Through this Personal Data Privacy Policy (the “Policy”), ANK REPUTATION CONSULTORIA EMPRESARIAL LTDA, legal entity governed by private law, registered with the CNPJ under No. 22.812.464/0001-35, headquartered at Av. Hungary, 620, 14th floor, Bairro Jardim Europa, São Paulo/SP, CEP 01455-000, hereinafter referred to as “ANK”, “we”, “our” or “our”, inform and give science interested parties to submit applications for open positions at ANK and/or interested parties to receive the newsletters and ANK's announcements (the “Interested”, “You”, “your” or “yours”) about ANK's practices regarding the collection, storage, sharing and other operations of personal data (the “Processing” or “Processing ”) obtained when the Interested Party submits their CV and/or expressly expresses their interest in receiving the newsletters of the ANK, through the website, social networks and service channels from ANK.
ANK Processes personal data owned by the Interested Parties and determines all its actions based on a premise of respect and attention to the privacy and security of such personal data. To put you in control, we recommend that you read this Privacy Policy carefully, as it will apply during all processing of personal data carried out by ANK.
1. What is Our Privacy Policy?
1.1. The Personal Data Privacy Policy is a guide for you to know our personal data processing guidelines, through: (i) information on the activities carried out; (ii) description of the assumptions of processing of personal data; (iii) information about your rights regarding the activities carried out; It is (iv) provision of a channel for exclusive service of requests from data subjects.
2. What personal data do we process?
2.1. In general terms, ANK will process personal data considering, for example, the following categories:
| DATA CATEGORIES | DATA EXAMPLES |
| Identification data | Name, CPF, RG, photograph, affiliation, date and place of birth. |
| Contact Details | Address, personal email and personal telephone. |
| Professional and School History Data | Information about academic or professional career, job titles, salary, work history, schools attended, employee files, employment history, evaluations, references, interviews, disciplinary actions, etc. |
| Communications Data | emails/electronic communications to or from an individual. |
2.2. We use your personal data in constant compliance with the legal bases that authorize the use and the purpose for which it is intended, in proportion to the Personal Data Processing activities that we will perform.
2.3. We understand that sensitive personal data that may be processed by ANK is any personal data about racial or ethnic origin, religious conviction, political opinion, union membership or organization of a religious, philosophical or political nature, referring to health or life sexual, genetic or biometric data.
2.4. We clarify that the submission of any free forms or resumes, for example, should contain only the data necessary for the identification and purpose for which they are intended..
2.4.1. We request that unnecessary information is not forwarded to the evaluation of the fulfillment of the prerequisites, emphasizing that You are responsible for your personal data, and it is up to you to send updated, complete and truthful information and that observe the purpose of the Treatment.
2.4.2. We inform you that we do not require the collection of sensitive personal data, except when necessary to comply with legal, regulatory and/or contractual obligations, upon prior request and clarification on the purpose of the Treatment.
2.4.3. We declare that no personal data is used or collected for discriminatory purposes, and, in the event that they are processed, it is intended to aggregate and promote greater diversity and multiculturalism.
3. Why Do We Collect Your Personal Data?
3.1. Application: If you are interested in participating in the selection process, your personal data will be collected for the submission of your application for the vacancy, and, if you are selected, for your registration in our systems, being supported by the legal bases provided for in Law 13.709/2018 (the “LGPD”), in particular to carry out preliminary procedures for the contract and compliance with contractual, regulatory and legal obligations.
3.2. Newsletter: If you are interested in receiving our news and news, we collect your personal data to operate, provide, improve, customize, understand, offer services, advertise products and services, as well as perform contractual obligations.
3.3. That said, here is an indicative table of the purpose and legal basis of Treatment that we use to collect the personal data indicated below:
| Who can have the data collected | PERSONAL DATA | PURPOSES | LEGAL BASIS OF PROCESSING |
| Candidate Users | Identification data Contact Details | Contact the company through the Service Channels. | Legitimate Interest; and contract fulfillment |
| Users | Identification data Contact Details | Use to carry out marketing actions. | legitimate interest |
| Candidates | Identification Contact Professional and School History | Screening CVs to identify potential Candidates. | Preliminary contract procedures; Legitimate interest. |
| Candidates | Identification Contact Communications Professional and School History | Screening CVs to identify potential Candidates. | To serve the legitimate interests of the organization. |
| Candidates | Personal identification Contact information Professional and School History Communications | Selection tests and interviews to assess technical skills and candidate profiling | To serve the legitimate interests of the organization. |
3.4. We do not use any of the personal data collected for discriminatory purposes, but to add the greatest possible diversity and multiculturalism to ANK.
3.5. Other new activities that require the processing of personal data by ANK that may not be mentioned above will be duly included in this Policy and informed to the holders of personal data.
4. How Do We Collect Your Personal Data?
4.1. ANK may collect personal data in the following ways:
4.1.1. Data provided by You. Data that You voluntarily submit to us to contact us, via email, telephone, applications, electronic forms, Web site, to access and use ANK services, as well as request guidance and various supports. If you do not provide this data, you will not be able to use ANK services..
4.1.2. Data we collect automatically. Data we collect through use of the Web site, through the integration of technology applications, Cookies, which includes how You use our websites, diagnostic files, faults, performance logs, connection and device data, operating system information, location data, data extracted from Cookies mandatory and/or optional.
4.1.3. Third party data. We work with third-party service providers who help operate, execute, enhance and customize our services, such as technology application integrations and electronic forms.
5. Who do we share your personal data with?
5.1. ANK shares your personal data in cases of strict necessity to:
(i) help operate, provide, improve, understand, customize, support and advertise your Services;
(ii) to carry out the selection and recruitment processes, as well as to formalize and continue the contractual relationship with the selected Interested Party.
5.1.1. The 3rd. Suppliers, service providers and/or commercial partners, when necessary for personnel management, records of activities performed, administration of our business and achievement of commercial objectives. In these cases, these specialized service providers will submit to the adoption of a contract that ensures secrecy and confidentiality, as well as the proper treatment of data;
5.1.2. Government agencies. To comply with legal and regulatory obligations, fiscal entities, unions, or even upon court order or request from the Public Ministry, police or administrative authority.
5.2. ANK does not sell, rent or trade any personal data to third parties.
6. What are the Rights of the Holders of Personal Data?
6.1. Interested parties, holders of personal data, are entitled to exercise, at any time:
6.1.1. Right of non-treatment. You may choose not to disclose your personal data to ANK, except for the data that will be necessary to enable access to ANK services, and full use of its resources, as well as, if applicable, for the completion of your application to the selection process and evaluation regarding the fulfillment of the described requirements necessary to fill the open opportunity.
6.1.2. Right to information about Data Processing. You can have easy access to information about the Treatments that we carry out on your data upon prior request, information about the use and operation that we carry out with your data, whether internally, with other companies or government agencies and ask for explanations and guidance on the possibility of not to provide consent and the consequences of that decision.
6.1.3. Right of access to data and confirmation of the existence of Treatment. You can question the existence or not of the Processing of your data, as well as request a copy of the personal data that we hold about You.
6.1.4. Right to correct incomplete, inaccurate or outdated data. You can request the correction or amendment of your personal data if you identify that some of them are incorrect, incomplete or out of date. However, for this correction to be effective, we will have to check the validity of the data you provide us.
6.1.5. Right to anonymize, block or delete data. You can request the deletion, blocking or anonymization of your personal data from our database when they are unnecessary, excessive, treated in disagreement with the provisions of the legislation on the protection of personal data or, even, when they were collected based on your consent. Upon receipt of your request, we will analyze its origin and clean up your personal data from our servers if the need or relevance of the Treatment is not identified to achieve the intended purpose, including, but not limited to, continuity of contracts, provision of services , access to websites, as well as interaction through social networks, another purpose or legal hypothesis that justifies the Treatment or a relevant reason for maintaining it, such as a possible legal or regulatory obligation to retain data or the need to preserve them to safeguard rights and activity of legitimate interest of the ANK.
6.1.6. Right to object to data processing. When we are processing your data without your consent or when you understand that this impacts your fundamental rights and freedoms, you can contest the way and reason why we carry out the Processing of your personal data. This does not mean that ANK should accept your opposition, if there is a relevant reason for maintaining it, such as a possible legal or regulatory obligation to retain data or the need to preserve it to safeguard rights and activities of legitimate interest to ANK.
6.1.7. Right to data portability. You may request that we provide your personal data to You or third parties of your choice. This means that we must provide your personal data as requested, but we do not guarantee that the shared format is compatible with the destination.
6.1.8. Right to revoke consent. You have the right to revoke your consent, however this will not affect the legality of any Processing carried out with your data before you revoke it. If you withdraw your consent, interactions may no longer be carried out and/or certain products and services can no longer be provided.
6.2. We reserve the right to request your Identification, Authentication and Contact Data to guarantee the exercise of your rights regarding personal data owned by you or people that you, legitimately and proven, represent.
6.3. ANK may contact you to obtain further information about your request through ANK's service channels.
6.4. ANK uses its best efforts to respond to all legitimate requests within a reasonable time.
7. How Do We Store Your Personal Data?
7.1. ANK uses the best governance, technical, organizational and security practices designed to protect your personal data on our servers, in the cloud contracted with a third party and in physical and digital workstations.
7.2. Information security also depends on the security of your computer, device or network that you use to communicate with ANK, as well as the level of security that you use to protect your personal data (eg: user login and password), it being your responsibility to certify the appropriate and necessary management to protect this information.
8. How Long Is Your Personal Data Stored?
8.1. We will only keep your personal data for as long as necessary to fulfill the purposes described in this Policy.
8.2. If you request the deletion of your data and/or your registration in our systems, we will delete your data, unless its maintenance is necessary to comply with the purposes for which the data were collected, legal, contractual obligations, accountability or request from competent authorities.
9. Talk to ANK!
9.1. If you want to talk to ANK about any type of occurrence and/or requests for guidance and/or curiosities and/or suggestions and/or comments and/or criticisms about the processing of personal data that we carry out, you can contact the our Supervisor at the following address:
9.2. We want to hear from you!
10. Policy Changes
10.1. This Privacy Policy may be revised, and will be republished whenever necessary to publicize its updates.
10.2. If relevant changes are made, therefore considered those that require a new consent from you, we will ask you again.