• “Personal Data”: information related to an identified or identifiable natural person;

• “Sensitive Personal Data”: personal data on racial or ethnic origin, religious belief, political opinion, union membership or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person;

• “Data Subject”: natural person to whom the personal data that are being processed refer to;

• “Treatment”: any operation performed with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, diffusion or extraction;

• “Controller”: natural or legal person, under public or private law, who is responsible for decisions regarding the treatment of personal data;
• “Operator”: natural or legal person, under public or private law, who treats personal data on behalf of the controller;

• “In charge”: person appointed by the controller and operator to act as a communication channel between the controller, the data subjects and the National Data Protection Authority (ANPD).
• User: visitor who accesses or interacts with the activities offered by the SPIC Brasil website, including through forms available on the platform.

SPIC Brasil is the Controller of the personal data it collects through its website. This means that SPIC Brazil is responsible for making decisions about how personal data will be handled, as per the terms set out below.

We collect and treat the following personal data:

• General personal data: name, title, email, telephone, address.
• Professional data: resume, education, reference letter, biographies, diplomas and other certificates.

Your personal data may be collected by SPIC Brasil by the following means:

• Personal data provided by the user: by filling in forms on the SPIC Brazil website.
• Personal data provided by third parties: in specific cases, some personal data may be received through third parties. For example, referrals from outplacement companies or headhunters; list of professionals from a supplier who will work in a project at SPIC Brasil locations.
• Data collected automatically: SPIC Brasil uses cookies on its website. For further details, we recommend reading SPIC Brazil’s Cookies Policy
• Publicly available data: we may be able to collect publicly available information, including, but not limited to, social media (such as LinkedIn). We also consulted some external databases, such as Serasa. We recommend that you familiarize yourself with the privacy practices and terms of use of these social media and public websites or databases, as they are not under the management of SPIC Brazil.

The personal data collected will be used for the following purposes:

• General personal data: to identify and confirm your identity for the purpose of providing services; to compose a database of collaborators, associates, partners, suppliers and alike; for any other contacts, including ethics channel;
• Professional data: for the creation of a database of candidates for job vacancies, internships and service provision at SPIC Brasil;

To achieve the purposes listed, SPIC Brasil may share personal data with the following third parties:

• Consulting companies and professionals, auditing, communication, financial institutions to enable activities necessary for the operations of SPIC Brasil.
• Providers of software and technologies necessary for the management and security of SPIC Brasil.
• Regulatory bodies or public authorities, such as the National Authority for the Protection of Personal Data, Brazilian Institute for the Environment and Renewable Natural Resources, for the fulfillment of legal or regulatory obligations or judicial or extrajudicial orders.

According to Brazilian law, the legal bases we use for the treatment of your personal data are:

(a) Your consent. You have the right to revoke it at any time. You can do this via email: privacidade@spicbrasil.com.br.

(b) Compliance with legal or regulatory obligations;

(c) For contract execution;

(d) For the regular exercise of rights in judicial, administrative or arbitration proceedings;

(e) In our legitimate interest;

(f) For credit protection;

(g) To guarantee fraud prevention and your security, in the identification and authentication processes of registration in electronic systems.

Your personal data is stored securely, respecting the information security guidelines.

We retain your personal data as long as there is a need for treatment to perform our services, as well as to comply with legal or regulatory requirements. Upon completion of the treatment, your personal data will be securely discarded.

SPIC Brasil may transfer your personal data outside of Brazil to companies of the same economic group located abroad. When the international transfer is necessary, SPIC Brasil will adopt the appropriate technical security measures to guarantee the protection of your transferred personal data, in accordance with the applicable Data Protection Law. In addition, the transfer will be carried out through contractual safeguards in order to demand the same level of protection from third parties who receive the data outside the country.

Throughout the treatment of your personal data, technical and administrative measures are used to keep them safe and prevent any unauthorized access, accidental or unlawful situations of destruction, loss, alteration, communication or any form of inappropriate or unlawful treatment.

According to LGPD, you have the following rights to your personal data:

• Confirmation of the existence of treatment – each and every data subject, without justification, has the right to confirm the existence of treatment of their personal data.

• Access to data – the data subject has the right to access the data and obtain information about it.

• Correção de dados incompletos, inexatos ou desatualizados – the data subject has the right to keep his data up to date and correctly.

• Anonymization, blocking or deleting – the data subject has rights to request these actions when there is unnecessary, excessive or treated data in violation of the LGPD.

• Personal data portability – rights to obtain your personal data in a structured way in order to be transmitted to another service or product provider (another data controller).

• Deleting – right to delete personal data treated on the basis of consent, except when there is a legal or regulatory obligation that allows the treatment, transfer to a third party or the data is anonymized for the exclusive use of the controller.

• Sharing information – right to know with which public and private entities your personal data sharing was carried out.

• Not providing consent – the data subject is guaranteed the right not to provide the requested consent and to be informed of any consequences of not providing.

• Revocation of consent – the data subject is assured to revoke the consent provided at any time.

You must be served within a reasonable time stipulated in the LGPD and other regulations. Please be advised that to comply with the right of access and/or confirmation of treatment of personal data, the period is 15 (fifteen) days.

Your rights can be exercised via email: privacidade@spicbrasil.com.br.

If you have any questions about the use and treatment of personal data carried out by us, you can make a request to our Data Officer via the email below:

privacidade@spicbrasil.com.br

SPIC Brasil is committed to keeping up to date with new regulations and new activities incorporated into the provision of services. Therefore, we may update this Policy from time to time. To access the new version, just periodically visit our page and access the link in order to stay informed of any updates.