About the Let’s Water website
Last revised: October 17, 2023
Introduction
The www.letswater.com website is comprised of several individual sites (global, regional, country specific or let's Water business practice specific), each provided by Let's Water do Brazil (“WTR“) or by member firms of their respective entities (collectively referred to as “Let's Water Network“). These individual websites are located in the upper right corner of each page.
This Declaration of Privacy and Protection of Personal Data applies only to the specific pages of the website www.letswtaer.com designated as Let's Water do Brazil in the upper right corner, which are referred to below as “this website“.
Let’s Water, a member firm of Let’s Water do Brazil (also referred to below as “we” or “our”) is a global organization aware of the importance of privacy and protection of personal data. We are the entity within Let’s Water do Brazil that presents this website and this Privacy and Personal Data Protection Statement and explains how to protect visitor information on this website.
This Personal Data Protection and Privacy Statement expresses our commitment to treating your personal data in a responsible, ethical manner, in line with our principles and values and, especially, in accordance with the rules of Law No. 13,709/2018 (General Law Personal Data Protection – “LGPD”) and other applicable legislation in force.
By using this website, you agree to the use of your information as described in this Declarationof Privacy and Protection of Personal Data.
Please note that there are national, regional and business practice specific websites available within www.letswater.com provided by other entities in the Let’s Water do Brazil Network and not by us. These and other sites that may be linked are not applicable to this Privacy and Personal Data Protection Statement. We recommend that visitors review each of the privacy and personal data protection statements of these other sites before disclosing any personal information.
If you have any questions about this Privacy and Personal Data Protection Statement, please contact our Manager/DPO, Dr. Paulo Marcondes via email dpo@letswater.com
Summary of the Privacy and Personal Data Protection Statement
This Personal Data Privacy and Protection Statement tells you what personal data we collect about you, what we use it for, how and where we store it and with whom we share it. It also defines your rights in relation to your personal data and who you can contact for further information or clarification on this topic. See the sections of this statement below:
- What types of personal data do we collect
- How we collect your personal data
- How we use your personal data
- What legal grounds do we use to process your personal data?
- To whom we disclose your personal data
- How we protect your personal data
- How long do we keep your personal data
- What are your rights
- Claims
- Changes to this Privacy and Personal Data Protection Statement
What types of personal data do we collect
The personal data we collect may include: your name; age; date of birth; sex; email address; home address; Country of Residence; lifestyle and social circumstances (e.g. your hobbies); family circumstances (e.g. your marital status and dependents); employment and education details (for example, the organization you work for, your role and your educational details); financial and tax information (e.g. your income and tax residency); your posts on blogs, forums, wikis and any other social media applications and services we provide; your IP address; your browser type and language; your access times; details of the complaint; details of how you use our products and services; details of how you like to interact with us and other similar information.
The personal data we collect may also include sensitive personal data, which is defined by law as personal data about racial or ethnic origin, religious belief, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to to health or sexual life, genetic or biometric data, when linked to a natural person. In this way, we may collect details about your dietary requirements (for example, when Deloitte wants to provide you with lunch during a meeting), health (for example, so that we can provide reasonable accommodation for you in our buildings and in the offering of products and services) and sexual orientation (for example, if you provide us with details about your spouse or partner).
The types of personal data and special categories of personal data we collect may vary depending on the nature of the services we provide to you or our client, or how you use our website. In some rare circumstances, we may also collect other special categories of personal data about you, either because you provide that data to us or because we are obliged to collect it as a result of legal requirements imposed on us.
How do we collect your personal data?
We collect and process personal data about you or your company to provide services. For example, we may collect personal data:
Arising from the provision of services: we may collect personal data in the course of providing services to you or our client;
Coming from the holder: we may collect or obtain such data because you provide it to us or because it is publicly available;
Arising from your interaction with Let's Water: we may also collect or obtain your personal data because we observe or infer this data about you from the way you interact with our website, to provide information that we believe will be of interest to you ;
Coming from our customers: When your personal data is provided to us by our customer, we take steps to ensure that the customer has complied with privacy and data protection laws and regulations.
Additional information about how we use cookies and other tracking technologies, as well ashow you can control them, can be found.
We understand the importance of protecting the privacy and personal data of children and adolescents. Our website and services are not designed or intentionally directed at children and adolescents. It is not our policy to intentionally collect or store information about this type of audience, however, in eventual situations in which the collection and use of these types of personal data is necessary, such as in the provision of services that involve analysis of personal data of minor dependents, the treatment will take place in the best interests of the child and/or adolescent, in accordance with current legislation.
How we use your personal data
Use of personal data to provide services to our customers
We will use your personal data to provide services to you or our customer. As part of this, we may use your personal data in the course of correspondence relating to the Services. Such correspondence may be with you, our customer, other members of the Let’s Water Network, our service providers or competent authorities. We may also use your personal data to carry out due diligence checks relating to the Services.
Use of personal data for other activities that are part of the operation of our business
We may also use your personal data for or in connection with:
- Applicable legal or regulatory requirements;
- Requests and communications from competent authorities;
- Customer relationship purposes, which may involve: (i) sending eminent content or details about our products and services that we believe may be of interest to you; (ii) contact you to receive feedback about the Services; and (iii) contact you for other market or research purposes;
- Recruitment and business development purposes (for example, testimonials from a client's employees may be used as part of our recruitment and business development materials, with that employee's permission);
- Services we receive from our professional advisors, such as lawyers, accountants and consultants;
- Protection of our rights and those of our customers
Use of personal data collected through our website
In addition to the purposes related to operating our business above, we may also use your personal data through our website to:
- manage and improve our website;
- adapt the content of our website, based on monitoring access to the content available, to provide you with a more personalized experience and draw your attention to information about our products and services that may be of interest to you;
- manage and respond to any requests you submit through our website;
What legal grounds do we use to process your personal data?
We are required by law to establish in this document the legal basis for processing your personal data, mainly related to the legal hypotheses defined by the LGPD.
As a result, your personal data will be processed in the following cases:
(a) by providing your consent to the processing of your data, for example, to grant you access to a platform maintained by the Let’s Water Network or to make marketing material available. If you no longer wish to receive any marketing material from us, simply click on the unsubscribe function contained in the communication or email received.
(b) when there are legitimate interests of the Let's Water Network in offering and delivering our services to you or our client, as well as for the effective and lawful operation of our business, provided that such interests are not outweighed by your interests, rights and fundamental freedoms.
(c) compliance with applicable legal and regulatory obligations that may require the collection, storage and sharing of your personal data in order to comply with legal and regulatory provisions, such as (i) maintaining records for tax purposes or providing information to a body public or law enforcement agency; (ii) compliance with labor and social security obligations; (iii) compliance with obligations to combat corruption, money laundering, fraud and irregular conduct.
(d) to execute any contract, as well as to provide our services to you or our client.
(e) to regularly exercise our rights, such as, for example, to exercise our right to defend ourselves in any judicial or administrative process.
(f) protection of the life or physical safety of you or a third party;
(g) protection of your health.
Likewise, your sensitive personal data will be processed in the following cases:
(a) by providing your specific and highlighted consent for the processing of your data;
(b) When necessary to comply with applicable legal or regulatory obligations that may require the collection, storage and sharing of your personal data in order to comply with legal and regulatory provisions, such as (i) maintaining records for tax purposes or providing information to a public body or law enforcement agency; (ii) compliance with labor and social security obligations; (iii) compliance with obligations to combat corruption, money laundering, fraud and irregular conduct.
(c) protection of the life or physical safety of you or a third party.
(d) health protection.
(e) to regularly exercise our rights, such as, for example, to exercise our right to defend ourselves in any judicial or administrative process.
(f) guarantee of fraud prevention and security, in the processes of identification and authentication of registration in electronic systems.
To whom we disclose your personal data
In connection with one or more of the purposes set out in the “How we use your personal data” section above, we may disclose details about you to: other members of the Let’s Water Network; third parties that provide services to us and/or the Let’s Water Network; competent authorities (including courts and authorities that regulate us or another member of the Let’s Water Network); technology companies responsible for storing and ensuring security in the processing of your data; your employer and/or your advisors; his advisors; credit reference agencies; or other organizations that help us make credit decisions and reduce the incidence of fraud and other third parties who reasonably require access to personal data relating to you for one or more of the purposes described in the “How
we use your personal data” section above.
Our website hosts various blogs, forums, wikis, and other social media applications or services that allow you to share content with other users (collectively, “Social Media Applications”). It is important to note that any personal information you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users and therefore cannot guarantee that any information you provide with any social media application will be treated in accordance with this Personal Data Protection and Privacy Statement.
Please note that some of the recipients of your personal data mentioned above may be located in countries outside Brazil or outside the European Union, whose laws may not offer the same level of data protection. In such cases, we will ensure that we take all possible steps to protect your personal data in accordance with our legal obligations. When the recipient is not a member of the Let's Water Network, the appropriate guarantee may be a data transfer agreement with the recipient, based on standard contractual clauses approved by the National Data Protection Authority (ANPD) or other competent authority to transfers of personal data from other countries.
We also make further details about the transfers described above, and the appropriate safeguards used by Let's Water in respect of such transfers (including copies of relevant agreements), available via Talk to the DPO.
We may also need to disclose your personal data if required to do so by law, regulator or during legal proceedings.
We may share non-personal, de-identified and aggregated information with third parties for a variety of purposes, including data analysis, research, contributions, eminence content and promotional purposes.
How we protect your personal data
We use a range of physical, electronic and managerial measures to ensure that your personal data remains secure, accurate and up to date. These measures include:
- Education and training of responsible staff so that they are aware of our privacy and data protection obligations when dealing with personal data;
- Administrative and technical controls to restrict access to personal data, conditioned on the need to know;
- Technological security measures, including firewalls, encryption and antivirus software;
- Physical security measures, such as employee security passes to access our facilities.
Although we use appropriate security measures, once we receive your personal data, the transmission of data over the internet (including by email) is never completely secure. We strive to protect your personal data, but we cannot guarantee the security of data transmitted to or by us.
In order to properly protect and process your personal data in accordance with the LGPD, in addition to other applicable laws, we are committed to:
- Adopt security, technical and administrative measures to protect personal data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication or any form of inappropriate or unlawful processing;
- Maintain records of personal data processing operations carried out, especially when based on legitimate interest;
- Communicate, within a reasonable period of time, to the National Data Protection Authority and the holder the occurrence of a security incident that may cause significant risk or damage to the holders;
- Use systems to process personal data that are structured to meet security requirements, good practice and governance standards and the general principles set out in the LGPD;
- Delete personal data after the end of their processing, within the scope and technical limits of the activities, allowing conservation for the purposes provided for by law; It is
- Observe the guidelines, rules and regulations published by the National Data Protection Authority (ANPD).
How long will we keep your information?
We will keep your personal data on our systems for the longest of the following periods: (i) as long as it is necessary for the relevant activity or services; (ii) any retention period required by law; (iii) end of the period in which disputes or investigations in relation to the services may arise; (iv) while your consent is valid, in applicable cases; (v) in accordance with current legislation.
Your rights
You have several rights in relation to your personal data, which can be exercised at any time, free of charge, through a request registered by you to our DPO/Manager, through Talk to the DPO. In particular, you have the right to:
- Obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
- Request that we update the personal data we hold about you or correct data that you believe is incorrect or incomplete;
- Withdraw the consent granted for the processing of your personal data, as well as request its deletion (to the extent that such processing is based on consent);
- Request the portability of the personal data we have about you to another supplier of products or services, as long as commercial and industrial secrets, as well as applicable confidentiality, are respected;
- Obtain information about with whom we share the use of your data;
- Request that your personal data that you consider unnecessary, excessive or treated in non-compliance with the LGPD be anonymized, blocked or deleted;
- Request the review of decisions made solely based on automated processing of personal data.
To exercise any of your rights, or if you have other questions about the use of your personal data, please contact our DPO/Manager at Talk to the DPO.
Claims
If you are not satisfied with the way we treat your personal data or with any question or request related to your privacy, you can direct your complaint or request to our DPO/Incharge via Talk to the DPO.
Changes to this Privacy and Personal Data Protection Statement
We may modify or amend this Privacy and Personal Data Protection Statement from time to time.
To inform you when we make changes to this Privacy and Personal Data Protection Statement, we will change the revision date at the top of this page. The new modified or amended Privacy and Personal Data Protection Statement will apply from that revision date.
Therefore, we encourage you to periodically review this Statement to be informed of how we are protecting your information.
By providing information through this site, you agree to the disclosures described above.