DISCLAIMER: Argo Energia is a Brazilian company and, therefore, generally follows the provisions of the Brazilian General Data Protection Law (Federal Law No. 13.709/18, the "LGPD") regarding the collection and processing of personal data from its website. In the event that a different law other than the LGPD applies to a website visitor, our Data Protection Officer (DPO) can be contacted at gtpd@argoenergia.com.br for clarification of their rights and obligations.

 

1. Initial provisions

Here at ARGO ENERGIA EMPREENDIMENTOS E PARTICIPAÇÕES S.A. (“Argo” or “Company”), we aim to maintain a relationship of trust and transparency with all our clients, third-party commercial partners, users of our services, and the general external public ("You"). Therefore, we ensure that your browsing here at Argo Energia will be conducted with the highest possible security and in compliance with all current privacy standards.

We have prepared this Privacy Notice ("Notice") to help You understand how Argo handles your information and how you can exercise your rights related to that information.

Our top priority is to safeguard the privacy and security of your Personal Data. Therefore, any information you provide to us will be handled according to the limits set herein and in accordance with applicable legislation.

You are not required to share the Personal Data we request. However, if you choose not to share it, in some cases, we may not be able to fulfill the purposes described in this document.

2. Definitions

Argo: ARGO ENERGIA EMPREENDIMENTOS E PARTICIPAÇÕES S.A. (“Argo”) a private legal entity registered with the CNPJ/MF under No. 24.624.551/0001-94, headquartered at Rua Tabapuã No. 841, 5th floor, Conj. 51, Itaim Bibi, São Paulo/SP, 04553-013.

Accept or acceptance means the act of the Data Subject clicking the “I agree with the Privacy Notice” box. This action implies free, informed, and unequivocal expression by which the Data Subject agrees with all the terms set forth in such documents.

Cookies: refers to small files or data packages sent by Argo to your device to identify it and collect information that helps us improve the services provided.

Data Subject: refers to a natural person to whom the Personal Data belongs, in this case, You.

Personal Data: refers to information that allows the direct or indirect identification of natural persons.

Sensitive Personal Data: refers to Personal Data related to racial or ethnic origin, religious belief, political opinion, membership in a union or religious, philosophical, or political organization, data concerning health or sex life, genetic or biometric data when linked to a natural person.

Personal Data Processing: refers to any operation performed on Personal Data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination, or extraction.

Controller: a natural or legal person, public or private, responsible for decisions regarding the Personal Data Processing.

Processor: a natural or legal person, public or private, that processes Personal Data on behalf of the Controller.

Data Protection Officer (DPO): a person (natural or legal) appointed by Argo, responsible for acting as a communication channel between us, you, and government authorities on matters related to this Notice and the use, collection, and processing of Personal Data.

Legal Bases: refers to the legal grounds that allow Personal Data Processing by Controllers and Processors. The Legal Bases provide the justifications or reasons why organizations may collect, process, and use Personal Data.

Data Protection Law: refers to all applicable legislation governing the Personal Data Processing, including but not limited to Law No. 13.709/2018.

 

3. A quick summary of the most important information

To make it easier for you to understand this Notice, we have provided a summary of the information that will be presented to You in this document:

Who will process your personal data?

Meet Argo!

ARGO ENERGIA EMPREENDIMENTOS E PARTICIPAÇÕES S.A. (“Argo”) is a private legal entity registered with the CNPJ/MF under No. 24.624.551/0001-94, headquartered at Rua Tabapuã No. 841, 5th floor, Conj. 51, Itaim Bibi, São Paulo/SP, 04553-013. It focuses on the electricity sector, specifically in the transmission segment.

Argo was founded in 2016 by Pátria Investimentos, a leading manager in alternative investments and a pioneer in Private Equity in Brazil. Today, it is a company recognized for its operational excellence, particularly for focusing on sustainable growth to maximize investments.

You can learn more about us by visiting our website: https://www.argoenergia.com.br.

Argo is the entity responsible for Personal Data Processing, and it determines the purposes and means of processing.

Purpose of this Privacy Notice

The purpose of this Privacy Notice is to provide comprehensive information about the collection and Processing of your Personal Data by Argo when You use this website, including any information You may provide during its use.

It is important that You read this Privacy Notice, as well as any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you, to ensure you are fully aware of how and why we are using your Personal Data.

 

Special message for legal representatives

The Brazilian General Data Protection Law (LGPD) requires greater rigor in the processing of Personal Data of children and adolescents, imposing specific and highlighted consent to be given by at least one parent or legal guardian (art. 14, § 1º).

For this reason, we may request that one parent or legal guardian signs a consent form when it comes to Personal Data of children or adolescents.

We do not aim to collect or process Personal Data of individuals under the age of 18, as the website is only intended for individuals of legal age. Therefore, if we become aware that we have collected Personal Data from an individual under 18, we will disregard the information provided and will not retain it in our records.

If You are a parent or legal guardian and become aware that your child has provided Personal Data to Argo, please contact us through the channel provided below.
 

Data Protection Officer (DPO) Contact Information

The DPO is the internal or external professional responsible for addressing issues related to the protection of data of the organization and its clients.

If You have any questions regarding this Privacy Notice, including any requests to exercise your rights, please contact the data protection department via email: gtpd@argoenergia.com.br.

Our DPO is Guilherme Cunha Braguim, and he is available to assist You in the best way possible.

How do we collect your Personal Data?

The information we process about you may have been provided directly by you to Argo, obtained from third parties, or automatically collected through our platform and other channels.

Which data will be collected?

Below, we provide a summary of some Personal Data we process, which will be detailed in Topic 4:

• Personal Data: name, date of birth, RG (identity document), CPF (tax ID), PIS number, CTPS (work permit) number, passport number, driver's license number, residential/commercial address, marital status, nationality, parentage, date of birth, age, gender, landline or mobile phone numbers, personal and/or professional emails, bank, bank account and branch, income tax declaration, profession, workplace, job title, professional history, academic qualifications, diplomas, and other certificates, registration number, professional profile, criminal record, social media profile, signature, geolocation, and attributes associated with your electronic devices.
• Sensitive Personal Data: data related to your racial/ethnic origin, health, biometric data, or union membership.

Why do we need your personal data?

Below is a summary of some of the purposes for which we process your Personal Data, which will be detailed in Topic 5:

• To facilitate a service/product requested by you;
• To communicate with you;
• To comply with our legal or regulatory obligations;
• To allow the regular exercise of our rights;
• To facilitate activities necessary for our company;
• To execute a contract you have entered into with us or conduct pre-contractual procedures;
• Recruitment and selection;
• To prevent fraud and ensure your safety; and
• Advertising.

 

How long will your data be stored for?

We store your Personal Data for the time necessary to achieve the purposes for which it was collected. When possible, we will keep the Personal Data in an anonymized form, maintaining the highest level of care and security in the market.

When may your personal data be shared?

We may share your Personal Data with third parties to achieve the purposes for which it was collected.

Additionally, sharing may occur when necessary to meet judicial requests or comply with legal or regulatory obligations.

How to exercise your rights as a Data Subject?

We are committed to respecting all your rights as a Data Subject. Therefore, we provide a communication channel to resolve any questions, suggestions, or requests related to the processing of collected Personal Data.

Contact our Data Protection Officer (DPO) via email at: gtpd@argoenergia.com.br.

 

4. How do we collect your Personal Data?

The information we process about you may have been provided directly by you to Argo, obtained from third parties, or automatically collected through our platform and other channels.

Let’s better understand each of these data collection situations:

a. Information provided directly by You

From the moment You interact with us, You voluntarily provide information about yourself. For example, when You contact us through social media, including registering for participation in a selection process via LinkedIn or similar platforms, through our service channels, or through our Ethics Channel when You interact with our platform’s content via phone, email, or other tools like the "Client Area."

b. Information obtained from third parties

In specific cases, we may also receive some of your Personal Data from third parties, such as information provided by partners in contracts with Argo.

c. Information collected automatically

In some situations, we may also collect Personal Data automatically through the devices You use to access our platform. This information helps us generate access statistics and better understand our audience. This is important so that we can improve our platforms and services and adapt them to various audiences. Some of this data may be collected through Cookies or similar technologies, as explained in a dedicated section below.

d. Publicly available information

We may also collect information about you that is publicly available, such as on social media (like LinkedIn) and databases of public bodies (such as the Federal Revenue Service).

 

5. What Personal Data do we process?

To respect your privacy, we believe that any and all Personal Data Processing must be limited to the minimum necessary, relevant, and proportional to achieve the intended purpose.

Therefore, the Personal Data we collect about You will vary depending on the relationship you choose to have with us, whether as a customer, consumer, visitor, partner, among others.

Below, categorized into groups, we present the main types of Personal Data that we may process:

• Registration data: name, date of birth, RG, CPF.
• Qualification data: residential/commercial address, marital status, nationality, affiliation.
• Contact data: landline or mobile phone, personal and/or professional emails, residential/commercial address.
• Financial data: bank account and branch.
• Professional and academic data: profession, workplace, job title, professional history, academic qualifications, diplomas and other certifications, enrollment number, academic background, school/academic history, languages, professional experience, salary expectations, date of hiring, languages, and other information found on your resume.
• Behavioral data: consumption or professional profile, social media usage patterns, travel history.
• Sensitive Personal Data: data related to racial/ethnic origin, health (such as a possible disability – PCD), occupational risks, or union affiliation.
• Attributes associated with your electronic devices: access provider, operating system, browser (type, version, enabled options, and installed plugins), video settings (size/resolution and color depth), date and time of access, and pages viewed through Cookies.

6. Your duty to inform us of any changes to your Personal Data

Article 6, item V of the LGPD emphasizes the quality of data as one of its principles, aiming to ensure that Personal Data is collected, processed, and stored accurately and relevantly.

Argo is not responsible for the accuracy, inaccuracy, or outdated information and Personal Data provided by You, and it is your responsibility to provide accurate information and keep it updated.

Therefore, we ask that You inform us of any changes to your Personal Data during your relationship with us so that we can keep it accurate and current.

 

7. Why do we use your information?

The Personal Data we collect may be used for the purposes described in the table below:

 

8. What are cookies, and how do we use them?

Cookies are text files that may be stored on your electronic devices when you visit our platform. Argo uses this tool for various purposes, such as generating access statistics and improving your experience on our platform.

We have listed below the types of Cookies used and their purposes:

We emphasize that Necessary Cookies are essential for the normal functioning of our platform. This means that if You oppose the use of this tool, it may result in the inability to use our platform or suspension of your access.

If you do not want your information to be collected through Cookies, there is a simple procedure in most browsers and devices that allows non-essential Cookies to be blocked.

 

9. With whom do we share your Personal Data?

It is possible that Argo may share your Personal Data, and in such cases, the sharing will be restricted to the minimum amount necessary and appropriate for achieving one of the specific purposes previously communicated to you in this Notice.

Thus, we may share your data with third parties in the following situations:

• When it involves a company that is part of the group to which Argo belongs or affiliated companies, to enable the achievement of the results of our research and the subsequent disclosure of these indicators.
• Business partners, service providers, subcontractors, and other suppliers, within the scope of what is necessary, and always in accordance with applicable Brazilian legislation, adopting the best information security practices to enable communication and marketing channels, as well as the infrastructure necessary for the viability of our services.
• In the event of a corporate operation, such as a merger, acquisition, split, or incorporation.
• With administrative and judicial authorities, when necessary to comply with a legal obligation or to assist in the investigation of suspicious or illegal activities; and
• With law firms, legal advisors, and other legal representatives, when necessary to defend Argo's interests in administrative, arbitral, or judicial proceedings.

When we share your Personal Data in the situations mentioned above, we use contractual instruments to ensure that any third party receiving the data guarantees its adequate protection.

In situations where the sharing involves a third party located outside Brazil, in addition to ensuring the security and protection of the Personal Data through a contract, Argo will rely on one of the legally authorized grounds for international transfer permitted by law.

 

10. How long do we store your Personal Data?

We will not retain your Personal Data for longer than necessary to fulfill the purposes stated above, nor will we use your data for other purposes, except in cases authorized by law.

When the retention of Personal Data after the intended purpose has been achieved is required, the criteria for determining the retention period will be as follows:

• If we have a legal, regulatory, or contractual obligation or are required by a competent authority to retain Personal Data; and
• If it is necessary to maintain accurate commercial and financial historical records or to meet Argo’s internal requirements.

The termination of Personal Data Processing will occur when:

• The purpose for which the data was collected has been achieved, or the collected Personal Data is no longer necessary or relevant to achieving the intended specific purpose.
• There is a manifestation by the Data Subject to terminate, particularly in cases where Argo received specific consent for the processing of Personal Data; or
• There is a legal or judicial determination to cease processing.

In cases of termination of Personal Data Processing, unless otherwise required by applicable law or this Policy, the Personal Data will be deleted by Argo but may remain stored in backup systems under the terms of the Personal Data Retention Policy.

 

11. How do we protect your Personal Data?

We have internal policies and procedures that dictate how Personal Data should be handled by Argo. These guidelines aim to ensure the appropriate and lawful Processing of the Personal Data we hold.

In addition to these organizational and governance measures, we also adopt several technical measures to ensure even greater security for your Personal Data, including but not limited to:

• Strict control over Personal Data Processing, including access limitation and password-protected access.
• The implementation of an information security program.
• Segregation of access to Personal Data.
• Guidelines for password protection; and
• Access to services exclusively through secure networks.

Despite our best efforts to protect the Personal Data we have access to, we acknowledge that incidents can happen, as no security system is foolproof. Therefore, if any of your Personal Data is exposed in any way, we will take the necessary steps to mitigate and manage the risks, including notifying you and the relevant authorities when necessary.

If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of your data has been compromised), please inform us immediately.

 

12. International Transfers

In general, international transfers occur when the Controller offers and proves guarantees of compliance with the principles of Data Subject rights and the data protection regime outlined in the General Data Protection Law (LGPD), in the form of:

(I) specific contractual clauses for a given transfer; (II) standard contractual clauses internationally known as Standard Contractual Clauses (SCCs); (III) global corporate norms or binding corporate rules known as Binding Corporate Rules (BCRs); or (IV) certifications, seals, and codes of conduct issued on a regular basis.

Some services provided by the platform require the support of a technological infrastructure that may be located outside of Brazil, such as servers and cloud services that may be owned or provided by third parties.

In such situations, the transfer will always be carried out for the purposes described in this Notice, and we will make efforts to seek out third parties who meet the highest security standards, ensuring protection of Personal Data at least equivalent to Brazilian legislation.

 

13. What are your rights, and how can you exercise them with Argo?

Whatever your relationship with Argo, you are guaranteed all the rights related to your Personal Data provided by law, including:

• Knowing whether we process any of your Personal Data.
• Knowing which Personal Data of yours we process.
• Correcting incomplete, inaccurate, or outdated data.
• Requesting the anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in violation of the law.
• Requesting the portability of data to another service or product provider.
• Requesting the review of automated decisions that affect your interests.
• Requesting the deletion of data processed with your consent.
• Obtaining information about public or private entities with which we share your data; and
• When the processing activity requires your consent, you may refuse to give it. In such cases, we will inform you of the consequences of not carrying out that activity. If you give consent, you may revoke it at any time.

You can exercise your rights at any time. To do so, contact our Data Protection Officer via email at gtpd@argoenergia.com.br. For this, we ask that you identify yourself and indicate which right you wish to exercise.

It is possible that other information and/or documents will be requested by Argo to confirm your identity or verify the accuracy of your information.

Requests involving Personal Data and/or documents of other Data Subjects will not be honored unless authorized by power of attorney, parental authority, or another legitimate authority enabling you to exercise the rights of another Data Subject.

It is important to note that, in specific circumstances, your request may not be granted. In such cases, we will explain the reasons justifying the refusal.

 

14. Questions?

If you have any questions, feel free to contact our Data Protection Officer via email at gtpd@argoenergia.com.br.

 

15. Update

Some of the information provided in this Notice may be updated or changed. Therefore, we advise you to check this Privacy Notice periodically. When there are any changes, we will inform you on our homepage. 

Last update of this Privacy Notice: 10/09/2024