After you activate your device’s geolocation functionality and accept the permissions required by the application to use it, Inloco starts to collect location and visit data safely, without identifying you directly. This data is consolidated into clusters - user groupings based on similarities - to generate visit flow metrics; send you contextualized messages through push notification technology; and validate your address without the need for document checks.
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Inloco does not collect unique static identifiers of devices (IMEI and MAC), associated accounts (e-mail address and phone number) or civil identification data (name, social security number etc). Neither do we collect sensible data, by blocking visit counts to locations that could allow us to infer any information such as sexual orientation, health condition, ethnicity, religion or political opinions; or children or teenagers’ data, by not making partnerships with child/teenage-oriented apps.
The data collected by Inloco is consolidated into groups based on similarities, called clusters, in order to prevent individuals from being identified. In addition, this data is protected by hash and encryption functions, decreasing even more the risks of identification.
We believe that the use of a geolocation technology developed with privacy by design in mind, such as ours, is the safest and most efficient solution to fight this pandemic. That’s why we took the following initiatives:
To learn more about our initiatives, visit our website.
¹ As stated in the topic “What does Inloco do to protect the privacy of its users?”, generally, we block visits to locations that we consider “sensitive” as they may allow the inference of sensitive information about users, such as health data. However, under exceptional circumstances and in view of the atypical and emergency situation that we are experiencing, we will count unidentified visits to hospitals and health posts, aiming at the efficient allocation of health professionals and patients, especially considering that one of the greatest dangers brought by coronavirus is not the severity of its resulting disease, but the speed of transmission and consequent overcrowding of health systems. The visit counts will be made with representative precision using an algorithm called HyperLogLog, without storing unique device identifiers. This means that we will know how many devices visit these establishments, but not which ones. Visits will be stored in a separate environment from our database and eliminated at the end of the COVID-19 crisis.
No personal data will be shared with any third parties for the purpose of fighting COVID-19. Inloco made statistical information about the COVID-19 pandemic publicly available for anyone or any institution to use as an instrument of study and research, being all data shared completely anonymous. Therefore, it is impossible to infer any information about a natural person from the indexes and metrics shared by Inloco.
Regarding the integration of our technology to government apps, push notifications will be sent by us, through those apps, to clusters of users when we consider opportune. Thus, no individual can be identified in that action.
According to Article 1798.140 (o) (1) of the California Consumer Privacy Act (CCPA), “‘Personal information’ means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Article Article 1798.140 (o) (3) states that “‘Personal information’ does not include consumer information that is deidentified or aggregate consumer information.”
Article 4 (1) of the EU and EEA’s General Data Protection Regulation (GDPR) defines '”personal data” as “any information relating to an identified or identifiable natural person ('data subject'); (...)'” Recital 26 (5-6) of the same regulation states that “The principles of data protection should therefore not apply to anonymous information, namely information which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable. This Regulation does not therefore concern the processing of such anonymous information, including for statistical or research purposes.”
Article 5, I, of the Brazilian General Data Protection Law (LGPD) defines “personal data” as “information related to an identified or identifiable natural person.” Article 12 of the same law states that “anonymized data will not be considered personal data for the purposes of this Law, except when the anonymization process to which they were submitted is reversed, using only their own means, or when, with reasonable efforts, it can be reversed.”
² For Californian law, "household" corresponds to a group that (1) reside at the same address, (2) share a common device or the same service provided by a business, and (3) are identified by the business as sharing the same group account or unique identifier. The term was included in the CCPA to prevent data controllers from claiming not to identify individuals who share the same device. Available at: https://oag.ca.gov/sites/all/files/agweb/pdfs/privacy/ccpa-text-of-mod-clean-020720.pdf?. Accessed on: 04/01/2020.
Yes, Inloco's partnership with government institutions is legal, concluded through terms of donation and cooperation, to provide free access to the Social Isolation Index created by Inloco.
This index can assist in fighting against COVID-19 and solving the biggest issue of current public interest: the right to health, provided for in the Brazilian Constitution, which must be guaranteed by the State through public policies. The index, which can accurately measure the level of social isolation in a given neighborhood, city and even the country, is not able to identify or report the location of a single person, since the data are always aggregated by regions. Therefore, when using Inloco technology, the fundamental right to privacy is also preserved.
The use of location data, aiming to control the pandemic, is an emergency measure that can flatten the disease evolution curve and reduce risks for Brazilians and residents in Brazil during the State of Public Calamity. Countries like Taiwan, Japan and South Korea have adopted similar strategies, with great effectiveness.
It is also important to clarify that the Brazilian General Data Protection Law authorizes personal data to be used for the purposes of implementing public policies aimed at “protecting life or physical safety” (Art. 7, VII, LGPD). Although the law is not yet in force, it is a good parameter for the analysis of the data processing by Inloco, especially because LGPD was inspired by foreign regulations already in force, such as the General Data Protection Regulation (GDPR) of the European Union. This regulation clarifies that “some types of processing may serve both important grounds of public interest and the vital interests of the data subject as for instance when processing is necessary for humanitarian purposes, including for monitoring epidemics and their spread or in situations of humanitarian emergencies, in particular in situations of natural and man-made disasters.” (Recital 46, 3, GDPR).
Finally, the Prosecutor’s Office for the Federal District and Territories (MPDFT), through the Data Protection and Artificial Intelligence Special Unit (Espec), decided that the business model of the company Inloco is legal, in view of the existing regulatory framework, after all, there is no collection data that allows direct linking to the personal data subject.
To learn more, read the article “Means of Controlling the COVID-19 Pandemic and the Inviolability of Privacy” written by Inloco's Head of Data Privacy.
The integration of Inloco’s technology with government applications will be terminated and the data collected through them will be promptly eliminated by the end of the COVID-19 crisis. We will not continue partnerships signed with government institutions to fight the pandemic or the data processing resulting from these partnerships.
Data used to assist institutions at this time of crisis will not be stored or used for business purposes, under any circumstances.
Privacy is Inloco's main value and an essential right to ensure individual freedom and democracy. Ten years ago, since our foundation, we made a commitment to society, because we believe that it is not necessary to give up privacy to receive convenience.
Following the same principle, we believe that it is not necessary to give up privacy to beat coronavirus. For that reason, we are working to prevent the pandemic control from having the long-term consequence of strengthening surveillance and privacy violation policies.
³ Available at: https://content.inloco.com.br/hubfs/Estudos%20-%20Conte%C3%BAdo/Coronavirus/Means%20of%20control%20to%20the%20COVID-19%20pandemic%20and%20the%20inviolability%20of%20privacy.pdf?hsCtaTracking=f950a9ca-e25e-4c67-b3dd-9a9cd7e174fc%7Cc0b3e038-0366-4beb-abc4-9e165bf71089. Accessed on: 04/02/2020