Aria Privacy Policy

Version 2026.05.1 — en-US

Draft for legal review. This document is an operational baseline for Aria and must be reviewed by qualified counsel before publication to the public, customers, employees or contractors.

1. Who we are, roles and material scope

This Policy describes how Aria Tecnologia Ltda., its affiliates, successors or operational entities indicated in the applicable agreement processes personal data in the context of website, admin console, APIs, mobile app, field modules, integrations, transactional communications and related Aria platform services.

In B2B relationships, the Customer (tenant) is generally the controller of data relating to its users, employees, field contractors and end customers recorded or monitored through the platform. Aria predominantly acts as a processor, carrying out processing necessary to deliver the contracted service based on instructions compatible with law and console settings.

Aria may act as an independent controller where it processes data for its own purposes, such as billing, fraud prevention, information security, legal compliance, commercial relationship, product improvement in aggregated or anonymised form where feasible, and responses to authorities.

2. Categories of personal data

Depending on subscribed modules and use of the platform, we may process the following categories, among others:

• Identification and registration: name, email, phone, documents, company, role, account and tenant identifiers.
• Tax identification (provider — app): CPF when required for sign-up via the mobile app, stored in normalised form and unique across the platform to prevent duplicate provider accounts, except where specific legal or contractual arrangements apply.
• Identification documents (optional in the flow): document images, OCR, metadata and extracted data when the provider chooses to upload them; not uploading does not waive identifiers required by the product (e.g. a valid CPF).
• Authentication and security: credentials, session tokens, login records, IP, device type and security events.
• Field operations and assets: work orders, checklists, signatures, photos, short videos, audio or voice notes, barcode reads, geolocation (including background where enabled), geofences, time tracking and clock events.
• Biometrics (facial): templates or measurements only where the Customer enables the feature and there is a lawful basis and transparency for data subjects.
• Subscription billing data: information required for invoicing, tax documents and plan management (via payment processors where applicable).
• Communications: transactional, in-app, email and push notifications.
• Telemetry and diagnostics: technical logs, failures, performance and usage metrics for reliability and support.
• AI and reporting: inputs sent to AI features configured by the Customer and outputs displayed in the product, within product limits.

2.1. Facial data and face recognition (mobile app)

Where the Customer enables biometrics, time clock with selfie, facial checklist fields or provider KYC, the app may process facial data as follows:

• Collection: photographs containing the face (enrollment reference selfies, time-clock and task photos); biometric templates (embeddings) generated by CompreFace (FaceMatch) from reference photos; verification metadata (similarity score, timestamp, engine, audit).
• We do not collect: Face ID / Touch ID templates from the device — native authentication stays on the OS. Real-time on-device face detection (ML Kit) is for framing only and does not store local templates.
• Purposes: identity at time clock; presence on work orders/checklists; provider KYC; fraud prevention and audit. No advertising or sale of data.
• Sharing: contracting company (tenant); Lansolver servers (/uploads/face-enrollment/ and operational evidence); CompreFace sub-processor (templates segregated by tenant/user); optional OpenAI Vision for enrollment selfie quality only.
• Retention: reference biometrics while the account is active; deletion/anonymisation after closure; time-clock evidence per Customer legal obligations. Contact: dpo@lansolver.com or in-app account deletion.
• Legal basis and notice: sensitive data (LGPD Art. 11); consent and/or contract/legitimate interest as applicable. In-app BIOMETRIC_NOTICE when required.

3. Sensitive data and occupational health

Certain forms or flows may capture sensitive data (including, in some scenarios, health or occupational safety data) by decision and configuration of the Customer. In those cases the Customer is responsible for informing data subjects, applying applicable legal bases (including LGPD Art. 11 hypotheses), minimisation and retention periods. Aria restricts internal access to what is strictly necessary and enforces logical segregation between tenants.

4. Purposes of processing

We process data to provision and operate the platform; authenticate users; register and validate service providers in the app (including CPF uniqueness and onboarding flows); synchronise offline data; evidence service execution; prevent fraud and abuse; send operational communications; provide support; perform contracts; invoice; comply with legal or regulatory orders; conduct audits and defend rights; improve performance, stability and security; and, where applicable, enable location, biometrics, AI and integrations authorised by the Customer.

5. Legal bases (LGPD and equivalents)

Depending on role (controller/processor) and context, LGPD Art. 7 hypotheses may apply, including contract performance; legal obligation; regular exercise of rights; protection of life; health protection; legitimate interests (with balancing); credit protection; and consent where required. For sensitive data, LGPD Art. 11 applies. Where data subjects are in the European Union, GDPR bases may apply complementarily without prejudice to Brazilian law governing the agreement.

6. Cookies and similar technologies

Websites and web apps may use cookies, local storage and similar technologies as described in the separate Cookie Policy. Non-essential cookies follow consent settings available in the public interface or onboarding flow, as implemented.

7. Recipients, sharing and subprocessors

We may share data with subprocessors and suppliers that support infrastructure (cloud, database, CDN), maps, push notifications, email, object storage, payments, e-signature, biometrics (when enabled), AI, observability and support. We require data-protection clauses and segregation. We do not sell personal data in the sense of a commercial sale for independent third-party marketing. We may disclose data to authorities pursuant to valid legal process or to defend rights in proceedings.

8. International transfers

Part of our infrastructure or subprocessors may be located outside Brazil. Where international transfers occur, we adopt instruments and measures compatible with the LGPD (including standard clauses, risk assessment and technical safeguards). Where the GDPR applies, we observe equivalent transfer requirements.

9. Retention and deletion

We retain data for as long as necessary for the purposes described, legal obligations, dispute resolution and defence of rights. Specific periods by category (e.g. raw location telemetry vs. legal evidence) are set out in the Data Retention Policy. Upon contract termination we will delete, anonymise or return data according to the agreement and the Customer’s documented instructions, subject to legal exceptions.

10. Data subject rights and contact channels

Under the LGPD, data subjects may request confirmation of processing, access, correction, anonymisation, blocking or deletion, portability (where applicable), information on sharing, information on the possibility of not providing consent and consequences, withdrawal of consent and review of automated decisions (where applicable). In B2B contexts many requests must be handled by the Customer controller; Aria will provide reasonable assistance to the Customer within legal timeframes. Aria channel: dpo@lansolver.com. Data subjects may also contact the Brazilian National Data Protection Authority (ANPD) as provided by law.

11. Security and incidents

We implement risk-proportionate technical and organisational measures, including logical tenant segregation, access controls, event logging, encryption in transit, secure development practices, backups and monitoring. Should a relevant incident involving Customer data occur, we will notify the Customer as required by law and contract, with reasonably available information to support the controller’s duties towards data subjects and authorities.

12. Automated processing, profiling and AI

AI or automated rules may suggest routes, pre-fill fields, classify operational risk or assist triage, depending on product configuration. Decisions producing legal or similarly significant effects will observe applicable safeguards, including transparency and, where required, human review or high-level information on logic. The Customer must assess impacts on its employees, contractors and end customers when enabling such features.

13. Children and adolescents

The platform is not intended for children under 16 as a target audience. Customers must not register minors’ data without a specific legal basis, assisted consent where required and appropriate internal policies.

14. Changes to this Policy

We may update this Policy to reflect legal, product or risk changes. Material changes will be communicated by reasonable means (including console, institutional email or in-app consent flows). Published versions may require recorded acceptance where the nature of the change so requires, according to the environment’s compliance settings.

Legal & privacy contact: dpo@lansolver.com