No faces
No facial recognition, no representation of faces, no attempt to find out who someone is.
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, Brazil's data protection law, applies.
In short
Pseudonymised
Trajectories and sessions are pseudonymised personal data, fully covered by the LGPD, the Brazilian data protection law. Only irreversible aggregates are treated as anonymised.
Clear roles
The retailer decides how the data is used (the controller) and Afluxion processes it on their behalf (the processor). No real footage is processed without a signed contract and data processing agreement.
Data in Brazil
Hosted in a Brazilian region by default, with records of processing, access audit and an incident plan.
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.
- Using the employee classification to assess or punish an individual.
- Age estimation, age groups or any function aimed at minors.
Exact terminology
Recorded 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 number of people per group and no session identifiers, are treated as anonymised. In contracts, on screen and in Afluxion materials, this data always goes by that name.
Roles
| Obligation | Retailer (controller) | Afluxion (processor) |
|---|---|---|
| Purpose and legal basis | Defines | Provides technical input |
| In-store and employee notices | Installs | Provides the templates |
| Data subject requests | Responds | Supports with records and deletion by store and period |
| Security of processing | Consulted | Responsible for infrastructure and processing |
| Incident communication | Assesses and reports to the ANPD | Notifies 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 for each store, with a data protection impact assessment before the first video is processed.
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: since it does not know who each person is, the platform cannot find "one person's data". It reports which kinds of data and which periods were 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 privacy masking of shop windows, the 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.