Privacy Policy

Hello! Welcome to Minum!

In this document you will find our privacy policy and notices. We use clear, practical and accessible language. We recommend that you read and understand what your rights and duties are when using our services by accessing our Terms: https://minum.com.br/en/terms-of-use/. 

Below we list the subjects that you will find in this document:

  1. Intro
  2. Your rights and control over your data
  3. Data we collect about you
  4. How we use your data
  5. Sharing your data
  6. Data retention
  7. Data transfer
  8. How we protect your data
  9. Minors
  10. Changes to this policy
  11. How to contact us about privacy

1. Intro

This privacy policy (“Privacy Policy”) describes how we process your personal data at Minum. It is important that you carefully read and understand both this Privacy Policy and our Terms. For the definition of any capitalized terms in this Privacy Policy not otherwise defined in this document, please refer to our Terms.

Our Privacy Policy applies to your use of:

  1. All Minum Services and access and use of the Minum Platform. This includes, for example:
    • Your use of the Minum platform on any device;
    • The personalization of your user experience;
    • The infrastructure and technology necessary to provide our Services;
    • The equipment, meters, and other hardware necessary to provide our Services;
    • The connection of your Minum account and Minum Platform with other applications and third-party services;
    • Our free, public, paid and/or private content across the Minum Platform and all digital and social media channels, including our website; and
  2. Any of our Services that reference this Privacy Policy. This includes use and access of the Minum Platform and any contracted Services.

From time to time, we may adjust or expand our Services, the Minum Platform and our digital content. Unless otherwise mentioned, this Privacy Policy will apply to any and all of our offerings. Please note that our Services are governed by additional privacy considerations contained in your plan documents.

By accessing, browsing, registering for or using any of our services, you represent that you have read, understood and fully agree to this Privacy Policy, the Terms and any other guidelines referenced in these documents. If you do not agree to his Privacy Policy, you may contact us at any time via e-mail to contato@minum.com.br.

2. Your rights and control over your data

Several privacy laws govern your personal data rights, primarily the General Data Protection Law (“LGPD”). This includes your user data, usage data, and other data listed in Section 3: Data we collect about you. Some of your LGPD rights only apply depending on the purpose (“Purpose”) for processing your data. In this Privacy Policy, we explain each legal basis and when we use your data. Please refer to Section 4: How we use your data.

There are situations in which Minum cannot delete your data, including:

  1. When necessary to process the data for the Purpose for which we collected it;
  2. When our interest in the use of the data overrides your right to exclude such data. For example, if we need to retain data to protect against fraud;
  3. When we have a legal obligation to keep the data; and
  4. When we need the data to establish, exercise or defend against any legal claim. For example, if there is an unresolved issue related to your account.

To request the deletion of your personal data not subject to the above exceptions, please contact our support team.

3. Data we collect about you

Below we describe the types of personal data that we collect:

  1. Data collected when you access our website, Minum Platform;
  2. Data collected when you create a User Profile or engage our Services; and
  3. Personal data needed to create and maintain your User Profile and that allows us to provide you with our Services.

The type of personal data we collect and how we use it depend on whether or not you have engaged any of our Services. It also depends on how you create and access the Minum Platform, the country you’re in, and whether you use any third-party services to access or use the Minum Platform. This personal data may include: 

  • Your name, identity document, and/or CPF;
  • Your date of birth;
  • Your gender;
  • Your address and country;
  • Your phone number(s) and email address;
  • Your User Profile data, including login and password;
  • Your utility bill(s) and related utility account information, including login information;
  • Your billing and payment information; and
  • Information related to your Unit(s) registered in the Minum Platform and with your utility.

We receive some of this data from you, for example, when you fill out any registration form, create a User Profile or upload your utility bill to receive an offer for our Services. 

We also collect some data from your device, such as your country and location. For more information about how we collect and use this generalized location data, please refer to Section 4: How we use your data.

We may request and process your personal data for the following Purpose:

  • Verify your eligibility for our Services;
  • Provide relevant, geographically appropriate information and content;
  • Provide our Services and access to our Minum Platform;
  • Deliver any notices as required by law;
  • Provide customer support options;
  • Administer billing, tax and financial matters;
  • Deliver physical products, gifts or other items that you have requested or otherwise acquired;

In some cases, we may use a third-party app to help you verify your address, such as Google Maps.

Data related to use of the Minum Platform or our Services

We collect and process personal data when you access or use the Minum Platform or engage our Services. We also collect and process data related to your usage and engagement with us, the Minum Platform, and our Services. This information includes: 

  1. Information about how you interact with us. Examples include:
    • Information about your Services, including your Services agreements and plan documentation;
    • Your interactions with the Minum Platform and use of our Services (including date and time);
    • Your use of third-party services, devices, and applications in connection with our Services and the Minum Platform;
    • Inferences (i.e., our understanding) of your interests and preferences based on your interactions with us;
    • Content you provide when participating in promotions and programs, such as contests or sweepstakes;
    • Content that you post on any part of the Minum Platform. For example: images, audio, text, names, descriptions, communications, and other types of content.
  2. Your technical data. Examples include:
    • URL;
    • Online identifiers, such as cookie data and IP addresses;
    • Information about your devices and accounts, such as: device ID; third-party account IDs provided by you; type of network connection (e.g., WiFi, 4G, LTE, Bluetooth); provider; network and device performance; browser type; language; information that enables digital rights management; your operating system; and which version of our software you are using.
  3. Information that allows us to discover and connect with third-party devices and applications. Examples of this information are device name and ID, brand, and version.
  4. Your general location includes country, region, or state. We can learn this from technical data (e.g., your IP address, your device’s language setting). 

If you engage our Services or make any other purchase or payment, or participate in any trial offer or benefits program, we will need to handle your payment details. The exact personal data collected and used will vary depending on your payment method. This information may include:

  • Your name, identity number and CPF;
  • Your date of birth;
  • Your payment method (e.g., credit or debit cards), including the type of card, expiration date and certain digits;
  • Your billing address and zip code;
  • Your mobile number; and
  • Details of your purchase and payment history.

When you complete a survey or participate in a user study, we collect and use the personal data you provide. We also receive some personal data from third parties, including your utility. The following table describes the different third parties that process or provide your personal data:

PartyData collection and processing
Authentication partnersIf you register for or access our Services or the Minum Platform using another service, we will receive your information from that third party
Third party applications, services and devicesIf you connect any devices, apps, services or hardware to your User Profile, the Minum Platform or to your account or that is provided under the terms of our Services, we may collect and use this information for integration, interoperability with the Minum Platform and our Services
Technical service providersWe work with technical partners who support any installations, review and assessment of your Unit(s) and other service providers in connection with providing and tailoring our Services. This includes security providers who help us protect your account and personal data;
Payment partners and merchantsIf you choose to pay through a third party (e.g., telecom carriers) or you pay with debit, credit or transfer, we may receive data from our payment partners and/or your financial institution. If we refer you to a third-party merchant, we may receive data from them related to your activities and purchases with them. This allows us to calculate any commissions, manage any benefits, referrals or other programs, assess the effectiveness of our partnerships, and to understand your interests.
Advertising and marketing partnersWe receive certain data and inferences from our advertising or marketing partners. This data include their understanding of your interests and preferences, in order to provide more relevant marketing, content and communications.

4. How we use your data

The information below sets out our Purpose(s) for processing your personal data. You can learn more about the types of data we collect in Section 3: Data we collect about you.

Purposes of collecting and handling your personal data:

  • To provide our Services in accordance with your Services agreement and plan documentation;
  • To enable certain functionalities and interoperability with third-party services, such as enabling the sharing of our content, participation in referrals and partnership programs; 
  • For legitimate business interests, including: 
    • To maintain the Minum Platform and provide our Services;
    • Allow users to access and use the Minum Platform and our Services;
    • To evaluate and develop new features, technologies, and enhancements to our Services and the Minum Platform. For example, we use personal data to develop and improve our algorithms, our service and pricing;
    • To take appropriate action on infringement of intellectual property rights and/or and contractual obligations related to use of the Minum Platform or our Services. 
  • To understand, diagnose, and troubleshoot issues with our Services and the Minum Platform. For example, we use your personal data to respond to your messages when you contact our customer service team, when we detect unusual activity that may indicate a bug; and/or to verify accounts to locate and prevent unauthorized users;
  • For marketing, promotional, and advertising purposes as permitted by law;
  • To comply with any legal obligations, establish, exercise or defend against any legal claims;
  • To ensure compliance with legal obligations, including assisting law enforcement authorities in preventing or detecting serious crime;
  • To fulfill contractual obligations with third parties;
  • To maintain relationships with third parties, partners and servie providers;
  • Perform planning, forecasting and reporting related to business;
  • Process your payments;
  • Detect and prevent fraud; and
  • Conduct research and studies.

5. Sharing your data

This section defines who may receive your personal data collected or generated through your use of the Minum Platform and our Services. We share the following personal data as indicated in the table below. When you decide to use a feature of the Minum Platform or our Services, in relation to third-party applications, services, or devices, it is necessary to share personal data for activation and ongoing operation of our business. We may share additional data in the event you provide us with consent for a specific Purposes.

RecipientsData sharedPurpose
Third party applications, services and devices
  • User Profile;
  • Usage and technical data;
To connect the Minum Platform to your third-party applications, services, or devices and provide our Services
to your Minum Account
Service providers
  • User Profile;
  • Usage and technical data;
  • Payment and purchase data;
  • Consumption and other data related to research and analysis;
To enhance and improve our Services offering. We engage these service providers to, among others:

  • support customer service;
  • install, maintain and operate technical infrastructure and hardware necessary for the provision of our Services;
  • help secure our systems and Services (e.g., Google's reCAPTCHA); and
  • promote our Services and associated products, events and offerings, and those of our service provider partners;
Payment partners and merchants
  • User Profile;
  • Usage and technical data;
  • Payment and purchase data;
To process your payments and for anti-fraud purposes.
Advertising and marketing partners
  • User Profile;
  • Usage and technical data;
  • Payment and purchase data;
  • Consumption and other data related to research and analysis;
To help improve our Services, provide more appropriate content and to measure the effectiveness of our marketing and advertising campaigns. For example, our ad partners help design and deliver personalized advertising and offerings.
Commercial partners
  • User Profile;
  • Usage and technical data;
  • Payment and purchase data;
  • Consumption and other data related to research and analysis;
To partner with third parties to:
  • To allow you to participate in special promotions, benefits, and other bundled offers;
  • To promote our Services in the media and in advertising;
  • To help our partners and Minum evaluate the effectiveness of Minum promotions and manage ongoing and new commercial partnerships;
Our partners may combine the personal data we share with them with other data they collect about you, such as your use of their services. We and our partners may use this information to provide you with offers, promotions, or other marketing activities that we believe may be relevant.
Academic researchers
  • User Data;
  • Usage Data;
  • Consumption and other data related to research and analysis;
To participate in research and studies, but only in pseudonymized format. Pseudonymized data is identified by a code instead of your name or other personal identifying information.
Our group companies
  • User Profile;
  • Usage and technical data;
  • Payment and purchase data;
  • Consumption and other energy data;
To carry out our day-to-day business operations and so that we can maintain, improve and provide our Services and those of our group companies. For instance:
  • To enable our employees working for different group companies to develop, enhance and manage our Services and the Minum Platform;
  • To manage, operate and improve our Services and the Minum Platform
Law enforcement or other entities, as well as other parties related to legal claims
  • User Profile;
  • Usage and technical data;
  • Payment and purchase data;
  • Consumption and other energy data;
When we believe in good faith that it is necessary for us to do the following, for example:

  • Comply with and respond to legal claims;
  • Respond to legal processes (such as a search warrant, court order, or subpoena);
  • In own interest or that of a third party, with respect to:
    • national security;
    • compliance with the law;
    • litigation (judicial process);
    • criminal investigation;
    • protection of physical safety and prevention of imminent death or bodily harm;
Investors and sources of funding
  • User Profile;
  • Usage and technical data;
  • Payment and purchase data;
  • Consumption and other energy data;
If we raise financing or sell or negotiate the sale of our business, we may need to transfer your personal data to a successor or affiliate as part of that transaction, or as part of a due diligence process, in which case data will be pseudonymized.

6. Data retention

We keep your personal data only as long as it is necessary to provide our Services to you and for our legitimate business interests and Purposes, such as:

  1. Maintain and improve the performance of the Minum Platform an our Services;
  2. Make data-driven business decisions about new features and new offerings;
  3. Comply with legal obligations; and
  4. Resolve disputes.

We may apply different retention policies to your data, such as:

  • Indefinite retention, unless and until you request its deletion. Note that you have the right to request the deletion of some, but not all, personal data. Please refer to Section 2 “Your rights and control over your data” for more information;
  • Retention for a specific period. For example, we may not store or may automatically discard historical consumption data when no longer needed for an express Purpose. We may automatically and irreversibly delete such data based on such specific retention period;
  • Retention while you have a User Profile and/our engaged our Services: We keep some data until your User Profile is deleted. 
  • Retention for an extended period of time once our Services have concluded or your User Profile is deleted. For example, some data is retained for a longer period of time for limited Purposes (e.g. after account deletion, for anti-fraud or account reactivation.

7. Data transfer

Due to the global nature of our business, we share personal data internationally with Minum group companies, subcontractors and partners to provide our Services and operate the Minum Platform. We may process your data in countries whose data protection laws are not considered as strong as the LGPD or other laws that apply where you live and engage our Services. For example, they may not give you the same rights over your data.

8. Data transfer

We are committed to protecting the personal data of our users. We have implemented appropriate technical and organizational measures to help protect the security of your personal data. However, be aware that no system is completely secure.

We have a number of safeguards in place to protect against unauthorized access and unnecessary retention of personal data in our systems, including pseudonymization, encryption, access, and retention policies.

To protect your user account, we encourage you to:

  • Use a strong password that is unique to your Minum account;
  • Never share your password with anyone;
  • Limit access to your computer and browser;
  • Log out when not using our Services or the Minum Platform on a shared device;
  • Read more details on how to secure your account.

If other individuals have access to your User Profile, they will be able to access personal data, Unit(s) data, controls, and the Services and devices available through your account. For example, you may have given someone permission to use your account on a shared device.

You are responsible for allowing the use of your account only by people with whom you feel comfortable sharing your personal data.

9. Minors

Our Services have a minimum age and are not intended for minors. If we learn that we have collected the personal data of a minor, we will take reasonable steps to delete such data. This may require the deletion of that User Profile associated with a minor.

10. Changes to this policy

We may, from time to time, make changes to this Privacy Policy. When we make material changes, we will prominently notify you, as appropriate, in accordance with the circumstances. For example, we may show a prominent notice on the Minum Platform, send you an email, or send you a notification on your device.

11. How to contact us about privacy

If you have any questions or concerns about this policy, please contact our Data Protection Officer via contato@minum.com.br or through our official service channels as indicated on our website: https://minum.com.br. 

Any disputes related to this Privacy Policy or these Terms shall be resolved in the courts of São Paulo – SP.