EDF EN DO BRASIL PARTICIPAÇÕES LTDA. (“EDFR” or “Organization”) committed to fostering a relationship of trust and transparency with all our customers, partners and all those who maintain a relationship with us (“you”). For this reason, we assure you that we collect information through our platform, social networks and other channels (e.g. e-mail) within a secure environment, and in full compliance with all applicable privacy standards.
We have crafted this Privacy Notice (“Notice”) to help you understand how we process the information you share with us and how you can exercise your rights pertaining to this informatio.
Our Platform and other open channels, such as email, are designed exclusively for adults. Therefore, we do not intend to collect or process personal data from individuals under the age of eighteen (18). If we inadvertently collect personal data from someone under this age, we will promptly delete this information from our databases.
Our utmost priority is to safeguard the privacy and security of your personal data. Rest assured, any information you provide will be processed securely and within the parameters outlined in this Notice.
Should you have any queries or concerns about the protection of your personal data or this Privacy Notice, we have established a dedicated contact channel for your convenience: DPO@edf-re.com.br. Please do not hesitate to reach out to us.
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WOULD IT BE HELPFUL IF WE CLARIFIED SOME OF THE TECHNICAL TERMS IN THIS NOTICE FOR YOU?
| Term/Expression | Meaning |
|---|---|
National Data Protection Authority (or ANPD) | It is the public authority belonging to the federal public administration, responsible for the regulation, inspection, and application of administrative penalties, related to the protection of personal data. |
| Personal data | Any information relating to an identified or identifiable natural person; an identifiable person is a person who can be identified, directly or indirectly, by reference to an identifier, such as a name, an identification number, electronic identifiers, among other information that identifies him or allows his identification. |
| Sensitive personal data | Is the special category of personal data, which is related to racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious, philosophical, or political nature, as well as data relating to health or sex life, genetic or biometric data. |
| Data Protection Officer (DPO) | The Data Protection Officer is the person in charge for the processing of personal data of the Organization and the main responsible person appointed to function as a communication channel with You and with the ANPD. |
| General Personal Data Protection Law (or LGPD) | Federal Law No. 13,709/2018. |
| Processor | Natural or legal person, governed by public or private law, who performs the processing of personal data on behalf of the controller. |
| Platform | EDFR‘s official channel for contacting and publicizing its services: https://edf-re.com.br/ |
| Third party | Any natural or legal person that EDFR has or will have a relationship with. This includes service provider, supplier, consultant, partner, third party contractors or subcontractors, tenants, space assignees, regardless of formal contract or not, including those who use the Organization’s name, provide materials, interact with public officials, the government or other third parties on behalf of EDFR. |
| Data subject | Natural person to whom the personal data refers. |
| Processing | It is any activity conducted with personal data, such as collection, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, updating, communication, transfer, sharing and extraction. |
1. HOW ABOUT A SUMMARY OF THE MOST PERTINENT INFORMATION?
To make this Notice easier to understand, we have provided a summary table of the information that will be presented to you in this document:
| WHO WILL PROCESS YOUR DATA? GET TO KNOW EDFR! | EDF EN DO BRASIL PARTICIPACOES LTDA., limited liability company with headquarters in the city of Rio de Janeiro, State of Rio de Janeiro, at Av. Almirante Barroso, 52, sal 1801, sal 1802, postal code 20.031-918, enrolled before the CNPJ/MF under no. 21.812.954/0001-79, is a organization focused on the development, manufacturing and running of wind and solar photovoltaic power generation projects. You can get to know more about us accessing our website here: https://edf-re.com.br/ EDFR is the entity in charge of processing your personal data and also who sets forth the purpose and means for this processing to take place. |
| HOW DO WE COLLECT YOUR DATA? | The information we process about you may have been provided directly by you to EDFR, by third parties or even collected automatically through our platform and other channels. |
| WHICH TYPES OF DATA ARE PROCESSED? | Personal data: name, date of birth, RG (ID), CPF, profession, job title, place of work, academic qualifications, address, telephone number, e-mail address, your image and voice, banking information and attributes associated with your electronic devices. |
| WHY DO WE NEED YOUR PERSONAL DATA? | For what purposes we use the information • For registration and verification purposes; To be able to communicate with you and conduct our opinion surveys; • To comply with our legal or regulatory obligations; • To allow the regular exercise of our rights; • To enable activities necessary for our organization; • Perform a contract you have entered into with us or carry out pre-contractual due diligence; • Recruitment and selection; • Preventing fraud and ensuring your safety; and • Requesting commercial proposals. |
| FOR HOW LONG DO WE KEEP YOUR DATA? | We store your personal data for as long as necessary to achieve the purposes for which it was collected. We will keep personal data in an anonymized form as much as possible, respecting the highest level of care and market security. |
| WHEN CAN WE SHARE YOUR DATA? | We may share your personal data with third parties in order to achieve the purposes for which it was collected. It may also be shared when necessary to comply with requests from judicial authorities or to fulfill legal or regulatory obligations. |
| HOW TO ENSURE YOUR RIGHTS AS A DATA SUBJECT? | We are committed to complying with all your rights as a data subject. For this reason, we have a communication channel to resolve any doubts, suggestions or requests regarding the processing of personal data collected. Please contact our DPO via e-mail: DPO@edf-re.com.br. |
2. HOW DO WE COLLECT YOUR PERSONAL DATA?
The information that the Organization processes about you may have been provided directly by you, by third parties or even collected automatically through our platform and other channels.
The information that the Organization processes about you may have been provided directly by you, by third parties or even collected automatically through our platform and other channels.
Let’s have a look to better understand in which scenarios we collect your personal data, shall we?
a. Data provided directly by you
Since the beginning of your interaction with us, you voluntarily provide us with information about yourself. For example, when you contact us via social networks or our customer service channels, when you participate in actions promoted or sponsored by us, interact with the content of our platform, via chat, e-mail or other tools; when you are involved with the management of a project, when personal data needs to be collected in order to prepare invoices for payment, or when you register to take part in a selection process on our website.
b. Data provided by third parties
In specific cases, the Organization may also receive some of your personal data through third parties. For example, information made avaliable by contracted parties of EDFR, such as consulting services, service providers and suppliers.
c. Data collected automatically
In some situations, the Organization may also collect personal data automatically, through the devices that you use to access our platform. This information helps in generating access statistics and, thus, getting to know our public better. This is important so that we can improve the platforms increasingly and adapt them to the most diverse audiences. Some of this personal data may be collected through cookies or similar technologies, as we will explain in a separate topic below.
3. WHICH TYPES OF DATA ARE PROCESSED?
To respect your privacy, we understand that all processing of personal data must be limited to the minimum necessary, relevant, and proportionate to allow the intended purpose to be conducted.
For this reason, the personal data we collect about you will vary depending on the relationship you choose to have with us, i.e. as a service provider, customer, visitor, partner, among others.
Please find below the main categories of your personal data that may be processed by us:
- Identification information: such as your name, age, gender, among others with relevance;
- Legal classification information: residential address, marital status, nationality, parentage;
- Contact information: telephone or cellphone number, personal or professional e-mail addresses;
- Image and voice: video recordings and photographs ;
- Financial information: such as current account and bank branch;
- Occupation and qualification personal data: profession, place of work, position, professional history, academic qualifications, diplomas and other training certificates; and
- Attributes associated with your electronic devices: date and time of access, user identification, management of cookie preferences and visited pages.
4. WHY DO WE NEED YOUR PERSONAL DATA?
The personal data we collect can be used as described in the table of contents below:
| Personal data category | Purpose |
|---|---|
Identification information Contact information Financial information | Contracting with clients, suppliers and service providers We will process your data so that you can act as one of our customers, suppliers or service providers, for registration and verification purposes. |
Identification information Financial information | Communication and Opinion Research We will process your personal data to respond to your requests or other interactions with us, such as by e-mail, chat or other tools of our platform. Receiving your responses to the EDFR Opinion Surveys, conducted in the context of implementing new projects, forwarding relevant information about our activities, such as changes in address and company structure. Finally, to also give updates that impact your relationship with us in respect of transparency, for example updates to this Privacy Notice. |
Identification information Image and Voice | Communication Actions We may process your personal data for the purpose of communicating and publicizing actions promoted or sponsored by EDFR on our website, social networks, as well as other communication channels. |
Identification information Contact information Legal classification information | Comply with our legal or regulatory obligations Your personal data may be used to meet our obligations provided by law and/or regulations of government agencies and orders or requests from tax authorities, the judiciary and/or other competent authority. For example, we can process personal data to issue invoices. |
Identification information Contact information Legal classification information | Allow the regular exercise of our rights Even after your relationship with us has ended, we may process some of your personal data to exercise our rights guaranteed by law, including as evidence in judicial, administrative or arbitration proceedings. |
Identification information Contact information Attributes associated with your electronic devices | Enable activities necessary for our Organization Based on our legitimate interest, we may also process your personal data in activities such as: improvements to our products and services, relationships with our customers and partners, analysis and reporting of company performance and internal consultations. In activities to support EDFR’s interests, we will always observe the limits of your expectation and the processing of personal data will not be to the detriment of your interests, rights, or fundamental freedoms. |
Identification information Contact information Financial information | Perform a contract you have entered into with us or carry out pre-contractual due diligence If you are a party to a contract with EDFR, or represent a company in a early stages of negotiation, we will process your personal data for the conclusion and performance of the contract, to ensure that the work is carried out and settled for. |
Identification information Contact information Occupation and qualification personal data | Recruitment and selection We disclose our vacancies on specialized websites, we also receive resumes through our website, indications of our employees, in addition to the resumes eventually left in person in our facilities. In these situations, we will process your personal data to analyze your resume, verify your competencies, curriculum information and whether you meet the specific requirements of the vacancy for which You have applied, as well as to follow up the selection process, where appropriate, in situations such as telephone contact or e-mail and for scheduling interviews. |
| Identification information | For your own safety We may process the personal data of our partners and suppliers to ensure their safety at work, with a view to enabling them to carry out the contracted services. |
Identification information Contact information | Business Proposals We may use your personal data to register you for the purpose of sending or receiving commercial proposals, in order to establish a relationship as our partner/supplier. |
5. WHAT ARE COOKIES AND WHAT ARE THEY FOR?
The cookie is a small text file that may be stored on your electronic devices while using our website. EDFR uses this tool for different purposes, such as generating access statistics, improving your experience on our Platform. The cookies we use are presented in the table of content as follows:
| Types of Cookies | What are they for? |
|---|---|
| Needed | Allow the website to load properly and allow you to navigate correctly, as well as make use of all available functionality. |
| Performance | They help to understand how visitors interact with our website by providing information about the areas visited, the time spent on the website and any problems encountered, such as error messages. |
| Functional | They allow our website to remember your previous choices, such as language, to provide a personalized experience. They also allow users to fill in fields for comments, among others. |
We emphasize that the acceptance of cookies classified as necessary are essential for the standard functioning of our website. This means that in case you disable them this may affect your browsing experience and also invalidation of access.
For more information on cookies used by EDFR, please access our Cookie Notice here.
6. WITH WHOM CAN WE SHARE YOUR DATA?
It is possible that the Organization shares the personal data, in which case it will be restricted to the minimum appropriate and necessary to fulfill any of the specific purposes previously informed to you.
Therefore, we may share your data with third parties in the following situations:
- when necessary for payment transactions to suppliers and service providers;
- when dealing with affiliated companies of the same group in which EDFR takes part in, not only to meet the legitimate interests of these companies in the promotion and support of their activities, but also in the case of corporate transactions, such as merger, acquisition, and incorporation;
- before the notary’s office to register real state affairs
- when necessary to protect our Organization’s rights, to comply with legal obligations or to assist in the investigation of suspicious or illegal activities.
- law firms, legal advisory and other legal representatives: when necessary to defend EDFR’sbest interests and administrative, arbitration or judicial proceedings.
When we share your personal data in the above situations, we use contractual instruments to ensure that any third party who receives it guarantees them adequate protection.
As a company with operations in Brazil, it is expected that your personal data will be processed within Brazilian territory and shared with Brazilian partners and public authorities.
In situations where the sharing is with a third party located outside Brazil, for example, France, where our parent company is located, in addition to guaranteeing the security and protection of personal data through an agreement, EDFR will use one of the legal grounds presented by article 33 of the LGPD to conduct an international transfer based on the law.
7. FOR HOW LONG DO WE KEEP YOUR DATA?
The Organization retains your personal data for as long as necessary to fulfill the purposes for which the personal data was collected, as set out above, unless a longer retention period is necessary to comply with legal obligations, safeguard our rights or comply with judicial/extrajudicial agreements.
To determine the retention period of your personal data, the Organization considers the following criteria:
- whether there is a legal, contractual, or other obligation to retain personal data, or is necessary for investigation or litigation purposes; and
- whether they are necessary to maintain accurate business and financial records.
8. HOW DO WE PROTECT YOUR PERSONAL DATA?
We use appropriate technical, organizational, and administrative security measures to protect any personal information we store from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
In addition to these organizational and governance measures, we have adopted several other technical measures that guarantee even greater security to their personal data, such as:
- strict control of personal data processing, including access limitation, and password-protected access.
- the existence of an information security programme.
- the realization of segregation of access to personal data.
- password protection guidelines.
- the use of services exclusively by secure networks.
- traffic encryption.
- firewall protection.
9. HOW TO ENSURE YOUR RIGHTS AS A DATA SUBJECT BEFORE EDFR?
- make sure if we process any of your personal data;
- make sure which personal data about you is processed by us;
- correct incomplete, inaccurate or outdated personal data;
- request the anonymization, blocking or deletion of personal data that is unnecessary, excessive or that has been processing in violation of the law;
- request the portability of personal data to another service or product provider;
- request the review of solely automated decisions that affect its interests;
- request the deletion of personal data processed with your consent;
- obtain information about the public or private entities with which we share your personal data; and
- when the processing activity requires consent, the data subject may refuse to consent. In this case, you will be informed about the consequences of not performing such activity. If consent is given, it can be revoked at any time.
To exercise these rights, feel free to contact our DPO via e-mail DPO@edf-re.com.br.
Other information and/or documents may be requested by EDFR in order to confirm your identity or the veracity of the information you provided us.
Requests involving personal data and/or documents of other data subject will not be met, except by means of a power of attorney, parental authority or other hypothesis that authorizes the exercise of the right of another data subject by you.
In specific circumstances, it is possible that your request will not be fulfilled. In these cases, we will explain the reasons that justified the non-attendance.
10. ANY QUESTIONS?
In case you have any further questions, please contact our DPO at the following eletronic address: DPO@edf-re.com.br.
11. UPDATES
It is possible that some of the information provided here may be updated or changed. We therefore advise you to check this Privacy Notice regularly. We will make avaliable any changes on our home page.
Date of last published version: 04/02/2024.
