Privacy Notice

PRIVACY NOTICE

DATA CONTROLLER: TALENTOBE, with registered office at 31100 Treviso (TV), Via G. Massari n. 2, certified e-mail (PEC): talentobe@legalmail.it, acts as data controller pursuant to Article 4(7) of Regulation (EU) 2016/679 (“GDPR”) for the processing operations described in this Privacy Notice, relating to the Clients, Members and Prospects who use the TALENTOBE website and/or Platform.
For certain processing of personal data relating to candidates, job applicants and/or personnel of our Clients carried out through the Platform, TALENTOBE instead acts as data processor pursuant to Articles 4(8) and 28 GDPR, on the basis of specific data processing agreements entered into with the Clients, who remain data controllers for such activities and provide data subjects with the relevant primary privacy notice.

Any material changes to the privacy notice (“Privacy Notice”) will be published on this page.

This Privacy Notice applies to Talentobe, an Italian limited liability company. Talentobe is committed to protecting your personal data. This Privacy Notice is intended to provide information on how we collect, use, share and otherwise process information relating to the personal data of individuals, as well as on your rights and choices regarding the processing of your personal data. Please read this Privacy Notice before browsing any Talentobe website or application, providing any personal information to Talentobe, or purchasing any product or service. If you do not agree with our policies and practices, do not use the Talentobe application, website or products or services. By accessing or using a Talentobe website or application, providing personal information to Talentobe or purchasing products or services, you accept this Privacy Notice.

This Privacy Notice may be amended from time to time (see Updates to the Notice). Your continued use of the Talentobe website, application or products or services after changes have been made is deemed to constitute acceptance of those changes, so please check this Privacy Notice periodically for updates. This Privacy Notice also applies to Talentobe’s mobile and web applications (“App”).

Although we have chosen to specifically identify and discuss the GDPR and the LGPD, this does not change our position with respect to other privacy laws in force in the jurisdictions in which Talentobe operates.

These rules strengthen the rights and obligations of data controllers, data processors, data subjects and data recipients.

In the course of its business, Talentobe processes personal data by collecting information relating to its Clients, Members and Prospects.

For a proper understanding of this Privacy Notice, please note that:

“Assessment” means Talentobe’s MyPrint Assessment or the equivalent version used by Clients and Members under this Privacy Notice.
“Clients” may be described as natural or legal persons who purchase Talentobe’s Assessment Packs, a licence or subscription to Talentobe Manager or access to Talentobe’s APIs. Clients typically include those who wish to recruit personnel and/or assess the skills of their Members, but also employment professionals, who may be described as natural or legal persons whose business is in the field of personnel search, in particular recruitment agencies, temporary employment agencies, companies in the temporary work sector or consultancy firms for interim management or human resources.
“Members” may be described as any natural person who registers on the Talentobe website or application, regardless of whether that person completes the Assessment.
“Prospects” means any potential client of Talentobe whose contact details were received at events, on business cards, etc.
“Talentobe Manager” means Talentobe’s SaaS Platform, application and related APIs or its equivalent during the term of this Agreement; and

In order to meet its business needs, Talentobe implements and processes personal data relating to its Clients, Members and Prospects.

The purpose of this notice is to fulfil Talentobe’s information obligation and thus to formalise the rights and obligations of its Clients, Members and Prospects with regard to the processing of their personal data.

The processing of personal data may be carried out directly by Talentobe or through a data processor specifically designated by Talentobe.

This notice is independent of any other document applicable within the contractual relationship between Talentobe and its Clients, Members and Prospects, including the Terms of Use, the General Terms and Conditions or the Cookie Policy.

GENERAL PROVISIONS

PURPOSES OF DATA PROCESSING AND LEGAL BASIS

The purposes of the data processing are as follows: commercial (related to the contractual performance of the services requested) and compliance with the administrative, accounting and tax obligations imposed by law. Requesting services from TALENTOBE S.R.L. entails the necessary processing of the personal data you provide. The data and information will be processed for purposes strictly necessary for the performance of the service requested, namely: to acquire the information needed to carry out the activities preparatory to the provision of the services; to carry out the activities necessary for the conclusion of the contracts relating to the services requested and for their performance; to carry out all the activities necessary for and connected with the management of the contractual relationship relating to the service provided; to comply with the legal obligations laid down by the legislation in force concerning the services provided or to comply with instructions issued by authorities and supervisory and control bodies authorised by specific provisions of law.

Requesting services from TALENTOBE S.R.L. may also entail, subject to your explicit consent, the processing of personal data for: advertising and marketing purposes such as newsletters, promotional communications concerning additional services; and for customer satisfaction surveys. Such commercial and promotional communications may be made by post, e-mail, SMS, MMS and/or other forms of electronic communication. You may at any time express your wish not to receive such communications and promotions.

PURPOSES OF PROCESSING, NATURE OF DATA PROVISION, LEGAL BASIS

The purposes of the processing are as follows: a) Commercial (relating to the contractual performance of the services requested) b) Marketing (advertising and promotional purposes) c) Service quality control e) Service quality control. Compliance with administrative, accounting and tax obligations imposed by law.

a) Commercial purposes (connected with the contractual performance of the services requested) The data and information will be processed for purposes strictly necessary for the performance of the service requested, namely: to acquire information needed to carry out the activities preparatory to the provision of the services; to carry out the activities necessary for the conclusion of the contracts relating to the services requested and for their performance; to carry out all the activities necessary for and connected with the management of the contractual relationship relating to the service provided; to comply with the legal obligations laid down by the legislation in force concerning the services provided or to comply with instructions issued by authorities and supervisory and control bodies authorised by specific provisions of law (compliance with the administrative, accounting and tax obligations laid down by law). Nature of data provision: mandatory (requesting services from TALENTOBE S.R.L. entails the necessary processing of the personal data you provide). Consequences of any refusal to provide the data: failure to provide the data will make it impossible for the Controller to provide the commercial service requested. Legal basis of the processing: contract and the data subject’s explicit consent.
b) Marketing purposes (advertising and promotional purposes) Requesting services from TALENTOBE S.R.L. may entail, subject to your explicit consent, the processing of personal data for advertising and marketing purposes such as newsletters and promotional communications concerning additional services. Such commercial and promotional communications may be made by post, e-mail, SMS, MMS and/or other forms of electronic communication. You may at any time express your wish not to receive such communications and promotions. Nature of data provision: optional. Consequences of refusal to provide the data: failure to provide data for marketing purposes does not affect the performance of the contracts and services requested, and only means that the Controller will be unable to carry out the processing for the above purposes. Legal basis of the processing: the data subject’s explicit consent.
c) Service quality control Subject to your explicit consent, the Controller may process your data to carry out quality control activities on the services provided in the course of your business relations with the Controller. Purpose of the processing: processing for quality control activities on the services provided in the course of your dealings with the Controller. Nature of data provision: optional. Consequences of any refusal to provide the data: failure to provide data for these purposes does not affect the performance of the contracts entered into with the Data Controller, and only means that the Controller will be unable to carry out the processing for the above purposes. Legal basis of the processing: the data subject’s explicit consent.

Where the activities described above are carried out in the context of recruitment, assessment or personnel management processes organised by one of our Clients, TALENTOBE processes personal data on behalf of that Client, as data processor, in accordance with the instructions issued by the Client and the data processing agreements entered into with the Client. In such cases, the Client remains thedata controller and is responsible for providing data subjects with the relevant primary privacy notice.”

METHODS OF DATA PROCESSING AND STORAGE

The processing will be carried out by TALENTOBE S.R.L. by both digital and paper-based means, in compliance with Article 32 of GDPR 2016/679, by specifically authorised persons and in compliance with Article 29 of GDPR 2016/679. Please note that, in compliance with the principles of lawfulness, purpose limitation and data minimisation, pursuant to Article 5 of GDPR 2016/679, your personal data will be retained for the period necessary to achieve the purposes indicated.

RETENTION PERIOD

Personal data is retained for the time strictly necessary to pursue the purposes for which it was collected, in compliance with the principles of storage limitation and minimisation set out in Article 5(1)(c) and (e) GDPR. As a general rule:

the data of Clients is retained for the entire duration of the contractual relationship with TALENTOBE and, thereafter, for the period necessary to comply with legal obligations or to protect TALENTOBE’s rights;
the data of Members is retained for the period of validity of the account and, after its closure, for the time strictly necessary for the technical deletion of the data or to comply with legal obligations;
the data of Prospects is retained for a maximum period of approximately 24 months from the last relevant contact, unless consent is withdrawn or an objection to the processing is raised, where applicable.

For the data of candidates, job applicants and/or personnel of Clients processed by TALENTOBE as data processor on behalf of Clients, retention periods are determined by the Clients themselves as data controllers and are governed by the relevant contractual agreements with TALENTOBE.”

The data of those who do not purchase or use the services, despite previous contacts, will be immediately deleted or processed in anonymous form if its retention is not otherwise justified, unless valid informed consent has been obtained for subsequent commercial promotion or market research activities. Your personal data will be processed for the purposes referred to in point 2, letters b), c) and d) of this notice until you decide to withdraw your consent and/or request thecessation of the processing and, in any event, will be retained only for the period required by the legislation in force.

SCOPE OF DISCLOSURE AND INFORMATION Please note that the data collected will not be disseminated and will not be disclosed without your explicit consent. It should be noted that, in pursuit of the purposes set out above, TALENTOBE S.R.L. discloses your personal data to third parties that perform and/or provide specific services necessary for the establishment and performance of the services you have requested. The up-to-date list of processors and authorised persons is kept at the Controller’s registered office.

SPECIAL CATEGORIES OF PERSONAL DATA

Pursuant to Articles 9 and 10 of EU Regulation 2016/679, you may provide TALENTOBE S.R.L. with data classified as “special categories of personal data”, i.e. data revealing “racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data concerning health or sex life or sexual orientation”. Such categories of data may be processed by TALENTOBE S.R.L. only with your free and explicit consent, given after reading this notice. The website www.talentobe.com and the Controller’s services are not intended for persons under 18 years of age and the Controller does not collect personal data of minors.

EXISTENCE OF AUTOMATED DECISION-MAKING, INCLUDING PROFILING

TALENTOBE uses assessment and analysis tools, including behavioural and psychometric profiling tools, to provide Clients and Members with descriptive reports and potential indicators, in support of decisions concerning recruitment, development and people management.

TALENTOBE does not take decisions producing legal effects concerning data subjects or similarly significantly affecting them based solely on automated processing, including profiling, within the meaning of Article 22 GDPR. Any decisions (for example concerning hiring, promotion or inclusion in development programmes) are taken exclusively by our Clients, as data controllers, on the basis of their own internal policies and the information they consider relevant.

CLIENT DATA

TYPES OF DATA COLLECTED

Non-technical data (depending on intended use)

– Identity and identification (gender, first name, surname, year of birth, nickname, client code)

– Contact information (e-mail, postal address, telephone number)

– Professional status, where necessary (company, sector, career level, role, position)

– Place of work and position/title

– Avatar / Profile picture

– Social network links: (LinkedIn, Twitter, Facebook)

Technical data (depending on intended use)

– Identification data (IP address)

– Access data (logs, tokens in particular)

– Acceptance data (clicks)

SOURCE OF DATA

Talentobe collects its Clients’ data through:

– Data provided by the Client (paper forms, purchase orders, business cards, etc.)

– Electronic forms completed by Clients

– Data entered online (website, social networks, etc.)

– Registration for events organised by Talentobe (for example, trade fair organisation). We may also rent or purchase databases.

Collection may also take place indirectly through specialised companies or through Talentobe’s partners and suppliers.

PURPOSES

Depending on the case, Talentobe processes its clients’ data for the following purposes:

– Customer relationship management (CRM)

– Management of events organised or attended by Talentobe (conferences, breakfasts, etc.)

– Sending our newsletters or news feeds

– Management of client accounts

– Responding to questions put to us (by telephone or online)

– Improving our services

– Fulfilling our administrative obligations

– Community management

– Conducting surveys

– Compiling statistics

– Contacting Members or other recruiters through the application

– Offering qualified members the job vacancies created by recruiters.

MEMBER DATA

TYPES OF DATA COLLECTED

Non-technical data (depending on intended use)

– Identity and identification (gender, first name, surname, year of birth)

– Geographical information, including city, state and country

– Contact information (e-mail)

– Professional status and, if employed, company, sector, career level, role, position; for students, name of school or university, highest qualification obtained and work experience.

– Place of work and position/title

– Avatar / Profile picture

Technical data (depending on intended use)

– Identification data (IP address)

– Connection data (logs)

– Acceptance data (clicks)

– We store “tokens” when Members or Users sign up or log in using third-party single sign-on (SSO) providers (e.g. Twitter, Facebook, LinkedIn, Google, etc.).

Talentobe does not process sensitive data within the meaning of Article 9 of the GDPR, with the exception of data covered by Article 9.2(f), i.e. data necessary “for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.

SOURCE OF DATA

Talentobe collects its Members’ data through:

– Information collected through Clients

– Electronic forms completed by Members

– Registration or subscription to our online services (newsletters, social networks, etc.).

TALENTOBE’S PURPOSES

Talentobe processes Members’ data for the following purposes:

– Managing the sending of invitations to Members to register on the website

– Managing a Member’s registration process

– Management of client accounts

– Sending summaries and assessment reports to Members

– Sending our newsletters or news feeds

– Responding to questions put to us (by telephone or online).

– Improving our services

– Fulfilling our administrative obligations

– Community management

– Conducting surveys

– Compiling statistics

– Contacting other Members or recruiters through the application

– Offering qualified job vacancies based on Members’ profiles.

USE OF INFORMATION COLLECTED THROUGH BUSINESS SOLUTIONS

Clients, including but not limited to recruiters, head-hunters, individual consultants and/or coaches, may enter certain information about Members when using Talentobe’s business solution, Talentobe Manager. For example, a Client’s recruiter who has requested access to the personal profile of a User who has applied for a job vacancy will have the User’s profile in their Talentobe account. The recruiter will then be able to add comments on the Member’s profile, which may be shared with the recruiter’s colleagues or managers. This information is available to and shared only with the Client’s employees who have access to the Client’s Talentobe Manager business account. Clients using Talentobe Manager may also add other information to their account, such as labels created to classify their candidate pool, or include the Member’s assessment results when using Talentobe Manager’s analysis tools.

PROSPECT DATA

TYPES OF DATA COLLECTED

Non-technical data (depending on intended use)

Identity and identification (gender, first name, surname, year of birth, nickname, client code)
Contact information (e-mail, postal address, telephone number)
Professional status, where necessary (company, sector, career level, role, position)
Place of work and position/title
Avatar / Profile picture
Social network links: (LinkedIn, Twitter, Facebook)

Technical data (depending on intended use)

Identification data (IP address)
Connection data (logs)
Acceptance data (clicks)

SOURCE OF DATA

Talentobe collects its Prospects’ data through:

Business cards
Registration or subscription to our online services (website, social networks, etc.)
Registration for events organised or attended by Talentobe
Lists sent by the organisers of events or conferences we attend. Exceptionally, we may rent databases.

Collection may also take place indirectly through specialised companies or through Talentobe’s partners and suppliers. In this case, Talentobe pays the utmost attention to the quality of the data provided to it.

PURPOSES

Depending on the case, Talentobe processes its Prospects’ data for the following purposes:

Prospect relationship management (PRM)
Management of events organised by Talentobe (conferences, breakfasts, etc.)
Sending our newsletters or news feeds
Responding to questions put to us (by telephone or online)
Community management
Compiling statistics
Conducting surveys.

LEGAL BASIS

TYPES OF DATA COLLECTED

The data processing purposes listed have the following legal basis:

Clients: Pre-contractual or contractual purposes – general terms and conditions of sale relating to recruiters;
Members: Pre-contractual or contractual purposes – general terms and conditions of service relating to Members;
Prospects: Legitimate interest and, where required by law, consent (for example, newsletters).

RECIPIENTS OF DATA

Talentobe ensures that data is accessible only to authorised internal or external recipients.

The recipients of the personal data of Clients, Members and Prospects within Talentobe are subject to a non-disclosure obligation.

Personal data may be disclosed to parties acting as data processors pursuant to Article 28 GDPR (for example providers of hosting and cloud services, providers of electronic communication services, e-mail and notification tools, system performance monitoring tools, technical and IT consultants), duly appointed by TALENTOBE and bound by contractual obligations of confidentiality and data security.

Data is as a rule processed within the European Economic Area (EEA). In some cases, however, transfers may be made to third countries, for example to the United States, limited to the use of specific service providers (such as communication or e-mail sending services). In such cases, transfers take place in compliance with Articles 44 et seq. GDPR and on the basis of appropriate safeguards, such as the Standard Contractual Clauses adopted by the European Commission and, where appropriate, supplementary technical and organisational measures (e.g. encryption, minimisation of the data transferred).

You may request further information on the recipients and on the safeguards applied to transfers to third countries by contacting TALENTOBE at the addresses indicated in this Notice.

Talentobe decides which recipient may access which data on the basis of an authorisation policy.

Talentobe shall not be liable in any way for damage of any kind that may result from unlawful access to personal data.

All access relating to the processing of the personal data of Clients, Members and Prospects is subject to traceability analysis.

In addition, personal data may be transferred to any authority legally authorised to access it. In this case, Talentobe is not responsible for the conditions under which the personnel of such authorities access and use the data.

WITH REGARD TO CLIENTS

Internal recipients

Authorised personnel of the marketing department, the departments responsible for client relations, the administrative departments, logistics and IT services, and their managers.

External recipients

Service providers or support services (e.g. IT service provider, etc.)
Authorised personnel of the departments responsible for control (auditor, departments responsible for internal control procedures, etc.)
Judicial administration, judicial support staff, where applicable
Other clients or other members
Our trusted suppliers

WITH REGARD TO MEMBERS

Internal recipients

Authorised personnel of the department responsible for client relations, the marketing department, the administrative departments, logistics and IT services, and their managers.

External recipients

External recruitment companies (in accordance with this Privacy Notice, and a Member may withdraw consent at any time)
Talentobe’s Clients (in accordance with this Privacy Notice, and a Member may withdraw consent at any time)
Service providers or support services (for example, IT service provider, printing services, etc.)
Judicial administration, judicial support staff
Authorised personnel of suppliers, subcontractors and external data processors.

WITH REGARD TO PROSPECTS

Internal recipients

Authorised personnel of the department responsible for prospect relations, marketing, IT services, and their managers.

External recipients

Service providers or support services (for example, IT service providers, printing services, etc.)

SOCIAL MEDIA

Our website and application may use social media features, such as the Facebook “Like” button, the “Tweet” button and other sharing tabs and links (“Social Media Features”). You may have the option of posting information about your activities on a website on a profile page provided by a third-party social media network in order to share it with other users of your network. Social Media Features are hosted by the respective social network or hosted directly on our website or application.

To the extent that Social Media Features are hosted by the respective social networks, they may receive information that you have visited our website from your IP address. If you are logged in to your social media account, it is possible that the respective social media network may link your visit to our website or application with your social media profile.

Your interactions with Social Media Features are governed by the privacy policies of the companies providing the relevant Social Media Features.

TELEPHONE APPLICATION (“App”) and TELEPHONE LOG INFORMATION

If you use certain features of the service, we may also collect telephony log information (such as telephone numbers, time and date of calls, duration of calls, SMS routing information and types of calls), device event information (such as crashes, system activity, hardware settings, browser language) and location information (through IP address, GPS and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and mobile phone masts).

ANALYTICS

We may use third-party service providers to monitor and analyse the use of our Services.

“Google Analytics” We use a tool called ‘Google Analytics’ and may use other third-party analytics tools to collect information on the use of the Talentobe websites. Google Analytics collects information such as how often users visit the Talentobe websites and which pages they visit when they do so. We use the information obtained from Google Analytics only to improve Talentobe. Google Analytics does not collect your name or other identifying information. Although Google Analytics installs a permanent cookie on your device to identify you as a unique user the next time you visit the Talentobe sites, the cookie cannot be used by anyone other than Google. Google’s ability to use and share the information collected by Google Analytics on your use of the Talentobe sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

CHILDREN’S PRIVACY

Our websites and services are not intended for children under 16 years of age. Children under 16 may not provide information to or through our services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide information to our websites or services or on or through any of their features, do not register to become a member of our website or service, do not use any of the interactive features of our website or services, and do not provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or username you may use. If we become aware that we have collected or received personal information from a child under 16, we will delete that information. If you believe we may have information from or about a child under 16, please contact us at staff@talentobe.com or write to us at: Talentobe, Via Giorgio Massari 2, 31100 Treviso, Italy.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your rights under the CCPA, GDPR, LGPD or any other applicable international, federal or state data privacy protection law.

RIGHTS OF THE DATA SUBJECT

At any time you may exercise the rights set out in Articles 15 to 22 of EU Regulation 2016/679, including:

requesting confirmation of the existence of your personal data;
obtaining information on the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data has been or will be disclosed and, where possible, the retention period;
obtaining the rectification and erasure of the data;
obtaining the restriction of the processing;
obtaining data portability, i.e. receiving the data from a data controller in a structured, commonly used and machine-readable format and transmitting it to another data controller without hindrance;
objecting to the processing at any time, including for marketing purposes;
objecting to automated decision-making concerning individuals, including profiling;
requesting access to personal data and its rectification or erasure or the restriction of the processing, and objecting to its processing, as well as the right to data portability;
withdrawing consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal;
lodging a complaint with the Supervisory Authority, which is the Garante per la protezione dei dati personali, with registered office in Rome, Piazza di Monte Citorio n. 121 – 00186 Rome – garanteprivacy.it – Email: Fax: 06.69677.3785 Switchboard: 06.69677.1

To exercise the rights set out in Articles 15-22 of the GDPR, you may contact TALENTOBE S.R.L. by PEC or by registered letter at the addresses indicated below.

IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER

The Data Controller is TALENTOBE, with registered office at 31100 Treviso (TV), Via G. Massari n. 2, certified e-mail (PEC): talentobe@legalmail.it.

The up-to-date list of data processors is available on the website www.talentobe.com in the Privacy section.

MANDATORY OR OPTIONAL NATURE OF DATA PROVISION

As indicated in this document, the user/client may decide whether to provide their personal data. Only the data strictly necessary for browsing and viewing the pages of the site is mandatory. For service requests and for contact and/or information requests, the provision of data is mandatory within the limits specified in the individual notices provided. The user/client may refuse consent or withdraw previously given consent at any time. However, in the event of refusal, it will not be possible to fulfil requests for commercial services.

UPDATES AND AMENDMENTS TO THE PRIVACY NOTICE

This Privacy notice may change over time, including as a result of the entry into force of new sector legislation, updates, the introduction of new services or technological innovations. Users/visitors are therefore invited to consult this page periodically.

For processing operations in which TALENTOBE acts as data processor on behalf of its Clients, the mutual rights and obligations are governed by specific data processing agreements pursuant to Article 28 GDPR, which define in particular the subject matter, duration, nature and purposes of the processing, the types of personal data, the categories of data subjects, the security measures, the conditions for the use of sub‑processors, the assistance provided to the Client and the procedures for the deletion or return of the data.

FURTHER INFORMATION FOR USERS IN BRAZIL

This section of the document supplements and completes the information contained in the rest of the privacy notice and is provided by the entity operating this Application and, where applicable, by its parent company, subsidiaries and affiliates (for the purposes of this section collectively referred to as “we”, “us”, “our”).

This section applies to all Users in Brazil (hereinafter Users are referred to simply as “you”, “your”, “yours”), pursuant to the “Lei Geral de Proteção de Dados” (the “LGPD”), and for such Users it supersedes any other possibly divergent or conflicting information contained in the privacy notice.

In this part of the document, the term “personal data” is used as defined in the LGPD.

The reasons why we process your personal data

We may process your personal data only if we have a legal basis for such processing. The legal bases are as follows:

your consent to the processing activities in question;
compliance with a legal or regulatory obligation incumbent on us;
the implementation of public policies provided for by laws or regulations or based on contracts, agreements and similar legal instruments;
studies conducted by research bodies, preferably carried out on anonymised personal data;
the performance of a contract and its preliminary procedures, where you are a party to that contract;
the exercise of our rights in judicial, administrative or arbitration proceedings;
the protection of your or third parties’ physical safety;
the protection of health – in procedures carried out by health sector bodies or professionals;
our legitimate interests, provided that your fundamental rights and freedoms do not override such interests;
credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal data processed

To find out which categories of personal data are processed, you can read the section “Detailed information on the processing of personal data” within this document.

Why we process your personal data

To find out why we process your personal data, you can read the sections “Detailed information on the processing of personal data” and “The purposes of processing” within this document.

Your privacy rights in Brazil, how to submit a request and our response to your requests

Your privacy rights in Brazil

You have the right to:

obtain confirmation of the existence of processing activities concerning your personal data;
access your personal information;
obtain the rectification of incomplete, inaccurate or outdated personal information;
obtain the anonymisation, blocking or deletion of unnecessary or excessive personal information, or of information that is not processed in compliance with the LGPD;
obtain information on the possibility of giving or refusing your consent and the related consequences;
obtain information on the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except anonymised information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
obtain the deletion of your personal data being processed if the processing was based on your consent, unless one or more exceptions provided for in Article 16 of the LGPD apply;
withdraw your consent at any time;
lodge a complaint relating to your personal data with the ANPD (National Data Protection Authority) or with consumer protection bodies;
object to a processing activity where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information on the criteria and procedures used for an automated decision;
request a review of decisions taken solely on the basis of the automated processing of your personal data, which affect your interests. These are decisions that define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, nor suffer any kind of detriment, if you exercise your rights.

How to submit your request

You may submit your explicit request to exercise your rights free of charge, at any time, using the contact details provided in this document or through your legal representative.

How and when we will respond to your request

We undertake to respond to your requests promptly.

In any event, should this be impossible, we will make sure to inform you of the factual or legal reasons that prevent us from immediately, or ever, complying with your requests. In cases where we do not process your personal data, we will indicate the natural or legal person to whom you should address your requests, if we are in a position to do so.

If you submit a request for access to or confirmation of the processing of personal data, please make sure to specify whether you would like your personal data to be delivered in electronic or printed form.

You will also need to let us know whether you want us to respond to your request immediately, in which case we will respond in a simplified manner, or whether you need full disclosure instead.

In the latter case, we will respond within 15 days of your request, providing you with all the information on the origin of your personal data, confirmation of whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

If you submit a request for rectification, deletion, anonymisation or blocking of personal data, we will make sure to immediately communicate your request to the other parties with whom we have shared your personal data, in order to enable such third parties to fulfil your request, except in cases where such communication proves impossible or involves a disproportionate effort on our part.

Transfer of personal information outside Brazil permitted by law

We are authorised to transfer your personal data outside Brazilian territory in the following cases:

where the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, in accordance with the legal means provided for by international law;
where the transfer is necessary to protect your life or physical safety or that of third parties;
where the transfer is authorised by the ANPD;
where the transfer results from a commitment undertaken in an international cooperation agreement;
where the transfer is necessary for the implementation of a public policy or the legal attribution of a public service;
where the transfer is necessary for compliance with a legal or regulatory obligation, for the performance of a contract or preliminary procedures relating to a contract, or for the regular exercise of rights in judicial, administrative or arbitration proceedings.