3D Watt Serviços de Tecnologia Ltda.
WHO WE ARE
3D Watt is a digital solutions company for the electricity market with a focus on the Energy Transition, aiming to generate business opportunities and to make it easier to contract products and services relating to Distributed Generation (MMGD - Brazil's micro and mini distributed generation framework) and Distributed Energy Resources (DERs), through a multilateral platform that brings together the market's main players. Above all, 3D Watt seeks to promote the essential role of each player in the sector's recent transformations - in other words, "your place" in the energy transition.
PURPOSE OF THIS DOCUMENT
The Privacy Policy described here aims to demonstrate how your personal data is processed by 3D Watt, reaffirming its commitment to important values - notably a good relationship with, and transparency towards, Users - in accordance with the provisions of the Lei Geral de Proteção de Dados (Lei 13.709/18) (Brazil's General Data Protection Law, the "LGPD").
1. DEFINITIONS
1.1. "3D Watt Serviços de Tecnologia Ltda.", the "Platform" or "3D Watt": responsible for managing users and the interactions made available on the www.3dwatt.com.br platform and which, for the purposes of this Privacy Policy, refers to the Controller responsible for decisions concerning the processing of personal data.
1.2. "User": any person who uses the 3D Watt platform, in a general sense, regardless of login, registration or profile, and who, for the purposes of this Privacy Policy, shall be referred to as the "Data Subject" or simply as the "User", these terms being equivalent;
1.3. "Consumer User": a User, whether an individual or a legal entity, who is an end consumer of electricity, holding or acting on behalf of an electricity Consumer Unit.
1.4. "Installer User": a company or professional responsible for the sale, engineering design, construction and installation of micro or mini distributed electricity generation systems.
1.5. "Project Developer User": a specialist professional or company responsible for developing a renewable distributed electricity generation project from its earliest (greenfield) stage, covering all the disciplines required to deliver a micro or mini distributed generation project.
1.6. "Power Generator User": a User, whether an individual or a legal entity, who owns or acts on behalf of a micro or mini distributed electricity generation system or plant connected to an electricity distributor and participating in the Sistema de Compensação de Energia Elétrica (SCEE - Brazil's electricity net-metering scheme).
1.7. "LGPD": means the "Lei Geral de Proteção de Dados" (Brazil's General Data Protection Law), Brazilian Law No. 13.709/2018;
1.8. "Personal data": any information relating to a natural person that identifies them, or that, when used in combination with other processed information, identifies an individual. It also refers to any information through which the identification of, or contact details for, a natural person becomes possible;
1.9. "Data Subject": the natural person to whom the personal data being processed relates and who, for the purposes of this Privacy Policy, refers to the User.
1.10. "Anonymised Data": data relating to a data subject who cannot be identified, taking into account the reasonable technical means available at the time of processing;
1.11. "Anonymisation": the use of reasonable technical means available at the time of processing, by which data loses the possibility of being associated, directly or indirectly, with an individual;
1.12. "Processing of Personal Data": the processing of personal data is deemed to include the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction of data of natural persons;
1.13. "Controller": the natural or legal person, governed by public or private law, responsible for decisions concerning the processing of personal data and who, for the purposes of this Privacy Policy, refers to the "Platform" or "3D Watt".
1.14. "Data Protection Officer (Encarregado)": the person appointed by the Controller to act as the channel of communication between the Controller, the data subjects and the Autoridade Nacional de Proteção de Dados (ANPD - Brazil's National Data Protection Authority). For the purposes of this Privacy Policy, the Controller appoints as its Data Protection Officer Ms Karoline Oliveira de Araújo, who can be reached at the email address privacidade@3dwatt.com.br.
1.15. "Purpose": the Controller's objectives in processing personal data.
1.16. "Consent": the freely given, informed and unambiguous authorisation by which the User agrees to the collection and processing of their personal data for a previously specified Purpose;
2. APPLICABILITY OF THE 3D WATT PRIVACY POLICY
This Privacy Policy applies to all those who use the 3D Watt platform, whether Users or potential Users of the services offered by 3D Watt, as well as to those whose personal data is in any way processed by 3D Watt.
3. SOURCE AND PROCESSING OF PERSONAL DATA
3D Watt collects information provided by the Users themselves through the following channels:
3.1. On the website and platform:
3.1.1. In the "Register" option: name, email and telephone
3.1.2. In the "Installer User" registration: company legal name, trading name, address, neighbourhood, city, state, country, postcode, CNPJ (Brazilian company tax ID), company description, website, email, contact person, telephone.
3.1.3. In the "Project Developer User" registration: company legal name, trading name, address, neighbourhood, city, state, country, postcode, CNPJ, company description, website, email, contact person, telephone.
3.1.4. In the "Power Generator User" registration: company legal name, trading name, address, neighbourhood, city, state, country, postcode, CNPJ, company description, website, email, contact person, telephone.
3.1.5. In the "Contact us" option: name, email, telephone, address, company.
3.2. Via WhatsApp, Instagram, Facebook, LinkedIn and YouTube, through the "Get in touch" option: name, email and telephone.
3.3. Through subscription to our blog and/or Newsletter: name, email.4. AUTOMATICALLY COLLECTED INFORMATION
3D Watt collects and stores information whenever the User interacts with the platform. As is common practice on the internet, we collect and use information including the User's IP (Internet Protocol) address, the ISP (Internet Service Provider), the browser used by the User when visiting the website, the duration of their visit and which pages they visited within the 3D Watt website.
5. COOKIE POLICY
3D Watt uses cookies. A cookie is a small data file that is sent to your computer when you visit a website. As with other modern websites, our cookies operate to optimise your browsing experience and include an identification number that is unique to the computer you are using. This identifier helps us better understand our user base and how they are using our site and services. The 3D Watt Website will use the information obtained through cookies to analyse the pages browsed by the user and their searches, with the aim of improving the User experience, doing so in accordance with the following functionalities:
5.1. Essential cookies: these are necessary for the platform to work more simply and efficiently, enabling network management and a more secure environment;
5.2. Performance cookies: these help 3D Watt understand how Users interact with the platform, providing information about the areas visited, the duration of the visit and any problems encountered, such as error messages. This helps 3D Watt improve the platform's performance;
5.3. Functionality cookies: these allow information about the platform to be collected, enabling technical and statistical analysis, improving its usability and ensuring that the platform works properly;
5.4. Advertising cookies: these are used to provide more relevant content to the User through the distribution of advertising. Should the User wish, they may disable some or all cookies. This can usually be done through the "options" or "preferences" menu of their browser. However, disabling cookies may impair the browsing performance of the platform.
6. TRACKING PIXELS OR WEB BEACONS
A tracking pixel, web beacon or transparent pixel is an electronic image and serves purposes similar to those of Cookies. In addition, a Tracking Pixel is used to measure users' traffic patterns as they navigate between pages, with the aim of maximising the flow of traffic across the web. 3D Watt uses this feature to help improve its Users' experience.
7. CONSENT AND WITHDRAWAL OF CONSENT FOR THE PROCESSING OF PERSONAL DATA
When registering on the 3D Watt platform, the User must first tick the checkbox confirming that they are aware of and agree to this Privacy Policy and giving their free and voluntary consent to the processing of their personal data on the platform. 3D Watt keeps a record of consent, which may be withdrawn at any time by express request from the User via the email address privacidade@3dwatt.com.br.
8. PURPOSE OF DATA PROCESSING AND LEGAL BASIS
The processing of personal data by 3D Watt is based on compliance with legal obligations and the regular exercise of rights and legitimate interest, as provided for in items I, II, IV, V, VI and IX of Article 7 of the LGPD, including, but not limited to, the items below:
8.1. To provide a contracted service, giving it the appropriate functionality, or to initiate negotiations. Article 7, item V of the LGPD - Performance of a contract between 3D Watt and the User.
8.2. For commercial purposes, such as business analysis and management, market research for the development of new products or functionalities, enhancement of the platform and improvement of services or products. Article 7, item IX of the LGPD - 3D Watt's legitimate interest in optimising its administration and management.
8.3. For advertising purposes - whether targeted or not - via Newsletter, email marketing, banners, cookies or other methods. Article 7, item IX of the LGPD - 3D Watt's legitimate interest. The User's receipt of advertising is optional, as set out in item 13.1 of this Privacy Policy.
8.4. To perform backups and manage information in databases. Article 7, item IX of the LGPD - 3D Watt's legitimate interest. With the aim of protecting rights, privacy, security, property and operations, cloud storage of information, antivirus and/or firewall systems are adopted. Article 7, item IX of the LGPD - 3D Watt's legitimate interest.
9. RIGHTS OF PERSONAL DATA SUBJECTS
3D Watt guarantees its User the right to information and actions concerning their data, as set out in the items below:
9.1. Confirmation of the existence of processing of their data: personal data subjects may get in touch in order to confirm whether any of their personal data is processed by 3D Watt.
9.2. Access to data: a request for access to their data held and processed by 3D Watt.
9.3. Correction of incomplete, inaccurate or out-of-date data: data subjects may ask 3D Watt, at any time, to amend their personal data where it is incorrect, inaccurate or out of date. It should be noted that the User must keep 3D Watt informed of any need to update or correct their data.
9.4. Anonymisation, blocking or deletion of unnecessary or excessive data, or data processed in breach of the LGPD: the data subject may request the blocking and deletion of their personal data. Such a request will only be refused by 3D Watt where it cannot be fulfilled or where storage of the data is mandatory or permitted, in accordance with the situations listed in Article 7 of the LGPD and other applicable provisions. Because anonymisation prevents identification of the individual, anonymised data ceases to be regarded as personal data and therefore falls outside the scope of the LGPD.
9.5. Deletion of personal data processed with the data subject's consent: data subjects' personal data will be deleted once the purpose has been fulfilled, except in the following specific cases:
9.5.1. Compliance by 3D Watt with a legal or regulatory obligation;
9.5.2. Transfer to a third party, provided that the data processing requirements set out in the LGPD are observed;
9.6. Information about the public and private entities with which 3D Watt has shared data: the data subject has the right to request access to the personal data forwarded to public and private entities.
9.7. Information about the possibility of not giving consent and about the consequences of refusal: 3D Watt is available to address and assist, transparently, with any questions that may arise concerning the processing of users' personal data, including the possible implications of withholding consent.
9.8. Withdrawal of consent: the consent given by personal data subjects may be withdrawn at any time by written request to 3D Watt through a free-of-charge procedure, as already set out in item 7 of this Privacy Policy.
9.9. The User shall also have the right to request a review of any decisions taken solely on the basis of automated processing of personal data that affect their interests, including decisions intended to define their personal or professional profile or aspects of their personality. In such cases, 3D Watt will provide, as far as possible, clear and adequate information about the criteria and procedures used for the automated decision, subject to commercial and industrial secrecy.
9.10. In exercising any right referred to in this clause, the User must get in touch through the channels indicated in this Privacy Policy. 3D Watt will use its best efforts to take the necessary measures within the time limits set out in the LGPD and other applicable rules
10. SHARING OF DATA WITH THIRD PARTIES
10.1. 3D Watt shares personal data collected from users in order to promote interactions between Users on the platform, for 3D Watt's own marketing activities and for administrative practices, with a view to providing or improving its services and products. All sharing is carried out with the adoption of the necessary technical and administrative security measures.
10.2. The 3D Watt platform may contain links to third-party websites and platforms whose privacy and security practices are not covered by this Privacy Policy. Accordingly, on leaving the 3D Watt environment, the User should read the Privacy Policy of the new website or platform to which they have been directed.
10.3. 3D Watt may also share users' personal data where such sharing is necessary to comply with the applicable legislation or in response to a request from public or governmental authorities.
11. CONFIDENTIALITY
Personal information entered on the Platform or in the emails that pass through it is considered confidential, and its sharing is restricted to what is set out in item 10 of this Privacy Policy, save in cases of a court order and/or request and/or ruling.
12. INFORMATION SECURITY MEASURES
3D Watt undertakes to maintain the confidentiality, integrity and security of any information made available on the platform by the User or relating to them.
Without prejudice to other measures, the 3D Watt site has an SSL security certificate and all information is stored on AWS (Amazon Web Services) servers. AWS provides robust infrastructure with multiple layers of protection, including advanced encryption, strict access control and continuous monitoring to identify and mitigate threats. In addition, we follow best practices for compliance and data protection, ensuring that sensitive information is stored and processed securely, in accordance with the applicable privacy rules.
Unfortunately, it is not possible to guarantee the complete security of any data transmission over the Internet; however, 3D Watt uses the most up-to-date tools to protect your personal information and declares that, as at the date of this Privacy Policy, it has had no incident or history of data leaks from its systems on the Internet, and that any such incident, should it occur, will be reported to users.
As a security measure, the activities carried out by the User on the website are recorded by means of LOGs that record the IP address, the session ID, the pages accessed and the dates and times of access.
13. RETENTION AND DISPOSAL OF PERSONAL DATA
13.1. The personal data processed by 3D Watt will be stored and kept only for as long as necessary to fulfil the purposes set out in item 8 of this Privacy Policy. Once the User's relationship with the Platform has ended, the User's information, including third parties' personal data, will be stored in accordance with the limitation periods under Brazilian law, unless the processing is based on the data subject's consent, which may be withdrawn at any time.
Where there is a legitimate interest justifying storage, such as in cases involving marketing communications, the User has the option to unsubscribe or opt out of these communications, requesting removal from the mailing list.
13.2. After the limitation period, the personal data processed by 3D Watt will be deleted, except where processing is necessary on the grounds set out in the items of Article 16 of the LGPD, highlighted below:
13.2.1. Compliance by the controller with a legal or regulatory obligation;
13.2.2. Study by a research body, ensuring, wherever possible, the anonymisation of the personal data;
13.2.3. Transfer to a third party, provided that the data processing requirements set out in this Law are observed; or
13.2.4. Exclusive use by the controller, in anonymised form and with third-party access prohibited.
14. AMENDMENTS TO THE PRIVACY POLICY
3D Watt may modify, amend or replace this Privacy Policy at any time. In the event of a change, Users will be informed through the Platform or through appropriate communication channels within 30 (thirty) days.
15. JURISDICTION:
This Privacy Policy and the relationships governed by it are subject to the laws of the Federative Republic of Brazil, and the courts of the District (Comarca) of Porto Alegre are hereby elected to settle any disputes, to the exclusion of any other, however privileged.
Should you have any questions or queries about this Privacy Policy or related matters, 3D Watt provides the email address privacidade@3dwatt.com.br as the channel of communication between the 3D Watt Data Protection Officer, the data subjects and the Autoridade Nacional de Proteção de Dados (ANPD - Brazil's National Data Protection Authority).