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PRIVACY POLICY

GRUPO CIA DE TALENTOS

  1. Introduction

    Thank you for choosing Grupo Cia de Talentos!


    This Privacy Policy (“Policy”) explains the essential details of the relationship between the User's personal data and Grupo Cia de Talentos (“GCT”), currently composed of the companies: CT - CIA DE TALENTOS RECURSOS HUMANOS LTDA, DM VENCER RECURSOS HUMANOS LTDA and ER52 TECNOLOGIA, CAPACITAÇÃO E SELEÇÃO LTDA and applies to the platform on which the GCT curriculum database is stored, which covers both curricula registered via www.ciadetalentos.com.br and those registered via www.bettha.com.

    The terms governing the use of such platforms by the User are set out in our Terms and Conditions of Use, of which this Policy is part.

    The purpose of this Policy is:

    • explain to the User the respective rights in relation to their personal data collected and processed by us, and how we will protect their privacy;
    • ensure that the User understands which of their personal data we collect, the reasons why we collect and use it;
    • ensure that the User understands which of their personal data we collect may be shared, the reasons and purposes for which we share it;
    • explain how we use the personal data shared by the User when registering in the GCT curriculum database and the advantages and benefits resulting therefrom.

    We hope this Policy will help the User understand our privacy commitments. If you have any questions or concerns, please refer to Item 12 'Contact GCT' for information on how to contact us. On the other hand, if the User does not agree with the content of this Policy, we emphasize that the User is free to decide whether to register and use the GCT platform or not, and may, yet, in some cases, choose not to share certain optional data.

  2. User rights and preferences

    The General Data Protection Law (“Law No. 13.709/18” or “LGPD”) confers certain rights on individuals regarding their respective personal data. As provided for under applicable law and unless limited by it, the rights provided to individuals are as follows:

    • Right to confirm the existence of processing;
    • Right of access to data;
    • Right to correct incomplete, inaccurate or outdated data;
    • Right to anonymization, blocking or deleting unnecessary, excessive, or treated data in non-compliance with the LGPD;
    • Right to portability of data to another service or product provider, protected by trade and industrial secrets of GCT;
    • Right to the deletion of personal data processed with the consent of the holder, except in cases of legal custody and others provided in the LGPD;
    • Right to information of public and private entities with which GCT has shared use of data;
    • Right to information on the possibility of not providing consent and the consequences of refusal;
    • Right to revocation of consent, under the terms of the LGPD.

    If we send you electronic advertising messages based on your consent or otherwise permitted by applicable law, the User may at any time, respectively, withdraw their consent or declare their refusal, at no additional cost. The electronic advertising messages that the User receives from GCT, such as those sent via email, include a refusal mechanism within the message itself, for example, a link to unsubscribe from the emails we send them.

  3. How do we collect the User's personal data?

    We collect the User's personal data in the following ways:

    • When the user subscribes to the platform used by GCT (registers, subscribes or enrolls): to register in the GCT curriculum database it is necessary for the USER to provide certain personal data, such as full name, Individual Taxpayer Registration Number (“CPF”), email address, mobile phone number, level of education, areas of interest, knowledge of languages, city, state, and country, which are collected by GCT for sending invitation(s) to participate in both the process and/or event(s) related to career and/or the labor market, as well as to carry out any professional development trails available.
    • Through the use of the platform adopted by the GCT: when the User accesses the curriculum database, performs tests on it, applies for selection processes and/or participates in research and/or events to which they were invited and/or carries out professional development trails that may become available, we collect personal data from that use automatically or semi-automatically;
    • Personal data whose provision is optional and which is collected to provide the User with more opportunities: eventually, the User may also provide us with additional personal data or authorize us to collect it, for example, to provide them with more employment, trainee or internship opportunities. As described below, we do not collect, without prior authorization from the User, photographs, videos, sexual orientation, health data, location, or voice data. The User can always change their mind and withdraw their consent at any time.
    • Through third parties: we will receive personal data from the User through third parties, including customer companies, partners with whom we work, User-authorized platforms such as LinkedIn, Gmail, or Facebook to send them an invitation to participate in the selection process, event, research, among other interests related to career and labor market. We will use this personal data if the user has authorized the third parties in question.
  4. What personal data of the User's do we collect?

    In the tables below, we organize the groups of personal data of the User that we collect and use:

    • Personal data collected when the User registers in the GCT curriculum database
    Personal Data Group Group description
    GCT account registration data

    This is the personal data provided by the User or collected by us so that the User can register in the GCT curriculum database. It includes the full name, Individual Taxpayer Registration Number (“CPF”), email address, mobile phone number, educational level, areas of interest, knowledge of languages, city, state, and country of the User.

    Some personal data requested is mandatory for the User to create their account. The User also has the option to provide us with some additional personal data to make it more personalized.

    The personal data we collect depends on whether the User uses a third-party service, such as LinkedIn, Gmail, or Facebook, to register/create an account. If the User uses a third-party service to create an account, we will receive personal data through that third-party service, but only if the User has authorized the third-party service in question to share their personal data with us.

    The registration in the GCT curriculum database allows the User to access, with the same user and password, both the Cia de Talentos curriculum database, and Bettha identified at the beginning of this policy, as well as the ATS Globe platform (www.atsglobe.com). The ATS globe platform is the environment that hosts the GCT curriculum database and, in this condition, has its own Terms of Use as well as its own Privacy Policy, which is similar to this Policy.

    • Personal data collected through the User's use of the platform used by GCT
    Personal Data Group Group description
    Data of people with whom the Holder has worked

    In relation to recruitment and selection processes, personal data (name, telephone, and/or email) of people with whom the Holder has worked is collected for the purpose of obtaining professional references.

    Data on the use of the Platform

    Personal data collected about the User when they are using the platform adopted by GCT, which may include:

    • Information about the User's interactions with the platform, including the date and time of any actions, such as registration updates. It may also include information about the use of third-party applications and advertising received, such as system LOGS;
    • Content inserted in the platform by the User, including the messages they send or receive through the platform, the information provided in registration for selection processes, in addition to their interactions with the GCT Support Team; and
    • Technical data, which may include URL information, cookies data, the User's IP address, the types of devices used by the User to access the Platform, unique device identifications, device attributes, type of network connection (for example, Wi-Fi, 3G, LTE, Bluetooth) and network provider, network and device performance, type of browser, language, information that allows the management of digital rights, operating system and version of the Platform.
    • Anonymized data for various purposes, which include: testing our IT systems, analyzing data, sharing health data, creating marketing and promotion models, improving CIA DE TALENTOS service, and developing new features and functionality on the Platform.
    • Optional personal data, collected only when you choose to provide it, which allows us to provide additional functions or functionality
    Personal Data Group Group description
    Optional data

    In addition to the data we collect to send the User invitations to participate in recruitment and selection processes, research and events related to the career and the labor market, as well as to carry out the development trails in which they participate, the User also has the option of providing us with additional personal data so that we can provide them with features and functionality that will enhance their experience with GCT. We will not collect any of the personal data mentioned below without first obtaining the consent of the User:

    • The User's photographs and videos: we will only collect the images and videos that the User specifically chooses to share with us and the related metadata of those images, such as the type of file and the size of the image and video;
    • The User's photographs and videos: we will only collect the images and videos that the User specifically chooses to share with us and the related metadata of those images, such as the type of file and the size of the image and video;
    • Racial or ethnic origin, and sexual orientation: we will only collect this information when the user specifically chooses to share it with us;
    • Disabled Person: we will only collect this information regarding the User's health if the User specifically chooses to provide it to us;
    • The precise location of the User's device: if the User gives us the authorization to access the precise location, we can provide platform features that require location;
    • If the User gives us an authorization, we can access the voice commands collected through the microphone of the User's device, to allow the User to use, via voice, certain functionalities made available to them, such as virtual interviews.
    • User image and voice data: if the User gives us an authorization, we can collect the image and voice through a specific tool for this purpose, to allow the user to use certain features made available to them, such as conducting online interviews or recorded.
    Prize Draw and Promotions

    Personal data is used to invite the user to participate in these types of prize draws and promotions. The personal data collected varies according to the promotion.

    Marketing data:

    This personal data is used to enable GCT, either by itself or through third parties, to send marketing communications to the User:

    • by email, phone, communication applications such as WhatsApp and Telegram,
    • during the use of the Platform, and/or
    • directly from the third-party contracted by GCT to send marketing communications
    • through events
  5. For what purposes do we use the User's personal data?

    When the User interacts with the platform, we use various technologies to process personal data collected about the User for various reasons. In the table below, we set out the reasons why we process the User's personal data, the associated legal grounds on which we are based and which allow us to legally process the User's personal data, and the groups of personal data used for these purposes:

    Groups of personal data used by GCT for the purpose of processing Description of the reason why GCT processes the User's personal data ('the purpose of processing') Legal grounds for the purpose of the processing
    • Account registration data
    • Platform usage data

    To provide, personalize and improve the User experience on the platform and in the use of the advantages and benefits resulting from their registration in the GCT curriculum database, for example, by providing personalized content, individualized or adapted to their location, recommendations, features, and advertising inside or outside the platform, including for third-party products and services, as long as they are related to career, professional development, and the labor market, therefore meeting the expectations of those who register in the GCT curriculum database.

    • Consent
    • Legitimate interest
    • Account registration data
    • Platform usage data

    To understand how the User accesses and uses the platform that hosts the GCT curriculum database, in order to guarantee the respective technical functionality, develop new tools and utilities and analyze the use of that platform by the User, including their interaction with applications, advertising, research, articles, events, activities, among others, that are made available, to which direction is established, or that are offered through the platform.

    • Consent
    • Legitimate interest
    • Platform usage data

    To keep records of access to the platform so that, in the event of any crime or illegal act on the platform, we can identify the person responsible, in accordance with the provisions of the Brazilian Civil Rights Framework for the Internet.

    • Compliance with legal obligations
    • Account registration data
    • Platform usage data

    For communication with the User for purposes related to the platform.

    • Legitimate interest
    • Data of Prize Draws and Promotions
    • Marketing data

    For communication with the User, made by GCT itself or through third-parties contracted for this purpose (Operators), to:

    • Marketing;
    • articipation in prize draws and promotions.
    • Diffusion of internship opportunities, employment, courses, events, among others.
    • Consent
    • Legitimate interest
    • Optional data

    To provide the User with functionality, information, advertising, or other content based on User-specific data.

    • Specific and minimum consent
  6. Sharing of the User's personal data

    We define the groups of recipients of personal data collected or generated through the use of the platform by the User.

    • Personal data that the User may choose to share

    The following personal data will only be shared with the recipient groups listed in the table below if the User:

    • Explicitly authorizes the sharing of personal data, for example by selecting the appropriate setting on the Platform.
    Recipient Groups Reason for sharing
    Third-party applications associated by the User with the respective Platform account

    By connecting your GCT account to a third-party application, such as social networks, the User will allow their personal registration data in these applications to be imported into the platform used by GCT.

    GCT Partners

    If the User accesses the service of partners such as ATS GLOBE, Vagas, among others, through their platform User account, GCT may share their personal data with such platforms, for the registration in job, trainee and internship opportunities, including the racial or ethnic origin and sexual orientation of the User when authorized by the User and if necessary to participate in inclusion, diversity, or special hiring conditions.

    Companies with opportunities

    If the User applies for employment, trainee and internship opportunities for companies registered on the Platform, GCT may share the racial or ethnic origin and sexual orientation of the User to apply for employment, trainee and internship opportunities for such companies.

    • Information we may share
    Recipient Groups Reason for sharing

    Service providers and others

    We use technical service providers that operate the technical infrastructure we need to perform the various activities related to recruitment and selection processes, especially providers that host, store, manage and maintain the platform, its content, and the data we process, as well as providers that develop games and challenges used in certain phases of selection processes for behavioral assessment. We use technical service providers to help us communicate with the User. We use marketing and advertising partners to show you personalized content or to help us understand your use of the Platform and improve the tools available. We may also share personal data with certain marketing and advertising partners in order to send you promotional communications about GCT.

    CGT Partners

    If the User accesses the service of partners such as ATS GLOBE, Vagas, among others, through their platform User account, GCT may share their personal data with such platforms, for the registration in job, trainee and internship opportunities, including the racial or ethnic origin and sexual orientation of the User when authorized by the User and if necessary to participate in inclusion, diversity, or special hiring conditions.

    Companies with opportunities

    If the User applies for job, trainee, internship, or apprentice opportunities in the selection processes conducted by GCT, we will share with these companies the personal data indicated in the User registration, as well as other data reported during the selection process, such as level of education, areas of interest and knowledge of languages.

    GCT Companies

    There may be the sharing of the User's personal data between the companies that are part of GCT, to carry out our daily activities, improve the User experience, as well as maintain and make the platform available to the User. That is, the data collected through the registration of resumes made through any of the GCT companies will be stored in a single database, accessed by any one of them to meet the purpose for which it was provided: sending invitations to participate in selection processes conducted by any of these companies, of events and research related to the career and the labor market. In other words, the data collected via Bettha for participation in the selection process may be accessed by CT - and vice versa - in order to send an invitation to participate in another selection process of employment conducted by CT (and not by Bettha), to participate in events or research related to career and labor market supported by CT.

    Law enforcement and data protection authorities

    We will share your personal data when we believe, in good faith, that it is necessary to comply with a legal obligation under applicable law or to respond to a valid legal process, such as a search warrant, court order, or summon. We will also share the User's personal data if we believe, in good faith, that it is necessary for our legitimate interest, or that of third parties, in matters of national security, law enforcement, litigation, criminal investigation, protection of the safety of any person, or prevent imminent death or physical damage, provided that we consider that such interest does not prevail over the User's interests or fundamental rights and freedoms that require the protection of the User's personal data.

    Acquirers of our business

    We will share your personal data when we sell or negotiate the sale of our business to a buyer or potential buyer. In this situation, GCT will continue to ensure the confidentiality of the User's personal data, committing itself to inform them of the referred sale and to inform them of the acquiring company and the transfer of their data to it.

  7. Processing of personal data in another country

    Eventually, due to the selection process for which the User has applied, some of their data may be sent for treatment in another country, to countries or international organizations that provide a degree of protection of personal data appropriate to that provided for in the LGPD.

    This can occur in the following situations:

    (a) the job opportunity is located outside Brazil;

    (b) the analysis of the data of the finalists is carried out by the headquarters of the contracting company located outside Brazil; and

    (C) some service providers who develop tests, games, and/or challenges used in certain phases of selection processes for behavioral assessment are located outside Brazil.

  8. Data retention and disposal

    We keep the User's personal data for as long as necessary for the development of the recruitment and selection processes conducted by GCT and/or while the User is interested in participating in development activities, events, prize draws, promotions and/ or other legitimate and essential commercial purposes, such as maintaining the platform's performance, making business decisions about data-based features and offers, fulfilling our legal obligations, and resolving disputes. We retain some of your personal data as long as you remain a User of the platform. For example, we keep all registration data and assessment results in your account.

    At the request of the User, we will delete the personal data processed with the consent of the Holder or anonymize the personal data under the terms of the LGPD so that they do not identify them, unless it is legally permitted or mandatory to keep certain personal data, including situations such as the following:

    • If there is an unresolved issue with your accounts, such as an unresolved complaint or dispute, we will retain the necessary personal data until the issue is resolved;

    • If we are required to maintain personal data for our legal, tax, audit, accounting, and LGPD compliance obligations, we will retain the necessary personal data for the period required by applicable law;

    • When necessary for our legitimate business interests, such as fraud prevention or to maintain the safety of our Users.

  9. Third-party links

    We may display third-party advertisements and other content with links to third-party email addresses. We cannot control or be held responsible for third-party privacy and content practices. If you click on a third-party ad or link, you should be aware that you will leave the platform and that any personal data you provide will not be covered by this Policy. The User should read the respective privacy policies to know how they collect and process their personal data.

  10. Keep User's personal data safe

    We are committed to protecting the personal data of our Users. We implement technical and organizational measures to help protect the security of the User's personal data. However, the User must be aware that no system is completely safe. We implement a number of policies, including anonymization, access, and retention policies to prevent unauthorized access and unnecessary retention of personal data in our systems.

    The password protects the User account, so we encourage the user to use a unique and strong password, limit access to the computer and browser, and terminate the session after using the Platform.

  11. Children and Adolescents

    The platform is intended for users who are 14 years old or older. More details about this matter are available in our Terms and Conditions of Use.

    Legal grounds. All data collected from users between 14 and 18 years old (incomplete) will be treated based on the legal grounds listed in item 5 of this Policy or based on the consent of their legal guardian, where applicable.

    Processed data. The data processed will be those listed in item 4 of this Policy, except health data related to disabilities, tests and other methods of psychological assessment.

    Purpose. The data collected from these Users will be treated solely for the purposes listed in item 5 of this Policy, but will not be used for marketing purposes.

    Sharing. The data of users under the age of 18 years old will be shared in the cases of item 6 of this Policy, except for marketing purposes or communication with partners not crucial for the execution of the services or the provision of features expressly requested by the User.

    If you are the parent or legal guardian of a child or adolescent who has improperly provided personal data to the platform, you can contact us and request the exercise of your applicable rights which are listed in Item 2 of this Policy. The contract shall observe the following:

    if the registration was on the website https://www.bettha.com, open the ticket on this website, in the field 'fale com a gente/talk to us'.

    If the registration was on the website www.ciadetalentos.com.br, open an online service on this website by clicking on 'contato/contact' and then on 'dúvidas/questions'.

    If we become aware that we collect personal data from an adolescent without having identified themselves as such or from a user who does not meet the minimum conditions for using the Platform, we will take reasonable steps to delete the personal data in question, restrict such account and/or notify the legal guardian. To do so, you may need to delete the GCT account for that child or adolescent.

  12. Changes to this Privacy Policy

    If necessary, we may make changes to this policy. When we make material changes to this Policy, we will make a visible and appropriate communication according to the circumstances, for example, by submitting a notification on the Platform or by sending an email to the User. We may also send a notification to the User in advance. Thus, it is critical that the User makes sure to read any notification carefully. If you would like to learn more about this Policy and how the Platform uses the User's personal data, please contact us at the email address lgpd@grupociadetalentos.com.br to find out more.

  13. Talk to GCT

    Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact our Data Protection Officer by email lgpd@grupociadetalentos.com.br or by mail to the following address:

    GRUPO CIA DE TALENTOS

    Avenida das Nações Unidas, No. 12901, CENU Torre Norte, 11º andar, sala 11-133, Brooklin Paulista, São Paulo (SP), Brasil, CEP 04578-000

    GCT is responsible for treating User's personal data processed under this Policy.

    © GRUPO CIA DE TALENTOS.