E-REDES
Privacy policy
Digital Channel Privacy Policy
1. Purpose
This Privacy Policy regulates the processing of personal data within the scope of the E-REDES Portal (available here, also referred to as the ‘Portal’) and the E-REDES App (which can be downloaded via the following links here and here, also referred to as the ‘App’). Together, the Portal and the Reserved Area will be referred to as ‘Digital Channels’.
E-REDES - Distribuição de Eletricidade S.A. (also referred to as ‘E-REDES’), legal person number 504 394 029, with its registered office at Rua D. Luís I, n. 12, 1249-004 Lisboa. º 12, 1249-008 Lisboa, as operator and concessionaire of electricity distribution networks, is responsible for processing the personal data it obtains in the context of using the Digital Channels, under the terms and for the purposes indicated in the applicable personal data protection legislation, in particular the General Data Protection Regulation (hereinafter ‘GDPR’)0F[1], its Implementing Law1F[2], as well as the Electronic Communications Privacy Act2F[3].
In this regard, the data subject (‘User’) is informed about how E-REDES collects, processes and protects the personal data provided to it through the use of the Digital Channels.
E-REDES guarantees Users respect for their privacy by adopting the necessary measures to protect their personal data. Users must read this Privacy Policy carefully and decide freely and voluntarily whether they wish to use the Digital Channels by providing their data to E-REDES.
The User guarantees that he/she is of legal age and that the data provided is true, accurate, complete and current, and is responsible for any non-compliance. When the data communicated belongs to a third party, the User guarantees that they have informed the third party of the conditions set out in this document and that they have obtained their authorization to provide their data to E-REDES for the purposes indicated.
- This Privacy Policy should be read in conjunction with the Terms and Conditions of the Portal (here) and the App (here), as well as the Cookies Policy (here).
2. Data collection and processing - Portal and App
Users can access the Portal freely, particularly the open area of the Digital Counter (accessed here), without having to register.
2.1 Portal registration data
However, in order to take advantage of certain functionalities provided on the Portal, the User will have to authenticate themselves at the Digital Counter.
In order to access the aforementioned features, a User profile must be created (accessed here) by providing, in the case of a private customer: their email address, tax identification number (TIN), name, mobile phone number; or in the case of a business customer: Corporate Identification Number (TIN), name, address, email and mobile phone number. The User guarantees that the data provided is true, accurate, current and authentic, and must keep it updated at all times. Once registration has been validated, E-REDES will send you a link to set your password and activate your reserved access.
2.2 App registration details
As with the Portal (Balcão Digital), in order to take advantage of certain functionalities provided in the App, the User must register.
Registration in the App follows the same procedure defined for the Reserved Area of the Digital Branch as described above.
2.3 Registration data in the Reserved Areas of Local Authorities, Suppliers, the Collective Self-Consumption Manager and the LV Network Operator
User registration in the Reserved Area for Local Authorities, Suppliers, Collective Self-Consumption Managers and LV Network Operators is carried out by an Access Manager from the respective organization to which it relates.
- To access the Municipalities Reserved Area, you must provide your name, user ID, email address, address (optional), mobile phone number, profile, job title (optional), indicate whether you are an access manager (yes/no) and contact person (yes/no);
- In the case of access to the Suppliers' Reserved Area, the name, user ID, mobile phone number (optional), job title/theme (optional) and profile must be provided;
- With regard to the Collective Self-Consumption Manager's Reserved Area, the name, user ID, mobile phone number (optional), job title/theme (optional) and profile must be provided;
- For access to the LV Network Operator's Reserved Area, the name, user ID, mobile phone number (optional), job title/role (optional) and profile must be provided.
In all cases, once the user has been registered by the Access Manager, a link is sent by E-REDES to the user to set the password and activate the reserved access.
To access the Reserved Area for Local Authorities, here, for Suppliers, here, for the Collective Self-Consumption Manager, here, and for the LV Network Operator, here, the user ID and password must be entered.
- The data required on the registration form is necessary to create an account in the Reserved Area.
2.4 Access data
With regard to the data used to access the Reserved Areas, namely the TIN, email address, user ID (applicable, on the Portal - Balcão Digital - to the Reserved Area of Local Authorities and Suppliers) and password, the User is responsible for maintaining their confidentiality and must not disclose them to third parties or browse in conditions that allow them to be decoded and copied by third parties. Any access to and use of the Reserved Area using the User's credentials will be the User's sole responsibility.
In addition, E-REDES also processes data relating to your use of the Reserved Area, with a view to providing you with a better user experience and presenting you with content that meets your requirements.
Within the scope of the Reserved Areas of the Digital Counter, Local Authorities and Suppliers, as well as the App, the data will be processed for the following purposes in particular:
- Consultation of the history of readings (available in the Reserved Area of the Digital Counter and in the App);
- Checking consumption (available in the Reserved Area of the Digital Counter, the App and the LV Network Operator);
- Centralization of information on consumption sites (available in the Reserved Area of the Digital Counter and Municipalities);
- Quality of service for faults at the place of consumption (available on the App);
- Requests for information/operation (available in the Reserved Area of the Digital Counter, Local Authorities, Suppliers and Collective Self-Consumption Manager);
- Consultation of documentation (contract, invoicing) (available in the Reserved Area of Local Authorities, Suppliers and Collective Self-consumption Manager);
- Customer service appointments (available in the Reserved Area of the Digital Counter and Suppliers);
- Direct processes (requests/messages) with the DSO to fulfil the network access contract (available in the Reserved Area for Retailers, Collective Self-consumption Manager and LV Network Operator);
- Aggregated consumption data with the volume of energy per market agent (available in the Suppliers' Reserved Area).
3. Data collection and processing - Other Portal and App functionalities
Even if you are not registered in the Reserved Area, you can make your request to connect to the network via the Portal (Digital Counter). To do so, you must fill in the forms available here. The form must include your identification details (name and VAT number), address, postcode, email address and telephone number, without which it will not be possible to make a request for connection to the network.
Under the same terms, you can also notify us of your energy consumption reading on the Portal (Balcão Digital). To do so, fill in the form available here. The personal data required to use this service is your Point of Delivery Code (PDC) and your VAT number. You can also optionally provide us with your email address if you would like to receive an alert confirming that you have submitted your reading to the commercial system.
You can also notify us, via the Portal (Balcão Digital) or the App, of a risk situation (here) and proximity to vegetation (here). In these cases, your personal data must be provided: your name, telephone number and email address. You can also notify us of power outages (here) by providing us with your CPE and your NIF.
You can also inform us of any illegal use of electricity, here, available on the Portal (Balcão Digital) and on the App. You don't have to provide us with any personal data, but you can provide us with your name, telephone number and/or email address.
Through the Portal (Balcão Digital), you can also notify us of any damage you have suffered to your premises as a result of an incident related to electricity distribution. To do this, you must fill in this form (here), where we ask you to provide us with your Customer details, including, obligatorily: your name, street, postcode, town, CPE, VAT number, email address and telephone number.
You can also use the Portal and Digital Branch to contact us (here), without having to create an account in the Reserved Area. When you wish to use this means of contact, you must provide us with, depending on your request: your name, VAT number, EPC, email address and/or telephone number.
All this data is processed solely for the purpose of enabling you to access the services provided through the Portal.
3.1 Internal Regulations on Call Recording at Dispatch Centers within the scope of RND operation
4. Lawfulness of processing
Personal data will be processed for the fulfilment of E-REDES' legal obligations as a distribution network operator (pursuant to Article 6(1)(c) of the GDPR). In addition, certain data may be processed on the basis of the pursuit of legitimate interests related to responding to your contacts, complaints, queries or suggestions, as well as to enable the sharing of news on our websites (pursuant to Article 6(1)(f) of the GDPR). The legitimate interests in question refer both to the interests of E-REDES, which take the form of proactively providing informative communications to Customers, as well as preparing responses to User requests, maintaining contact with the User and allowing the User to share our content, and the legitimate interests of the User in pursuing the aforementioned purposes.
When you make a request to connect to the network, as mentioned above, without prejudice to the processing required under E-REDES's legal obligations, we may process your personal data for the purpose of executing the relationship established between you and E-REDES after acceptance of the quotation and which ceases with the realization of the connection to the network and payment of the associated costs (under the terms of Article 6(1)(b) of the GDPR).
Within the scope of our Reserved Area, we may process your personal data for the purpose of providing you with the services defined in the Terms and Conditions, as results from the agreement established with you in this document (pursuant to Article 6(1)(b) of the GDPR).
5. Sharing news
Through the Portal, the User can share relevant news on the various social networking platforms, namely: Facebook, LinkedIn and Twitter. E-REDES cannot be held responsible for the processing of your personal data carried out by these platforms following your sharing. Users should therefore carefully read the Terms and Conditions and Privacy Policies of these platforms before sharing news.
You can find more relevant information about the use of cookies or other tracking technologies to support the news sharing functionality in our Cookie Policy (here).
6. Transfer of data to third countries
E-REDES will endeavor to ensure that the processing of personal data takes place entirely within the European Economic Area.
Exceptionally, and when strictly necessary for the pursuit of its activities, E-REDES may transfer the personal data collected to third countries or international organisations for which there is an adequacy decision by the European Commission, or subject to the appropriate safeguards provided by law (pursuant to Article 46 of the GDPR). When transferring data to third countries or international organizations on the basis of appropriate safeguards, E-REDES will take additional measures to ensure that personal data enjoy a level of protection essentially equivalent to that existing in the European Union.
In addition, data collected during your browsing on our website, namely through cookies and other similar technologies, may also be transferred outside the EEA if you give your consent to the placement of certain categories of cookies (e.g. analytical or advertising cookies). These cookies are placed by third parties who may transfer your data to countries which do not have an adequacy decision from the European Commission and which do not offer a level of personal data protection essentially equivalent to that of the European Union (e.g. the United States of America), such as the web analysis and optimisation service ‘Google Analytics’, provided by Google Ireland Limited. By way of example, sharing data with service providers outside the EEA (such as Google LLC) could result in disproportionate access to your data by the government authorities and intelligence services of the country importing the data or the impossibility of effectively exercising your rights. For more information on the use of these cookies, please consult our Cookie Policy.
If the Data Subject wishes to obtain more information about the processing of personal data carried out outside the EEA, including the safeguards adopted in the transfer of data, he/she may contact the Data Controllers at the contact details provided in this Policy.
7. Retention period
The personal data collected will be kept for the period of time necessary to fulfil the aforementioned purposes, namely:
- Data related to access to networks, reading and making data available, and recording energy consumption/delivery point. These will be kept for up to 10 years or, in some cases, for the entire existence of the CPE and RPE;
- Data related to network connections, network operation and exploitation, legal and administrative operations, and audits will be kept for up to 20 years;
- [Data related to billing and debt management, consumption anomalies and reporting to the regulator will be kept for up to 10 years];
- Data related to supporting the processes of switching supplier, operational efficiency and continuous improvement, customer service, and handling complaints and interventions at the point of consumption will be kept for up to 5 years;
- Any other data collected through the Digital Channels will be kept for the period strictly necessary to fulfil the purpose for which it was collected;
- Personal data may also be kept for a longer period when required by law and/or to defend rights and interests in legal proceedings.
8. Users' rights
Users may, at any time and free of charge, exercise their rights of access, rectification, erasure, opposition, limitation of processing and portability of their data, in accordance with the law. Users may also withdraw their consent when this is the basis for the lawfulness of the processing, knowing, however, that this does not affect the processing previously carried out on the basis of the consent given, although they may no longer be able to access the tools that require the User's consent.
Rights of the data subject:
Right of Access
The right to obtain confirmation of what personal data is being processed and to obtain a copy of the personal data being processed.
The right to obtain such a copy is without prejudice to the rights and freedoms of third parties, including trade secrets or intellectual property and, in particular, copyright protecting software.
Right of rectification
The right to request the rectification of inaccurate personal data or to have incomplete personal data completed.
Right to Erasure
The right to have your personal data erased.
This right shall not apply when the processing of the data is necessary for the fulfilment of a legal obligation to which E-REDES is subject.
Right to Restriction of Processing
Right to request the limitation of the processing of your personal data by requesting the suspension of processing or the limitation of the scope of processing to certain categories of data or processing purposes.
Right to Portability
The right to receive the data you have provided to E-REDES in a commonly used, machine-readable digital format or to request the direct transmission of your data to another entity that becomes the new controller of your personal data, if the processing of your data is based on your consent or the performance of a contract.
Right to object
The right to object to data processing, for example in the case of data processing for the purposes of sending marketing communications or for processing carried out to realize targeted online advertising, based on the legitimate interests of E-REDES.
The User may exercise these rights in writing using the online form available in the Contact Us area of E-REDES (here) or by telephone on 218 100 100.
To this end, E-REDES may ask the User for evidence or elements necessary for their identification to the extent strictly necessary and proportionate in the exercise of the specific right.
The User also has the right to lodge a complaint with the National Data Protection Commission or other competent supervisory authority if they consider that the processing of their personal data is unlawful.
9. Data recipients
E-REDES may transmit your personal data to subcontractors for the purposes mentioned above, under the terms of the contracts entered into with them and guaranteeing compliance with the subcontracting obligations under the applicable legislation, particularly with regard to security in the processing of your data.
Finally, E-REDES may also communicate Users' personal data to third parties when the transmission is carried out in fulfilment of a legal obligation, a decision by the National Data Protection Commission or other relevant supervisory body, or a court order. They may also be communicated to protect Users' vital interests, with their consent or for any other legitimate purpose provided for by law.
10. Cookies
DigItal Channels uses cookies. To find out more, visit our Cookie Policy, here.
11. Security measures
E-REDES makes its best efforts to protect Users' personal data from unauthorized access via the Internet. To this end, it uses security systems, rules and other procedures to ensure the protection of personal data, as well as to prevent unauthorized access to data, improper use, disclosure, loss or destruction.
It is, however, the responsibility of Users to guarantee and ensure that the computer used to access the Portal is adequately protected against harmful software, computer viruses and worms. In addition, Users should be aware that without the adoption of appropriate security measures (e.g. secure browser configuration, up-to-date antivirus software, security barrier software and not using software of dubious origin), the risk of personal data and passwords being accessed by unauthorized third parties is increased.
In addition, if any defect, bug or anomaly is detected in the Digital Channels, the user must immediately notify E-REDES of its existence and not seek to access commercial information, personal data of other users, alter the characteristics of the Digital Channels or, in any other way, exploit the defect, bug or anomaly to use the Digital Channels in an irregular, unlawful or different way to that designed by E-REDES.
12. Contact
To contact E-REDES, the User can do so via the online form available in the Contact Us area of E-REDES (here) or by telephone on 218 100 100. For any questions relating to this privacy policy, the User may also contact the Data Protection Officer (DPO) at DPO@e-redes.pt.
13. Changes to the Privacy Policy
This Privacy Policy may be amended at any time by E-REDES. When such changes occur, they will be publicized through the Portal and/or communicated to Users through the contacts provided.
Date of last amendment: 25 October 2022
[1] Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
[2] Law no. 58/2019, of 08 August.
[3] Law no. 41/2004, of 18 August, transposing Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (in its most current version).