Privacy Policy for Job Applicants

1. About Us

Apollo Operations Ltda, a company duly incorporated in Brazil under CNPJ 54.923.003/0001-26, domiciled at Rua Venâncio Aires, No. 387, 6th floor, postal code 96810-204, is the controller responsible for the data processing activities conducted with your information and personal data. For the purposes of this policy, whenever we mention “KTO Group,” “KTO.COM,” “KTO,” “we,” “our,” or “us,” we are referring to Apollo Operations Ltda.

2. Scope

2.1 Your privacy is important to us, and we are committed to processing the information and personal data received and requested from job applicants in a secure and standard-compliant manner.

2.2 The purpose of this Policy is to clearly outline how the KTO Group manages and secures the information and personal data collected and processed during our recruitment process. We will clarify the purposes of data collection, specify the data collected, clarify the data processing activities conducted by us, outline the data retention period, and explain how you can exercise your rights.

2.3 This Policy is specifically applicable to job applicants who are participating in recruitment process. THE SCOPE OF THIS POLICY DOES NOT EXTEND, IN ANY WAY, TO THE DATA PROCESSING ACTIVITIES CONDUCTED FOR THE USERS OF THE PLATFORMS PROVIDED BY THE KTO GROUP.

2.4 By accepting this Privacy Policy for Job Applicants, you expressly agree and commit to providing only truthful, accurate, and precise personal data, without altering your identity and/or your data in any way.

2.5 If you do not agree and accept our recruitment process and/or this Privacy Policy for Job Applicants, you will not be able to participate in our job open applications, and we recommend refraining from engaging in any activities related to the recruitment processes conducted by us.

3. Data Collecting

3.1 The information and personal data we collect and process include:

Application materials (such as curriculum vitae – CV, resume, and cover letter).
Identification data (such as full name, national identification number, identification documents, professional registration numbers).
Contact information (such as full name, personal email address, home address, professional address, mobile number, telephone number).
Demographic data (such as date of birth, place of birth, marital status, nationality, gender, location). This data will only be required for contractual and post-contractual purposes once recruitment procedures have been finalized.
Education information (such as academic transcripts, diplomas, degrees, certificates, certifications, letters of attendance from educational sources, majors or areas of study, academic honours or awards, academic achievements and qualifications, educational institutions attended).
Professional information (such as occupation, profession, former employment history, professional registration numbers, previous work and workplaces, practical experience, and any other relevant work experiences).
Background Information (such as employment history, criminal, references and reference checks, professional work-related permits, any other information that aids in assessing job suitability and qualifications, and if necessary for the job position, credit history).
Voice and Image.
Skills (such as general and specific knowledge, languages, and any other competencies applicable).
Position of interest (such as positions, roles, and opportunities of interest, position offered, interview notes, test results, responses to questions, surveys, and/or questionnaires).
Reference information (such as contact data for references and/or former employers, information information regarding your character and work references, and any other applicable reference information).

3.2 We collect information and personal data from job applicants who participate in our recruitment process. This data collection is essential for us and may occur at various stages, including but not limited to when you apply through a LinkedIn add, submit your curriculum vitae (CV), resume and/or cover letter to us, engage in in-person and/or virtual interviews, respond to tests, questions, surveys, and/or questionnaires, and access and/or use our platform in any way.

3.3 When providing us with information related to third parties, such as referees and former employers, you confirm and expressly declare that you have obtained their consent to share the mentioned information and/or personal data. It is your responsibility to ensure that the data shared with us is lawful and in accordance with this Privacy Policy. You will be held responsible for any actions, liabilities, or issues arising from providing information about third parties without their consent.

3.4 We may also collect any other information and personal data that is included in your curriculum vitae (CV), resume, cover letter, and/or any other documents you forward to us, as well as information that is freely available in the public domain, in addition to any other data you may provide

3.5 We also collect information during the access and/or use of our platform. Our servers maintain records of activities, which may include but are not limited to the originating IP address, access time, date of access, visited web pages, selected language, software error reports, and the type of browser used.

3.6 During our recruitment process, we collect and process information and personal data for the following purposes:

To store the information in our systems.
To analyze your curriculum vitae – CV, resume, and/or cover letter.
To contact you for an interview and/or exam.
To contact your references after an interview.
To request evidence of your academic transcripts, diplomas, degrees, certificates, and/or certifications, to analyze your professional skills.
To assess professional skills.
To execute due diligence processes including but not limited to anti-money laundering, counter financing of terrorism and counter financing of proliferation of weapons of mass destruction; integrity, anti-corruption and anti-bribery background checks.
To draft a rendering of services contract (if applicable).
To draft a labour contract (if applicable).
To contact you for new positions different from the one you applied for.
To compile statistical reports on the recruitment processes.
To maintain a historical record of job applicants.
To enhance our recruitment process by sending surveys to job applicants.
To ensure compliance with any applicable legal or regulatory obligations.

3.7 We may conduct reviews, including security reviews, at any time, for any reason whatsoever, to ensure the accuracy of the information forwarded to us. These security reviews may involve background checks, contacting referees, requesting additional documents to verify the information provided to us, and cross-referencing details with third-party databases.

3.8 The collection and processing of all the information and personal data requested and received during our recruitment process is essential to us. This process is conducted lawfully in line with our legitimate interests, compliance with legal or regulatory obligation, for the exercise of rights, and/or with your consent.

3.9 By engaging in our recruitment process, you unequivocally and expressly provide consent for us to collect and process your data. Where applicable, you may withdraw your consent at your discretion. To learn more about your rights and how to exercise them, please consult the “Data Subject Rights” section in this Policy.

4 Data Transfer

4.1 KTO Group implements preventive controls for data transfer, including specific contractual clauses and codes of conduct, as the information and personal data collected during our recruitment process may be stored and processed in any country where we, our affiliates, suppliers, providers, and agents maintain facilities. By participating in our recruitment process, you explicitly consent to the transfer of information outside of your country.

4.2 The international transfer of personal data will occur to countries or international organizations that provide adequate personal data protection. In the event that transfers to non-adequate jurisdictions are necessary, we will take reasonable steps to ensure that the information is treated with the same level of security.

4.3 Please be aware that the National Data Protection Authority from Brazil has yet to publish the regulation regarding international data transfers, including the list of jurisdictions deemed to have an adequate level of data protection, specifying the required level of protection, and identifying the countries and international organizations considered suitable to receive personal data from Brazil.

5. Information Sharing

5.1 We may share information and data, including personal data, with third parties as needed to comply with our internal procedures regarding our recruitment processes and aligned with our legitimate interests, as well to comply with legal or regulatory obligation, to exercise rights, and/or with your consent. This sharing occurs when necessary and serves the following purposes:

With anti-fraud software to help detect and prevent fraudulent activities.
With cloud services for data storage and management.
With competent authorities when required.
To conduct background checks according to due diligence procedures.
To protect the rights and guarantee safety of our company, our customers, and/or third parties.
With your consent for specific instances of data sharing.

5.2 We will ensure that third parties with whom we share such information are committed to maintaining the confidentiality and security of the shared data.

5.3 Please be aware that by engaging in our recruitment process, you unequivocally and expressly provide consent for these actions to be performed.

6. Security Measures

6.1 We take the privacy and security of your personal information seriously, and we are committed to safeguarding the information and personal data shared with us during our recruitment process.

6.2 In addition to other security measures, your personal information is stored in password-protected databases with stringent access controls. Only authorized personnel who require access for legitimate business purposes are granted permission to access this data. We regularly review and update our security measures to stay ahead of emerging threats and maintain the confidentiality and integrity of your information.

6.3 We take the privacy and security of your personal information seriously. Therefore, we ensure that our subsidiaries, agents, affiliates, and suppliers also employ similar robust security measures to protect your data when they are entrusted with it. We have established contractual obligations and data protection standards that all such entities must adhere to, as stipulated in our agreements with them. This is done to maintain consistency in the protection of your personal information, regardless of where or how it is processed within our ecosystem.

6.4 While we do our utmost to protect your personal information, it’s important to remember that no method of data transmission or storage can guarantee 100% security. If you ever have concerns about the security of your personal information, please don’t hesitate to contact us using the contact information provided in this Privacy Policy.

6.5 We are committed to continuously improving and adapting our security measures to meet evolving threats and industry best practices, all in the interest of safeguarding your personal information. By engaging in our recruitment process, you acknowledge and consent to the security measures described in this Policy.

7. Data Subject Rights

7.1 As a data subject, you have rights inherent to your status, and the specific rights can vary from one region to another. If you wish to specify your rights in accordance with your region’s requirements, please contact us via email at [email protected]. Below are some of the rights you can exercise during our recruitment process:

Right to confirm the existence of processing of your personal data.
Right to access your personal data.
Right to rectify incomplete, inaccurate, or outdated data.
Right to anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data.
Right to data portability.
Right to the deletion of personal data processed with consent.
Right to information about data sharing.
Right to information about the possibility of not providing consent and the consequences of refusal.
Right to withdraw consent.
Right to submit a petition regarding the processing of your personal data to the National Authority.
Right to object to the processing carried out.
Right to review automated decisions making.

7.2 You can easily exercise your rights free of charge by contacting us via email at [email protected]. We are committed to promptly addressing your requests within the stipulated timeframes. When necessary, in order to ensure the security of your information, we may request proof of identity to process your request. Please be aware that the timeline for addressing your requests will commence only after your identity has been verified.

7.3 Please be aware that the National Authority from Brazil has not yet issued regulation regarding the right to portability personal data to another service or product provider.

7.4 If you wish to file a complaint, provide feedback, seek clarification, ensure your data protection rights, and/or express any concerns regarding this Privacy Policy, our procedures, and/or any other matter related to personal data processing activities conducted by us, please contact our Data Protection Officer (DPO) at the following email address: [email protected].

8. Data Retention

8.1 The information and personal data processed during our recruitment process are retained for a period of five (5) years to fulfil the purposes outlined in this Policy.

8.2 If deemed necessary, we may retain the information and personal data for a longer period in cases where the storage of personal data for additional time is required to comply with legal and/or regulatory obligations and/or for the exercise of rights

8.3 The five-years period begins after you have received the final response regarding the job position you applied for. Once this period has passed, we will initiate the data deletion process. If deemed necessary, we reserve the right to delete your information and personal data before the five-year deadline.

9. Changes

9.1 We reserve the right to update, amend, or undertake any other action to this Privacy Policy whenever necessary to enhance our internal processes, align with legal trends, and/or ensure compliance with regulations. We strongly encourage you to constantly review this Policy to stay informed.

9.2 Any changes made become effective upon update of this Privacy Policy. The current version and the last update date can be verified at the end of this page.

9.3 Please be aware that if you choose to continue in the recruitment process after any changes have been made, it clearly signifies your explicitly consent and acceptance of the latest updated version of this Privacy Policy. If you do not agree with the changes and prefer to opt out, please contact us via email at [email protected].

10. Contact Us

10.1 We strongly encourage you to read this Policy thoroughly. If, even after reviewing this Privacy Policy, you still have questions, comments and/or complaints about the processing of your personal data during our recruitment process, please do not hesitate to contact us via email at [email protected].

I acknowledge that I have read and fully understand this Privacy Policy for Job Applicants. I hereby give my consent to the collection, use, and disclosure of my personal information in accordance with the terms and conditions specified in the policy.

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