Candidate Privacy Policy EU

User Definitions

a) 99Hunters: private law company, registered with CNPJ nº 26.324.804/0001-34, headquartered at Rua Fernão Dias, n. 106, Conjunto. 02, Zipcode 05.427-000, Pinheiros, São Paulo, Brazil, offers a marketplace platform for recruitment, connecting companies looking for candidates to a network of headhunters and executive search consultancies.

b) Hunters: Professionals in the area of recruitment and selection previously selected by 99Hunters, commonly referred to as “HeadHunter” (or recruiter), which may be an individual or legal entity, who will use the Platform to access the Vacancies opened by the Contracting Parties and work in the search for qualified professionals who can fill them. Collectively, the Hunters will be called “Hunter Network” here.

c) Company or Contractor: Legal entity looking for qualified professionals to fill the job opportunity available in its staff, which, by hiring 99Hunters, will use the Platform to publish the Vacancy to be worked on by the Hunters Network.

d) Candidate: Professional in the job market, employed or not, who may be nominated by Hunters to compete to fill the Vacancy.

e) Marketplace: Business models in which a tool curates and connects two different parties with common business interests. In the present case, 99Hunters, through its Platform, promotes the connection of Contractors, who make their Vacancies available, with the Hunters Network, responsible for the presentation of Candidates.

Purpose

This privacy policy applies to all candidates registered on the 99HUNTERS platform. The Candidate is informed that their personal data will be processed by 99HUNTERS, which will manage the process of recruiting vacancies opened by the contracting companies, using autonomous recruiters ‘Hunters’ registered on the platform.

Thus, the Data Controller is 99HUNTERS. The company has designated a Data Protection Officer who can be contacted at the following email address: data@99hunters.com

Candidate personal data is identifiable information that a headhunter registered with 99HUNTERS makes available to 99HUNTERS within the scope of the recruitment process for a specific vacancy opened by a contracting company. 99HUNTERS may collect Candidate Data directly from a job seeker or from third parties, for example through LinkedIn. Candidate Data may include a variety of information, such as name, contact information, past employment information, education, Headhunter notes on the candidate, and the candidate's resume.

Purposes	Legal Base
Manage the recruitment process; manage your application; carry out assessments; organize and schedule interviews; analyze the feedback resulting from the interviews; analyze the hiring process and the result;	Legitimate interest
Provide the Candidate with future positions or vacancies that match their profile.	Consent
Disclose promotional and advertising information and contacts	Consent
Exercise or defense of a right in a judicial process or in an administrative or extrajudicial procedure; and	Legitimate interest
Compliance with applicable national/European laws and/or responding to requests from public and governmental authorities.	Legal obligation

The processing of data within the scope of the data subject's consent may be withdrawn at any time by the candidate. The activity of data processing within the scope of the Legitimate Interest is not mandatory and the Candidate may object to the processing of data at any time through the modalities provided for in item 8 of this Privacy Notice. In this case, 99HUNTERS will not carry out any processing of personal data, unless 99HUNTERS demonstrates the existence of compelling legitimate grounds for the processing or for the declaration, exercise or defense of a right in a legal proceeding.

The basis of legitimacy for the processing of personal data identified in point e) lies in the need for the Data Controller to comply with the applicable regulations, which makes the processing mandatory.

a) Headhunters and Contracting Companies: 99HUNTERS acts as an intermediary between the company seeking the candidate and the headhunter registered on the platform. For the correct provision of such services, these third parties process the Candidate's personal data on their own, thus, they become responsible for the processing of this data and acquire the legal obligations of controllers. Therefore, it is not allowed to use the data for a purpose other than or incompatible with the one that originated the collection. The data of candidates approved for the short list will be shared with the contracting company for evaluation, interview and subsequent hiring of the candidate by the contracting company.

b) Service providers such as: (a) computer system providers, cloud service providers, database providers and technology service providers in general. These Service Providers access only the information strictly necessary for the provision of the agreed services and cannot use them for other purposes that have not been entrusted to them by 99HUNTERS.

c) '99HUNTERS Group': companies belonging to our economic group, which operate under our same internal processes and policies, to comply with our internal policies, prevent fraud, manage risks and facilitate the management of 99hunters services.

d) 99HUNTERS may be required to disclose the Personal Data of certain Candidates to public authorities to (a) collaborate in the investigation and report fraud or any other illegal act, as well as any activity or circumstance that may generate legal liability for 99HUNTERS; (b) safeguard a public interest, the application or administration of justice, the recognition, exercise or defense of a right in a judicial or administrative proceeding and/or the resolution of disputes; and (c) comply with any applicable law, regulation or legal provision, or any duly substantiated and motivated mandate from a competent authority.

e) In addition, in the event of a reorganization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any part of 99HUNTERS' business, 99HUNTERS may transfer Candidate Data to successor entities or parties.

Within the scope of data transfers, 99HUNTERS has defined appropriate and adequate measures to protect the Candidate's personal data. Consequently, personal data are transferred in accordance with the requirements and obligations provided for by applicable data protection laws, such as standard contractual clauses adopted by the European Commission pursuant to Articles 45, 46 and/or 49 .º of the RGPD and article 33 of the LGPD.

What is The Period for Reservation of The Candidate's Personal Data?

The Candidate's personal data is stored for the period necessary to fulfill the purposes for which it was collected, as defined in this Privacy Notice. In any case, the following retention periods will apply to the processing of the Candidate's personal data for the purposes indicated below:

a) The Candidate's personal data will be kept until the end of the recruitment and selection process, but always for a limited period of time specific to the country where the job vacancy will be filled (i) to comply with legal record keeping requirements, and (ii) for eventual use in legal proceedings. 99HUNTERS will keep personal data for a maximum period of 03 months to avoid unreasonable duplication of recruitment efforts, except when data retention is necessary to respond or to initiate legal action, at the request of the competent authorities or in accordance with the applicable legislation.

b) If the candidate has given their consent, the Candidate's personal data will be kept after the end of the recruitment and selection process to make available to the Candidate future positions or vacancies that match their profile.

a) obtain confirmation of the existence of personal data from 99HUNTERS and be informed of its content and source;

b) verify its accuracy and request its update or change;

c) request the erasure, anonymization or restriction of the processing of personal data processed in violation of applicable legislation;

d) withdraw consent for the processing of data (if and to the extent that such consent is applicable), without prejudice to the legality of the previous processing;

e) request 99HUNTERS to limit the processing of the Candidate's personal data when:

the Candidate contests the accuracy of the personal data until 99HUNTERS has taken sufficient steps to correct or verify its accuracy;
the processing is illegal, but the Candidate does not want 99HUNTERS to erase their personal data;
99HUNTERS no longer needs the Candidate's personal data for the purposes previously determined, but the Candidate requests them for the declaration, exercise or defense of a right in a judicial process; or
The Candidate has exercised the right of opposition in relation to the processing of personal data based on legitimate interest, pending verification of whether 99HUNTERS has compelling legitimate grounds to continue the processing;

f) oppose the processing of personal data in the event that the processing is based on legitimate interest, unless 99HUNTERS demonstrates the existence of compelling legitimate grounds for the processing or for the declaration, exercise, or defense of a right in a judicial proceeding;

g) receive the personal data concerning you and which you have provided, in a structured, commonly used, and machine-readable format, and transmit this data to another controller without the controller to whom the personal data were provided (99HUNTERS) may prevent it, if: (i) processing is based on consent and (ii) processing is carried out by automated means.

In addition, the Data Subject may file a complaint with the relevant Data Protection Control Authority if it considers that its rights have been violated.

The information provided by the user is stored in highly secure media. We guarantee to take all possible measures to maintain the absolute confidentiality of our customers' personal data.

When registering, the candidate will inform the password, which will be stored securely by 99HUNTERS, however, it is up to the candidate to ensure the control and confidentiality of this information. If the user's password is compromised in any way, this fact must be communicated to 99HUNTERS, so that the password is immediately changed, and so that the last transactions carried out on the account are checked and analyzed, and the user must contact us through communication channels.

99HUNTERS considers the security of your information very important and therefore follows best practices to keep it safe. However, while 99HUNTERS takes all appropriate technical measures to protect your information and requests, we do not assume any responsibility if they are intercepted or incorrectly accessed by unauthorized third parties.

Privacy Policy and Data Protection for Candidates.

User Definitions

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Purpose

Changes To Our Privacy Policy

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