Privacy notice for Applicants to Greenwood residing in Brazil (English)

1. Glossary:

Job Applicant: Individual that applied for a Greenwood’s recruiting process with the purpose of competing for a job position. 

Personal data controller: Individual or legal entity, governed by public or private law, which determines the purposes and means of the processing of personal data.

Personal data: Information that relates to an identified or identifiable natural person, such as, name, an identification number, social security number, email and phone number.

Sensitive personal data: Personal data on racial or ethnic origin, religious belief, public opinion, affiliation to union or religious, philosophical, or political organization, data relating to the health or sex life, genetic or biometric data, whenever related to an individual. When regarding people with disabilities (Pwd) applicants their health statements contain data considered sensitive. 

Personal data processor: Individual or legal entity, governed by public or private law, that processes the personal data on behalf of the controller. 

Personal data processing: Any operation carried out with personal data, such as those that refer to the collection, recording, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, information evaluation or control, modification, communication, transfer, diffusion, or extraction.

2. General Provisions

2.1 When partaking a recruiting process at Greenwood, the applicants declare to be aware of all the provided in this Privacy Notice Statement and further legal polices that are in force on the date of access.

2.2 This Notice will be continuously updated and improved. Therefore, Greenwood claims the right to modify it at any given moment according to the purpose, such as to comply with legislation or standards with the same legal effects.

2.3 The eventual tolerance to any violation of the terms and conditions on this document will be considered and treated as mere freedom and not interpreted as novation, untouchable precedent, waiver of rights, implicit change of contractual terms, vested right or contractual alteration.

2.4 If any provision of this Term is found to be inapplicable or unenforceable, the remaining norms will still have effects, without the need of any judicial measures. The terms herein are to be interpreted by the Brazilian legislation.

2.5 The communication between Greenwood and the applicant should happen through the indicated and available communication channels, mainly through the e-mail address: privacidade@wgimglobal.comOpens Email

2.6 If the applicant is in fact hired, they will be guarded by our Intern Privacy Police, in which more information regarding employee’s personal data is presented.

3. Processing of Personal Data

3.1 When partaking a recruiting process at Greenwood, personal data will be collected on behalf of the company itself.

3.2 Greenwood will collect the personal data of individuals who provide such information on a voluntary basis, for example, when entered by the candidate in the application form, when provided by him during the interview process or at later stages requiring the submission of registration documents and identification to affect the hiring.

3.3 Occasionally, Greenwood might collect applicant’s information on public or third-party sources. Besides, the collection means of this information could be offered by the applicant themself when providing data for social and professional medias.

3.3.1 The personal data that Greenwood could obtain through professional medias (such as Linkedin or Job portal) depends on the privacy configurations set up by the user along with the indicated platform, as well as the professional information the user shares on his profile.

3.4 The data subjects could exercise the foreseen rights on the 7th item of this document “Applicants rights”. 3.5 To the law nº 13.709/2018 (“Lei Geral de Proteção de Dados Pessoais”), Greenwood will act as the controller of the applicant’s personal data.

4. Personal Information usage

4.1 Personal data will be used in a compatible way with the foreseen on this Privacy Notice, only with the hiring purposes, from the moment of application to the effective hiring of a new employee.

4.2 Greenwood will use personal data to:

I. Fulfill and support the recruiting process and the applicant evaluation.
II. Improve the recruiting process standard.
III. Ensure compliance to the corporative governance and other legal requirements.
IV. Ensure a communication with the applicant during the recruiting process or to advise them of future opportunities

4.2.1 Greenwood will process personal data based on the following legal events: compliance with a statutory or regulatory obligation, for the performance of agreements, for the regular exercise of rights and whenever necessary to serve the legitimate interests of the controller. The legal event may vary according to the processing activity. 

4.3 The applicant will be previously informed if Greenwood needs to use their personal data in a different way than the ones advised on this Privacy Notice.

5. Sharing personal information

5.1 Greenwood can share information of its applicants with police or judicial authorities or other parties, either in or out of the country, if needed by applicable legislation, by judicial decision or by authorities’ request, or if necessary, to respond to subpoenas, court orders, legal process, or disputes of any kind.

5.2 In these situations, Greenwood will cooperate with the competent authorities to the extent that, at its discretion, it deems necessary and appropriate in relation to any investigation of illicit acts, infringements of industrial or intellectual property rights, or other activity that is illegal or that may expose Greenwood or others to any legal liability or impose risks on them, except in cases of confidentiality of information contained in the applicable legislation.

6. Personal Data Storage

6.1 The personal data collected by Greenwood will be stored on trustable cloud services.

6.1.1 When hiring these services, Greenwood will seek out companies that employ a high level of security in the storage of its information, establishing contracts that do not violate the privacy definitions foreseen this Privacy Notice.

6.2 Greenwood stores applicant’s information’s only for the time course necessary for the purposes set out in the Terms of Use and this Privacy Notice, always respecting the data retention period determined by the applicable legislation. Occasionally, if the candidate is unsuccessful in the recruiting process, we might store their information for a reasonable period so that it is possible to contact them if new opportunities arise.

6.2.1 If the applicant requests the elimination of their personal information provided, their data will be anonymized or permanently deleted, unless this information is necessary to comply with a statutory or regulatory obligation by Greenwood, for the regular exercise of rights and whenever necessary to serve the legitimate interests of the controller.

6.3 Greenwood devote its best efforts to respect and protect users' personal information from loss, theft, or any form of misuse, as well as against unauthorized access, disclosure, alteration, and destruction.

6.3.1 Greenwood will carry out the processing of personal data with a high degree of security, implementing the best practices in use in the industry for data protection. However, it is not possible to completely guarantee the non-occurrence of interceptions and breaches of systems and databases since the internet has its security structure in permanent improvement. 6.3.2 In the event of an information security incident that results in the destruction, loss, alteration, unauthorized access, or leakage of personal data, Greenwood will immediately assess the risks to the personal data subject’s civil liberties and the fundamental rights. The communication data subjects or to the National Data Protection Authority will be carried out according to the specific case, after assessing the risks mentioned.

7. Applicant's right

7.1 Applicants will be able to exercise their rights as holders, as provided for in Article 18 of the LGPD, in an easy and accessible way, through our email privacidade@wgimglobal.comOpens Email: (i) confirm the existence of personal data processing; (ii) access to personal data; (iii) correction of incomplete, inaccurate, or outdated data; (iv) anonymizing, blocking or deleting unnecessary or excessive data; (v) data portability, within the legal limits.

January 2022