Logo General Water

Privacy Policy

1. GENERAL WATER’S PRIVACY POLICY

We at General Water believe that individual privacy is a fundamental human right. For this reason, we present our Privacy Policy to our users, so that they are aware of the rules relating to how we collect, record, store, use, share and delete their personal data, in accordance with applicable laws in Brazil, as well as the best Data Governance practices.

2. GLOSSARY

Personal data – according to the law, this is information relating to an identified or identifiable natural person. Thus, it can be given as a name, ID, etc. Or any data that can be identified after analysis. For example: a 30-year-old woman who lives on the 6th floor of Building XX. If there is only one woman of that age on that floor, she is identifiable.

Sensitive data – under the law, sensitive data is understood to be data about racial/ethnic origin, religious conviction or membership, political party opinion or membership, trade union membership, membership of a philosophical organization, data relating to health or sex life and genetic or biometric data.

Principles – Purpose, adequacy, necessity, free access, data quality, transparency, security, prevention, non-discrimination, accountability and responsibility.

Anonymization – a technique for anonymizing data, i.e. so that it cannot be identified as personal, taking into account the use of reasonable technical means available at the time of processing.

Pseudo-anonymization – Processing by which the data loses the possibility of direct or indirect association (the person will no longer be identifiable) other than through the use of additional information kept separately.

Processing – collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

Processing agents – controller and operator.

Controller – a natural or legal person, governed by public or private law, who is responsible for decisions relating to the processing of personal data.

Operator – natural or legal person, governed by public or private law, who carries out the processing of personal data on behalf of the controller.

Data Protection Officer (DPO) – person appointed by the controller and operator to act as a communication channel between the controller, the holders of personal data and the ANPD

ANPD – The National Personal Data Protection Authority is the agency responsible for ensuring the protection of personal data and for implementing and monitoring compliance with the LGPD. ⠀

3. OBJECTIVES OF THIS POLICY

General Water is committed to the security of the information of portal users, customers and employees by adopting appropriate protection measures in its operations, with consistent, effective and rigorous procedures.

We recognize the importance of your privacy and have therefore developed this policy to inform you of the conditions under which we process and protect your personal data. This policy also describes your rights and how to access them on our digital platforms, or by sending an e-mail to lgpd@generalwater.com.br

4. USER RIGHTS

You are the owner of your personal data and therefore have the right to be empowered with control over what happens to it. For this reason, we provide you with resources to let you know what is being done with your personal data, through our service channels.

We may, for the purposes of auditing, security, fraud control and preservation of rights, keep your data for a longer period of time, in the cases defined by law or regulatory standards.

If the USER wishes to access, correct, update or request the deletion of their personal data, they may do so at any time by contacting us through the aforementioned communication channel.

The USER may object to the processing of their personal data, request the restriction of processing, or request the portability of their personal data, by contacting us through the aforementioned channels.

Likewise, the USER may withdraw their consent to data processing at any time. Withdrawing consent will not affect the legitimacy of the processing carried out prior to the withdrawal, nor will it affect the processing of personal data carried out on the basis of legitimate processes which do not require consent.

5. PURPOSE OF DATA USE

We may use your data that has been collected and the records of your activities in our current digital interfaces or that we may develop in the future to improve your experience with us, for the following purposes:

  • Registration and security (knowing who you are): name, e-mail address, telephone number
  • Relationship and improving our service: name, telephone number, e-mail address.

You are aware of and freely consent to the collection of your personal data through our digital platform.

If you are unable or unwilling to give your consent, the following services will not be available: Sending a contact form to the company, via the “contact” tab. Sending CVs for open job vacancies via the “Work with us” tab.

The USER may manage permissions regarding the use of their data through the following service channel, and may grant new permissions or withdraw their consent to the current permissions, being advised of the consequences of withdrawing consent.

Channel with the Data Protection Officer: lgpd@generalwater.com.br

The data collected and the activities recorded may be shared with:

Competent judicial, administrative or governmental authorities, whenever there is a request, requisition or court order;

Automatically and legitimately, in the event of corporate changes, such as mergers, acquisitions or incorporations, within the same economic group to which we belong.

The data of our USERS is accessed internally only by duly authorized professionals, respecting the principle of proportionality, necessity and suitability for the purposes for which it was collected, in addition to the commitment to confidentiality and preservation of privacy under the terms of this Privacy Policy.

6. GENERAL GUIDELINES

As a condition for providing the following services: registration inquiry, registration update, issuing of payment slips, confirming the veracity of the Electronic Decore, issuing of an Electronic Regularity Certificate, registration for events and courses, by entering the site, the USER declares their free and express consent that they are fully aware of and in agreement with the terms of this Privacy Policy.

7. DATA COLLECTION AND ACTIVITY LOGGING

  • Data is collected through CVs that are sent digitally or physically.
  • The information we collect includes Personal data, such as name, address, e-mail address and contact telephone number. In addition, we receive information on academic background and professional experience.
  • General Water strives to guarantee the quality of the personal data it uses. However, in order to do so, it is essential that you, the user, provide correct and up-to-date information, seeking for veracity.
  • All the technologies referred to and used in our digital relationship environment will comply with current legislation and the terms of this policy.
  • When browsing our interface, the USER may be taken via links, content or services to other portals or platforms that may collect their information and have their own Privacy Policy. It is therefore up to the USER to keep up to date with these policies and to accept or reject them. We are not responsible for the Privacy Policy or the content of any websites, content or services linked to the portal, including through links.

8. STORAGE OF DATA AND RECORDS

  • The data and activity records collected will be stored in a secure and controlled environment for a minimum period of 6 (six) months, under the terms of the Brazilian Civil Rights Framework for the Internet, observing the technology available at the time.
  • The data may be deleted before this period, at the USER’s request, as long as it does not meet the legal exceptions for keeping records.
  • The USER is aware that the data collected (whether personal or not) may be stored on servers located in Brazil, as well as in an environment where resources or servers are used in the cloud (cloud computing), which in the latter case entails the transfer or processing of data outside Brazil, in third countries.

9. LEGAL BASES FOR DATA PROCESSING

Our legal basis for collecting and processing personal data is supported by the legislation in force in the country – Law 13.709/2018 (LGPD) and includes:

  • With your consent to do so (art. 7, item I, of Law 13.709/2018);
  • To comply with any legal or regulatory obligation (art. 7, item II, Law 13.709/2018);
  • When we need your personal data to enter into or perform a contract with the USER (art. 7, point V, Law 13.709/2018);
  • When the processing is in accordance with legitimate interests and does not disregard interests related to data protection or fundamental freedoms and guarantees (art. 7, item IX, Law 13.709/2018).

10. GENERAL PROVISIONS

We may change the content of the privacy policy at any time, according to purpose or need, such as for adequacy and compliance with legal or regulatory provisions, and it is up to the USER to check it periodically. We will notify the user of any significant updates that require a new collection of consent, through the means of contact provided. It is therefore important that you keep your registration up to date.

If you have any questions about the conditions set out in this Privacy Policy, please contact us through the service channels mentioned above.

If any provision of this Privacy Policy is deemed illegal or unlawful by authority of the place where you live or your internet connection, the other conditions will remain valid.

You acknowledge that all communications made by e-mail, SMS, instant messaging applications or any other digital or virtual form are valid as documentary evidence and are effective and sufficient for the disclosure of any matter relating to this relationship, except as otherwise provided in this Privacy Policy.

This Privacy Policy shall be governed by and interpreted in accordance with Brazilian law, in the Portuguese language, and the courts of the District of São Paulo/SP shall be elected to settle disputes, except for territorial, personal or functional jurisdiction, in accordance with specific legislation.

Date last updated: 04/04/2024