01About this Policy
This Privacy Policy applies to all products in the Bynar platform: the Command Center web app (used by dispatchers and supervisors), the Glass Cockpit tablet app (used by equipment operators in the cabin), the backend Edge Functions, and the landing page itself (bynar.tech).
It documents what we collect, why we collect, with whom we share, how long we retain, and the rights you, as a data subject, have under the LGPD.
Material updates are communicated through in-platform notices and via email to the administrators of customer companies.
02Who we are
Data controller
- Legal name: Blue Horizons LTDA
- CNPJ (Brazilian tax ID): 54.200.672/0001-70
- Address: Rua São Mateus, 396, room 101 — Sagrada Família, Belo Horizonte/MG, Brazil — postal code 31035-330
Data Protection Officer (DPO)
- Contact: privacidade@bluehorizons.com.br
- Response time for data subject requests: up to 15 business days (LGPD Art. 19).
Customer companies (mining operators that license the platform) act as controllers of their own employees' data. Bynar acts as a processor under LGPD Art. 5, VII, processing data solely under the customer's contractual instructions.
03Data we collect
We collect only the data needed to operate the platform. The inventory below lists, by category, exactly what is stored.
3.1 Identification and profile
Identification data
| User type | Data collected |
|---|---|
| Operators (employees table) | Name, badge number, email, phone, photo, date of birth, hire date, role, department, status (active/inactive). |
| Administrators (users table) | Name, email, phone, avatar, associated company. |
| Leads (landing page contact form and digital card) | Name, role, email, phone, company and operation details entered in the form; or just one contact (email or phone) on the digital card, with the associated employee, event and referral source. |
3.2 Authentication
- Operator PIN - stored only as a bcrypt hash; never in plaintext.
- Administrator password - managed by Supabase Auth (one-way hash).
- Device hardware ID (Android ID or iOS identifierForVendor) - used to bind a specific tablet to a specific piece of equipment.
- Device binding audit history (which tablet was paired with which equipment, by whom, and when).
3.3 Location (sensitive category)
- Real-time GPS coordinates: latitude, longitude, altitude, speed and heading, captured roughly every 10 seconds.
- Collection occurs only during the work journey recorded in Glass Cockpit (from operator login to logout/shift end).
- Full journey trails, stored as encoded polylines.
- Geofence entry/exit events configured by the customer.
Purpose: operational safety (tracking heavy equipment at risk), cycle-time monitoring, dynamic task dispatch, and operational reporting to the end customer.
3.4 Operational metrics
- Equipment hour meter and odometer.
- Duration of work journeys.
- Task assignment, acceptance and rejection (including free-form reason when the operator rejects a task).
- Minute-by-minute activity-code timeline (activity_logs table).
- Execution timeline of task segments.
3.5 Media
- Pre-operation checklist photos (up to 5 per item), compressed to WebP and stored in Supabase Storage region sa-east-1 (Sao Paulo).
- User avatars uploaded by the data subjects themselves.
3.6 Audit
- History of who assigned, forced or closed tasks, with timestamps.
- Messages sent from the dispatcher to the operator (notifications table).
3.7 Commercial contact (landing page and digital card)
- Landing page form: name, role, email, phone (optional), company, operation type, region, equipment and operator counts, shifts, equipment types, main operational challenge, and area of interest.
- Digital card (one-field ask): a single contact provided by the visitor (email or phone), the employee whose card was used, the originating event (when applicable), and the link's placement (business-card QR, badge QR, email signature, etc.).
04What we use the data for
Each data category is processed for the specific purposes listed below. We do not repurpose data without prior notice.
| Category | Purpose |
|---|---|
| Identification and profile | User onboarding, display of name in the app, company binding, operational communication. |
| Authentication | Verify identity at login, protect access to the system, bind tablet to equipment. |
| GPS location | Operational safety, task dispatch, cycle-time calculation, reporting to the customer. |
| Operational metrics | Production, productivity KPIs, bottleneck detection, operation optimization. |
| Media (checklist photos) | Proof of pre-operation inspection, evidence in case of incident, audit. |
| Audit | Traceability of operational decisions, incident investigation, compliance. |
| Commercial contact (leads) | Respond to the commercial interest expressed by the visitor and prepare a platform demonstration. |
05Legal basis for processing
The LGPD requires each processing activity to rely on a specific legal basis (Art. 7). Bynar does not rely on consent as the primary basis for operational data, because using the platform is part of the operator's employment relationship.
| Category | Legal basis (LGPD Art. 7) | Justification |
|---|---|---|
| Identification and profile | V - Contract performance; II - Compliance with legal obligation (Brazilian labor code) | Essential employee data tied to the employment relationship with the customer mining company. |
| Authentication (PIN/password/device ID) | V - Contract performance | Required to guarantee authorized access to operational systems. |
| GPS location | V - Contract performance; IX - Legitimate interest | Safe operation of heavy equipment; traceability required by the mining industry; protection of life and property. |
| Operational metrics | V - Contract performance; IX - Legitimate interest | Measurement of productivity and operational safety. |
| Media (checklist) | II - Legal obligation; V - Contract performance | Compliance with Brazilian occupational safety standards (notably NR-22 for mining). |
| Audit | II - Legal obligation; IX - Legitimate interest | Compliance, traceability required by internal and external audits. |
| Commercial contact (leads) | V - Preliminary steps related to a contract, at the data subject's request | The visitor does not yet have a contract with Bynar: by filling out the form or the digital card, they themselves request the initial commercial contact. The basis is LGPD Art. 7, V, its final clause - preliminary steps taken at the data subject's own request - not the performance of a contract that does not yet exist. |
07International data transfers
Some sub-processors (Vercel, Mapbox and Google Play) process data on servers located in the United States. For the data of users of customer companies (Command Center and Glass Cockpit), this transfer is grounded on LGPD Art. 33, II (transfer necessary for the performance of a contract with the data subject).
A visitor filling out the landing page contact form or the digital card does not yet have a contract with Bynar - so this specific data follows a different basis. Contact emails are sent through Resend, a US company acting as a processor in the United States; and the form's body itself first passes through the Vercel serverless function that serves /api/leads (transient processing, never persisted to a database). For both - Vercel, in this specific processing, and Resend -, the basis is LGPD Art. 33, IX, "a" (transfer necessary for preliminary steps related to a future contract, at the data subject's request), not Art. 33, II. The sa-east-1 (Sao Paulo) region configured in Resend controls only where the message is SENT from; Resend's control plane, delivery logs and dashboard are located in the United States regardless of that regional setting.
As an additional safeguard, sensitive data (including GPS trails, checklist photos and audit logs) is stored primarily in Supabase region Sao Paulo (sa-east-1). Routing through foreign services is limited to map tiling (Mapbox), asset delivery (Vercel CDN), app distribution (Google Play), and sending/receiving contact emails (Resend, Google Workspace).
08How long we store
We currently follow these general principles:
- Active operational data (journeys, tasks, metrics) is retained while the contract with the customer company is active.
- Audit data is retained for the legal period applicable to each category - including, where relevant, Brazilian labor and social-security statute-of-limitation periods.
- Upon contract termination with the customer, personal data is deleted or anonymized per the contractually agreed schedule.
- Data subjects may request earlier deletion under LGPD Art. 18, VI, subject to the exceptions of Art. 16.
Commercial contact (leads): since this data is not written to a table of ours, its retention follows Resend's own retention policy for send history and the retention policy of the comercial@bluehorizons.com.br mailbox itself. You may request earlier deletion of these messages by writing to privacidade@bluehorizons.com.br.
09How we protect the data
Technical and organizational measures in place to protect the data:
- Per-company isolation (multi-tenancy) - each customer's data is logically segregated via PostgreSQL Row Level Security (RLS).
- Operator PIN stored only as a bcrypt hash - never in plaintext.
- Administrator passwords handled by Supabase Auth with a one-way hash.
- Data in transit always over TLS 1.2 or higher (HTTPS).
- JWT-based authentication (JSON Web Tokens) with short expiry.
- Automatic audit of critical operations (task assignment/force, equipment changes).
- Production data access restricted to authorized engineers, logged.
- Periodic backups with encryption at rest.
Despite these measures, no system is fully immune. In the event of a security incident with relevant risk to data subjects, we will notify the ANPD and the affected individuals as required by LGPD Art. 48.
10Your rights as a data subject (LGPD Art. 18)
As a data subject, you have the following rights guaranteed by the LGPD:
- Confirmation that we process your data.
- Access to the data we hold about you.
- Correction of incomplete, inaccurate or outdated data.
- Anonymization, blocking or deletion of unnecessary or excessive data, or data processed in violation of the LGPD.
- Portability of data to another service provider, subject to trade and industrial secrecy.
- Deletion of personal data processed on the basis of consent, subject to LGPD Art. 16 exceptions.
- Information about the public and private entities with which we share data.
- Information about the possibility of withholding consent and the consequences of doing so.
- Revocation of consent, where applicable.
- Right to lodge a complaint with the ANPD for non-compliance.
12Children and adolescents
Bynar does not intentionally collect data from individuals under 18 years of age. The platform is for professional use only, by workers employed by customer companies (mining operators), all of legal age as required by Brazilian labor law.
If we identify inadvertent collection of minors' data, we will delete it immediately.
13Automated decisions
Bynar does not perform profiling or make fully automated decisions that produce significant effects on the data subject (such as automatic salary, dismissal or promotion decisions).
Operational metrics produced by the platform serve as informational input for human decisions made by supervisors and managers of the customer company. Under LGPD Art. 20, you have the right to human review of decisions that affect your interests.
14Changes to this Policy
This Policy may be updated to reflect changes in our services, applicable law or industry best practices. The "Last updated" date at the top of the page indicates the current version.
Substantive changes (new data categories, new sub-processors, changes in purposes) will be communicated reasonably in advance by email to customer-company administrators and via prominent in-app notice.
15Brazilian National Data Protection Authority (ANPD)
If you are not satisfied with how we handled your request, you have the right to lodge a complaint directly with the Brazilian National Data Protection Authority.
- Official website: gov.br/anpd
- The ANPD is the Brazilian federal agency in charge of overseeing personal data protection and enforcing the LGPD.
16Version history
History of substantive changes to this Policy.
| Version | Date | Summary |
|---|---|---|
| 1.0 | 2026-05-27 | Initial publication. |
| 1.1 | 2026-08-26 | DPO contact corrected to privacidade@bluehorizons.com.br; the incorrect hyphenated variant of the landing domain corrected to the real domain (miningops.com.br); Resend and Google Workspace listed as sub-processors for the commercial-contact (lead) flow; legal basis (Art. 7, V) and international transfer (Art. 33, IX, "a") for commercial contact detailed; a data-collected entry and a retention entry for leads added; Vercel's international-transfer basis in this flow reclassified from Art. 33, II to Art. 33, IX, "a"; the visitor's IP address added among the data processed. |