EDF EN DO BRASIL PARTICIPAÇÕES LTDA. (“EDFR” or “Organization”) is 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.
This Privacy Notice (“Notice”) describes the main types of personal data we collect, how the collected personal data is processed, the third parties with whom we may share it, how we protect personal data, and how to contact us.
For us, safeguarding the privacy and security of your personal data is a priority. Therefore, any information provided will be processed within the limits established herein and in accordance with applicable legislation.
We do not intend to collect or, in any way, process personal data of individuals under 18 years of age, as our platform and other channels are exclusively intended for use by adults. If we become aware that we have collected personal data from an individual under 18 years of age, we will disregard the information provided and will not retain it in our databases.
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WOULD IT BE HELPFUL IF WE CLARIFIED SOME OF THE TECHNICAL TERMS 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 personal data we process may have been provided directly by the data subject to the EDFR, by third parties—such as consultants, service providers, and suppliers—or automatically collected through our website and other devices used to access certain systems.
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, CPF, Company Registration Number (CNPJ), driver´s license (CNH), among others with relevance;
- Legal classification information: such as residential/commercial address, marital status, nationality;
- Contact information: such as telephone or cellphone number, personal or professional e-mail addresses;
- Financial information: such as checking account and bank branch;
- Occupation and qualification personal data: such as profession, position, place of work, salary, work hours, work experience, academic qualifications;
- Sensitive personal data: such as racial or ethnic origin, religious beliefs, Trade union membership, health-related data, data concerning a person’s sex life or sexual orientation and biometric data processed solely to identify a human being;
- Attributes associated with your electronic devices: such as date and time of access, user identification, management of cookie preferences and visited pages;
- Cookies: for more details on cookies, please refer to our Cookie Notice.
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 | Perform a contract with clients, suppliers, and service providers, or carry out pre-contractual due diligence Personal data will be used for the negotiation and performance of contracts, as well as to ensure the provision of services and the corresponding payment. |
Identification information Contact information | Communication We will process personal data to: 1. Respond to requests or other interactions with us via email, chat, or other platform tools; 2. Send relevant notifications about our activities; and 3. In the interest of transparency, provide updates to this Notice that may affect the relationship with data subjects, when applicable. |
Identification information Contact 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. |
Identification information Contact 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 EDFR Within the limits of the data subjects’ expectations, we may process personal data for activities such as improving our products and services, and maintaining relationships with clients and partners, among others. |
Identification information Contact information Occupation and qualification personal data | Recruitment and selection We will process personal data to review résumés and verify skills to assess whether the data subject meets the specific requirements of the advertised position, and to proceed with the selection process up to the conclusion of the admission process. |
Identification information | Ensure your safety We may process the personal data of our employees, partners, and suppliers to ensure workplace safety. |
Identification information Contact information | Business Proposals When necessary, we will use your personal data to send or receive commercial proposals. |
| Identification information Financial information Specific information necessary to achieve the desired outcome of the conducted research | Carry out project-related research Occasionally, we will use personal data for various purposes within the scope of EDFR projects, such as: • Facilitating the collection of primary data for stakeholder mapping and engagement plan development. • Understanding opinions about the projects. • Assessing whether the project would affect the routine of the individuals involved, including their personal and/or professional activities; and • Evaluating the impact the project may have on the community. |
5. WITH WHOM CAN WE SHARE YOUR DATA?
We may share personal data with third parties to achieve the purposes for which it was collected, such as:
- when necessary for payment transactions to suppliers and service providers;
- when dealing with a company that is part of the group to which EDFR belongs, or affiliated companies, to enable the achievement of research outcomes and the subsequent dissemination of these indicators.
- with notary offices, for the purposes of registration and land agreements.
- in the case of corporate transactions, such as merger, acquisition and incorporation.
- with administrative and judicial authorities when necessary to comply with legal obligations or to assist in the investigation of suspicious or illegal activities; and
- with law firms, legal advisory and other legal representatives, when necessary to defend EDFR’s best interests and administrative, arbitration or judicial proceedings.
In situations where data sharing involves a third party located outside Brazil, in addition to ensuring the security and protection of personal data through contractual agreements, EDFR will rely on one of the legally authorized bases for international data transfer as provided by applicable legislation.
- To share with our headquarters in France:
- Information regarding (i) data of owners/occupants of rural and urban properties used in civil lawsuits filed by EDFR/subsidiaries or by the property owners/occupants; and (ii) data of employees of suppliers or subcontractors in labor lawsuits in which EDFR is involved as the project owner.
- Contracts signed with suppliers, clients and partners, as well as land contracts.
Whenever personal data is transferred internationally, we will use technical and administrative methods to ensure that your data remains secure.
6. FOR HOW LONG DO WE KEEP YOUR DATA?
The Organization retains your personal data for as long as necessary to achieve the purposes for which it was collected. Whenever possible, we will retain personal data in an anonymized format, adhering to the highest standards of care and security, for:
- Comply with a legal, regulatory, or contractual obligation, or one imposed by a competent authority to retain personal data; and
- Maintain important historical, commercial, and financial records or meet internal requirements of EDFR.
7. HOW DO WE PROTECT YOUR PERSONAL DATA?
We have internal policies and procedures that establish how personal data should be processed by EDFR.
In addition to these organizational and governance measures, we implement technical measures to further enhance the security of personal data, such as:
- strict control of personal data processing, including access limitation, and password-protected access.
- implementation of an information security program.
- segregation of access to personal data.
- password protection guidelines; and
- use of services exclusively by secure networks.
8. HOW TO GUARANTEE YOUR RIGHTS AS A DATA SUBJECT WITH EDFR?
The Organization will respect your rights assured by the LGPD, which translates to:
- make sure we process any of your personal data.
- make sure which personal data is processed by EDFR.
- correct incomplete, inaccurate or outdated personal data.
- request the anonymization, blocking or deletion of personal data that is unnecessary, excessive or that has been processed 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 your interests.
- request the deletion of personal data processed with your consent; and
- obtain information about the public or private entities which we share your personal data.
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.
9. UPDATES AND QUESTIONS
This Notice will be reviewed annually or, when necessary, at any time to comply with legal updates or new processing activities. If there are changes that impact the purpose of processing, we will inform you via our website’s homepage, email, or another appropriate means.
In case of questions, data subjects may contact our Data Protection Officer (DPO): DPO@edf-re.com.br
Date of last published version: 2024/12/20.
