). With your authorization, the Hub also uploads or schedules videos on your channel when you ask.

This data is used exclusively to build the reports shown in your dashboard and to carry out the posts and replies you request or set up in the Hub. We do not sell it, rent it or use it for advertising, profiling or credit decisions. It leaves the Hub in only two cases, always to deliver what you asked for: the hosting and database providers where the Hub runs; and, when you use an AI analysis (the paid ads analysis, the Results report and the suggested reply to a Google Business Profile review), the AI model provider (currently the OpenAI API), which receives only the aggregated numbers for the period or the text of that review, solely to generate that response, and does not use them to train its models. We do not use Google data to develop, improve or train artificial intelligence models. Our use of information obtained through Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

You choose which sites, properties and accounts appear in the dashboard, and you can disconnect from the Hub itself, using the Conta Google (Google Account) button on the dashboard. When you disconnect, we revoke access with Google, delete the credential we stored and the numbers are removed from the dashboard. Previously imported history is kept — it comes back if you connect the same account again — until you request deletion: email contato@wearelume.com.br and we will delete the Google data from your account within 15 days. YouTube data has its own, shorter rule (see below).

Google user data (summary)

This summary describes how LUME Hub handles data received from Google APIs (Search Console, Google Analytics, Google Ads, Google Business Profile, Google Drive, YouTube Data API and YouTube Analytics API). Each user connects their own Google account and only they, and the people they authorize inside their LUME Hub account, see that data.

• Data accessed: the connected account's email address (to show which account is connected); Search Console performance (impressions, clicks, average position and queries) for the sites the user selects; aggregated Google Analytics reports (sessions, users, page views, traffic sources, region, key events) for the properties the user selects; Google Ads campaign performance (spend, impressions, clicks, conversions) for the accounts the user selects; Google Business Profile metrics, reviews and the profile fields the user edits; only the Google Drive files the user uploads or picks through LUME Hub (drive.file); and the user's own YouTube channel, video list with public statistics and YouTube Analytics reports (views, watch time, subscribers gained and lost, audience retention).
• Data use: only to show these numbers in the user's own dashboard and reports, and to perform the actions the user requests: replying to a Google review, publishing an update or editing the business profile, uploading a file to Drive or a video to YouTube. Google Ads access is used for read-only reporting; we never create, change or pause campaigns. Nothing is posted or changed without the user's action.
• Data sharing: we do not sell or rent Google user data and do not use it for advertising, profiling or credit decisions. It is only processed by our hosting and database providers and, when the user runs an AI analysis (paid traffic analysis, results report, or a suggested reply to a Google review), by our AI model provider (currently the OpenAI API), which receives only the aggregated numbers for the period or the text of that review, solely to generate that response, and does not use it to train its models.
• Data protection: all traffic uses HTTPS/TLS. Google OAuth tokens are encrypted at rest (AES-256-GCM) with a key kept outside the database, are stored in tables no user account can read, and are only used by server processes. Per-account isolation is enforced by the database row by row. Server and database access is limited to the technical team with key-based authentication.
• Retention and deletion: when the user disconnects a Google account in LUME Hub, we revoke the token with Google and delete the stored credential immediately. YouTube data is refreshed daily; data not refreshed for 30 days is deleted, and disconnecting the channel deletes it immediately. Other imported Google data is kept while the account is active so the history is available, and is deleted within 15 days of a request to contato@wearelume.com.br. Users can also revoke access at any time at myaccount.google.com/permissions.
• Limited Use: LUME Hub's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. The use of raw or derived user data received from Workspace APIs (Google Drive) also adheres to the Google User Data Policy, including the Limited Use requirements; we do not use Google user data to develop, improve or train AI/ML models, and we do not transfer it to third parties that use it for that purpose.

YouTube

The YouTube integration uses the YouTube API Services. By connecting a channel, you are also bound by the YouTube Terms of Service, and data obtained from YouTube is also handled in accordance with the Google Privacy Policy.

• What we read and store: the channel, video and YouTube Analytics data listed above, only for the channel you chose to link to the Hub.
• What we use it for: only to show these numbers in your dashboard and in the reports you generate, and to upload or schedule the videos you request. We do not share this data with third parties or use it for advertising.
• How long: YouTube data is refreshed every day; anything not refreshed for 30 days is deleted. When you disconnect the Google account or unlink the channel in the Hub, we delete that channel's YouTube data immediately.
• How to revoke: besides disconnecting through the Hub, you can remove LUME Hub's access at any time on your Google Account permissions page.

Chrome extension (Social Selling)

The LUME Hub · Social Selling extension is optional and only works after you sign in to it with your Hub login. It acts only on Instagram (instagram.com) and LinkedIn (linkedin.com) pages and reads only what is needed for Social Selling for the account you serve:

• The actions you take on Instagram: when you like, comment, react or reply to a story, or send a Direct message, the extension records in Social Selling the person's @ handle, the type of action, the link to the post or story and the text you wrote. It does not read your feed, your contacts or the messages in other conversations.
• The actions you take on LinkedIn: when you react to or comment on a post, send a connection request (with the note, if any), follow someone or send a message, the extension records in Social Selling the person's profile address (linkedin.com/in/…) and the name shown on screen, the type of action, the link to the post and the text you wrote. It does not read your feed, your network or the messages in other conversations.
• The open conversation, when you ask for suggestions: only when you click “Sugerir resposta” (Suggest reply), the text of the conversation on screen is sent to the Hub and to the artificial intelligence provider to generate the suggestions, following the client's playbook. The conversation is not stored; we only record that a request was made, by whom and for which profile.
• In your browser: the login session, the selected client, the latest records and those waiting for a connection. Signing out of the extension or removing it erases all of this.

The extension never likes, comments, follows, connects or sends anything on its own: you are always the one acting on Instagram and LinkedIn. It does not access other sites, does not read your browsing history and does not use this data for advertising. The use of information received by the extension adheres to the Chrome Web Store User Data Policy, including the Limited Use requirements.

How we use data

• Provide access to the platform and the features enabled for you.
• Manage the free trial and the subscription: enable the plan's modules, process charges and prevent repeated use of the trial.
• Build dashboards, reports and diagnostics from your own numbers.
• Send operational notices: invitations, password resets, end of the free trial, meeting reminders, billing alerts.
• With your permission, measure how the website is used and how LUME Hub's ads perform, and show those ads to people who have already visited us.
• Keep the platform secure and investigate misuse.
• Comply with legal or regulatory obligations.

Some features use artificial intelligence to generate text or analysis from your data. In those cases, the necessary content is sent to the model provider solely to produce that response. You acknowledge the use of AI whenever the screen indicates it.

Who we share data with

We do not sell personal data. We share it only with those necessary for the platform to exist:

• Infrastructure: hosting, database and file storage providers.
• Payments: Mercado Pago, which processes your subscription charges — and, if you sell digital products through the Hub, your buyers' payments, in your own Mercado Pago account.
• Communication: email and messaging delivery services.
• Measurement and ads: Google (Google Analytics and Google Ads), only if you allow the cookies, and without your registration data (see Cookies and ad measurement).
• Artificial intelligence: model providers, limited to the content of each request.
• Your mentor or agency: if you are their client, whoever invited you can see the data from your program. That is the purpose of the service.
• Authorities: when there is a court order or a legal obligation.

Security and protection of sensitive data

We treat as sensitive the credentials of the accounts you connect and the data that comes from them, including user data received from Google APIs. This is how they are protected:

• In transit: all traffic between your browser, the Hub and the APIs of Google and the other platforms is encrypted (HTTPS/TLS).
• Encrypted credentials: access tokens for Google accounts are encrypted in the database (AES-256-GCM), with the key kept outside the database, only in the server environment. Each token is bound to its connection: copied anywhere else, it cannot be opened.
• Out of the interface's reach: credentials are kept in tables that no user account can read (the database itself blocks it) and are used only by the server processes that fetch the data you requested. They never appear on screen or in reports.
• Only the access needed: we request read-only permission whenever it exists (Analytics, Search Console, YouTube and YouTube Analytics). In Drive, access is limited to the files used by the Hub. To upload a file to Drive or a video to YouTube, the browser receives a temporary token, valid for at most one hour, limited to that permission.
• Isolation between accounts: isolation is enforced by the database itself, row by row: a query made with one user's credentials cannot reach another user's data, even if the application has a bug.
• Internal access: access to the server and the database is restricted to the responsible technical team, with cryptographic key authentication.
• Retention and deletion: when you disconnect an account, we revoke access with the platform and delete the credential immediately. YouTube data not refreshed for 30 days is deleted, and you can request deletion of all your data whenever you want.

The modules in each account are enabled by the subscribed plan or by the free trial — or, in accounts administered by LUME, a mentor or an agency, by whoever administers the account.

No system is infallible. If a security incident occurs that may pose a significant risk, we will notify the affected data subjects and Brazil's National Data Protection Authority (ANPD) within the deadlines set by law.

How long we keep data

We keep data while the account is active — including when the free trial ends without a plan, so everything comes back if you subscribe; you can request deletion whenever you want. Once the relationship ends, we keep what is necessary to comply with legal or tax obligations or for our defense in legal proceedings, and delete the rest. Financial data usually has a longer legal retention period than other data.

Your rights

The LGPD guarantees you the following rights over your personal data:

• Confirm whether we process your data, and access it.
• Correct incomplete, inaccurate or outdated data.
• Request anonymization, blocking or deletion of unnecessary or excessive data.
• Request portability to another provider.
• Revoke your consent and request deletion of the data processed based on it.
• Know who we share your data with.
• Object to processing, when it is not based on another legal basis.

To exercise any of them, email contato@wearelume.com.br. We respond within 15 days. If you are the client of someone who uses the Hub, you can contact us directly — and we will reach out to whoever controls that data.

Cookies and ad measurement

Necessary storage, always: the browser's local storage keeps you signed in and remembers display preferences, such as the theme. The Hub does not work without it, and it is not used for measurement or ads. Clearing the site data in your browser undoes all of this, at the cost of having to sign in again.

Google's, only if you allow them: on the LUME Hub website and app (lumehub.me), we use Google Analytics and Google Ads, Google services, to understand in aggregate how the pages are used, measure the results of LUME Hub's ads and show those ads to people who have already visited the website, on Google's ad network. They are only turned on with your consent (Article 7, item I, of the LGPD), given in the cookie notice: without it, the website does not load any Google tool, does not set measurement cookies and does not send anything to Google.

With your permission, Google receives:

• the pages visited, by address without the filters and searches you type, and where the visit came from (ad, search, link or campaign);
• the device and browser type and the approximate region, which Google itself estimates;
• notice that something happened: an account created for the free trial, the start of a plan subscription, a confirmed subscription (with the amount, the currency and an internal subscription code, so the same purchase is not counted twice), a click on our WhatsApp, a contact form submission and a LUME Hub diagnostic submission.

Never sent to Google: your name, email, WhatsApp number or password, or anything you write in forms or store in the Hub. This is unrelated to the data from the accounts you connect to the Hub (described above), which is never used for advertising. In Google Analytics, Google signals (cross-device matching with your Google account) are turned off. LUME's admin area is not measured, and the pages LUME Hub clients publish through the platform (forms, landing pages, proposals) and custom-branded addresses do not load this measurement.

Cookies and expiration: Google Ads sets cookies starting with _gcl_ (such as _gcl_au and _gcl_aw), valid for up to 90 days; Google Analytics sets the _ga and _ga_7097TCDKGZ cookies, valid for up to 13 months. Google may also use cookies on its own domains to show and measure ads, as described in Google's advertising policy. In Google Analytics, browsing data is kept for up to 14 months; it may be processed outside Brazil, under Article 33 of the LGPD.

Where the visit came from: with your permission, the browser also stores, for up to 90 days, the campaign codes from the address through which you arrived (the utm_* parameters and the Google Ads click identifiers: gclid, gbraid and wbraid). They are used to know which ad brought the visit and, in LUME Hub's free diagnostics, they are sent along with the submission, so we know which campaign brought the contact. Before you respond to the notice, these codes only carry over in links from one page of the website to another, without being stored; if you decline, nothing is stored.

How to revoke: your choice is stored in this browser for up to 12 months (or until we change the notice) and applies to both the website and the app. You can change it here at any time; if you decline, we delete this website's Google cookies and the campaign codes stored in the browser:

You can also delete cookies in your browser settings and manage the ads Google shows you in My Ad Center.

Minors

The Hub is not intended for anyone under 18, and we do not knowingly collect data from this age group. If we identify any, we delete it.

Changes to this policy

If we change anything significant, we update the date at the top of this page and notify you through the platform's channels. Continuing to use the Hub after that means you agree to the new version.