Privacy Policy

Effective Date: March 23, 2026

Introduction

Aluga Facil App ("Company," "we," "us," or "our") operates the Aluga Facil App ("App"). This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information through our App, website, and related services.

We are committed to protecting your privacy and ensuring transparency about our data practices. This policy complies with applicable data protection laws, including GDPR, LGPD, and other international privacy regulations.

1. Information We Collect

1.1 Information You Provide Directly

  • Account Information: Name, email address, phone number, profile photo, password
  • Property Information: Property descriptions, images, location details, amenities, pricing
  • Profile Data: Bio, verification documents, rental history, preferences
  • Communication: Messages, inquiries, reviews, ratings provided through the App
  • Payment Information: Billing address, transaction history (processed securely through third-party providers)

1.2 Information Collected Automatically

  • Location Data: Approximate location data (GPS coordinates when you enable location services)
  • Device Information: Device type, operating system, unique device identifiers, mobile network information
  • Usage Data: Pages visited, features used, search queries, time spent in the App, clicks, interactions, in-app search history
  • App Performance: Crash logs, diagnostics, performance data
  • Cookies & Analytics: Browser cookies, web beacons, analytics data to understand user behavior and improve the App
  • IP Address: For security purposes and to provide location-relevant content

1.3 Information from Third Parties

  • Payment processors (transaction confirmation data)
  • Social media platforms (if you link your account)
  • Identity verification services for KYC/AML compliance
  • Other users (reviews, ratings, feedback about your interactions)

2. How We Use Your Information

We use your personal data for the following purposes. This table clearly shows which data is used for which purpose:

Data TypePurposes of Use
Personal Info (Name, Email, Address, Phone)
  • App functionality & account management
  • Analytics & user behavior tracking
  • Developer communications & support
  • Fraud prevention & security compliance
  • Advertising or marketing (with consent)
  • Personalization & account management
Location Data (Approximate)
  • App functionality (showing nearby properties)
  • Analytics & user behavior
  • Developer communications
  • Fraud prevention & security
  • Personalization & recommendations
Photos & Videos
  • App functionality (displaying listings)
  • Fraud prevention & security checks
  • Personalization & recommendations
  • Account management
App Activity (Interactions, Search History)
  • App functionality & feature improvement
  • Analytics & performance tracking
  • User experience personalization
  • Account management
App Performance Data (Crash Logs, Diagnostics)
  • App functionality & bug fixes
  • Analytics & performance monitoring
  • Developer communications & support
Files & Documents
  • App functionality (profile management)
  • Fraud prevention & security
  • Personalization & account management
Device IDs & Identifiers
  • App functionality & session management
  • Analytics & tracking
  • Personalization

Specific Use Cases

  • Provide Services: Creating accounts, matching renters with properties, processing transactions
  • Improve User Experience: Personalizing content, recommendations, feature development based on your usage patterns
  • Communication: Sending transactional emails, support responses, App updates, promotional content (with opt-in)
  • Safety & Security: Fraud prevention, account verification, abuse detection, compliance with legal obligations
  • Analytics: Understanding user behavior, improving App performance, conducting research
  • Legal Compliance: Tax reporting, dispute resolution, regulatory requirements (KYC/AML)
  • Marketing: Personalized advertisements, surveys, market research (always with your consent)

3. How We Share Your Information

3.1 With Other Users

Property listings, profile information, and reviews are visible to other users of the App. Location data is used to show nearby properties.

3.2 With Service Providers

We share data with trusted third parties including payment processors, cloud storage providers, analytics services, communication platforms, and identity verification services. These providers are contractually bound to protect your data.

3.3 Legal & Safety Reasons

We may disclose information when required by law, court order, or to protect our legal rights, your safety, or the safety of others.

3.4 Business Transfers

In case of merger, acquisition, bankruptcy, or asset sale, your information may be transferred as part of the transaction. We will notify you of any such change.

3.5 Aggregated & De-Identified Data

We may share aggregated or de-identified data with partners for analytics, research, and marketing purposes without identifying you.

4. Data Security

We implement industry-standard security measures including:

  • SSL/TLS encryption for data in transit
  • AES-256 encryption for sensitive data at rest
  • Regular security audits and penetration testing
  • Secure authentication mechanisms (passwords, two-factor authentication)
  • Access controls and role-based permissions
  • Incident response procedures

However, no method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

5. Data Retention

  • Active Accounts: Data is retained while your account is active
  • Deleted Accounts: Most personal data is deleted within 30 days of account deletion
  • Transaction Data: Retained for 7 years for tax and legal compliance
  • Analytics Data: Retained for 12 months then aggregated
  • Legal Claims: Data retained until dispute resolution is complete

6. Your Rights & Choices

Depending on your location, you may have the following rights:

6.1 Right of Access

You have the right to request a copy of the personal data we hold about you.

6.2 Right to Correction

You can request that we correct inaccurate or incomplete information.

6.3 Right to Erasure

You can request deletion of your personal data (subject to legal obligations). See our Data Deletion Policy for details.

6.4 Right to Restrict Processing

You can request that we limit how we use your data in certain circumstances.

6.5 Right to Data Portability

You have the right to receive your data in a portable format and transfer it to another service.

6.6 Right to Opt-Out

You can opt out of marketing communications, cookies, and tracking through your account settings.

6.7 Exercising Your Rights

To exercise any of these rights, contact us at privacy@exinndigital.com. We will respond within 30 days.

7. Cookies & Tracking Technologies

We use cookies to:

  • Essential: Maintain session, security, and basic functionality
  • Analytics: Track user behavior and app performance (via Google Analytics, Mixpanel)
  • Marketing: Deliver personalized ads (with your consent)

You can control cookie preferences through your browser or app settings. Disabling cookies may limit functionality.

8. Children's Privacy

Our App is not designed for children under 10 years old. Users aged 10-12 may only use the App with parental or guardian consent. Users under 13 cannot create independent accounts.

If we discover that a child under 10 has provided personal information, we will delete it immediately. Parents/guardians can contact us to review or delete a child's information.

9. International Data Transfers

Your information may be transferred to, stored in, and processed in countries other than your country of residence, including countries that may not have the same data protection laws. By using our App, you consent to such transfers.

We ensure adequate safeguards are in place, including Standard Contractual Clauses and Privacy Shield mechanisms.

10. Changes to This Privacy Policy

We may update this policy periodically. Material changes will be communicated via email or prominent notice in the App. Your continued use of the App constitutes acceptance of the updated policy.

11. Contact Us

For privacy-related inquiries, complaints, or to exercise your rights: