Terms of Use

1. The service

Lubi CRM is a CRM for WhatsApp and Instagram conversations, contacts, sales funnel, broadcasts on the official WhatsApp and publishing on Instagram, offered by COMAL EDTECH LTDA. It works on its own.

2. Access

Access is by an active lubi.bot account. There is no open sign-up. Signing in means you accept these terms and the privacy policy.

3. Accounts and content

You own your Meta accounts and answer for what you send and publish to Meta, to recipients and to third parties.

4. Your customers' data

You are the controller and you guarantee the legal basis. COMAL is the processor and follows your instructions and the privacy policy.

5. Consent

You obtain consent before messages that you start, keep the proof, and honor every request to leave a list. The consent statement of a broadcast is recorded with its date.

6. Permitted use

Use Lubi CRM to serve and talk to your own customers.

• You may not use it to offer a general-purpose AI assistant over WhatsApp.
• You may not send spam or use cold lists.
• You may not follow or like by automation.
• You may not publish illegal content, or content that Meta's rules forbid.
• You may not try to reach the data of another account holder.

7. Meta rules

You follow the terms and policies of Meta (WhatsApp Business, the Business Messaging Policy, Instagram and the Community Guidelines). Meta may change its rules and limit or block numbers and accounts, and COMAL is not responsible for that.

8. Message charges

Meta charges WhatsApp messages to the card you register with it, on your account, at its own rates. COMAL charges only for your lubi.bot account, under the terms of lubi.bot.

9. Automatic replies

Lubi CRM does not send automatic replies for you.

10. Human service

Whoever uses automatic replies offers a clear way to talk to a person.

11. Availability and suspension

Functions may change. COMAL may suspend numbers or broadcasts for a violation or by order of Meta, with no prior notice when that is needed to prevent harm or a block.

12. Liability

You answer for the damage caused by breaking these terms (fines, blocks, complaints) and reimburse COMAL for it. Liability is limited to the extent the law allows, without removing any consumer right that cannot be removed.

13. Ending and deletion

You can disconnect numbers and accounts and delete data at any time. What happens to the data follows the privacy policy and the data deletion page.

14. Changes to the terms

We post changes on this page. For a relevant change we also write to account holders by e-mail, 30 days ahead.

15. Law and venue

Brazilian law applies, with the courts of Itajaí-SC, saving the domicile of the consumer.

16. Contact

admin@lubi.bot. COMAL EDTECH LTDA, CNPJ 69.649.487/0001-34, Rua Dr. Pedro Ferreira, 155, Sala 00500, Box 144, Centro, Itajaí-SC, 88301-030.