Privacy by design

Measuring movement without identifying anyone

Afluxion sees currents, not people. This page describes what the product does, what it never does and how the LGPD applies.

What we never do

  • Facial recognition or storage of any representation of a face.
  • Finding out the civil identity of a person from an image.
  • Individual disciplinary use of the employee classification.
  • Age estimation, age groups or any function aimed at minors.

Exact terminology

Raw video is personal data. Trajectories, sessions and events are pseudonymised personal data, and the LGPD applies to them in full. Only irreversible aggregates, with a minimum population per bucket and no session identifiers, are treated as anonymised. Afluxion materials never call operational data anything else.

Roles

ObligationRetailer (controller)Afluxion (processor)
Purpose and legal basisDefinesProvides technical input
In-store and employee noticesInstallsProvides the templates
Data subject requestsRespondsSupports with records and deletion by store and period
Security of processingConsultedResponsible for infrastructure and pipeline
Incident communicationAssesses and reports to the ANPDNotifies the controller without delay

No real footage is processed before the contract and the data processing agreement are signed. The working legal basis is the controller's legitimate interest, assessed per deployment, with an impact assessment before the first processing.

Retention, deletion and rights

  • Short, configurable retention with recorded automatic deletion.
  • On-demand deletion by store and period.
  • At the end of the contract, deletion or return of the data with proof.
  • An honest limit: without a civil identification key, the platform cannot locate "one person's data". It reports the categories and periods processed and runs deletions by store and period.

Infrastructure

  • Hosting in a Brazilian region by default.
  • Per-customer isolation, access audit and records of processing operations.
  • Mandatory masks on shop windows, street and payment terminals.
  • Incidents: containment, notification to the controller without delay and root-cause analysis.

The positions on this page are working hypotheses of the product, built on the LGPD and public ANPD materials, validated with a lawyer and a data protection officer before the first processing of real data.

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