Privacy Policy Labora
PÓLEN IMPACTO SOCIAL S.A., a corporation based at Alameda Vicente Pinzon, No. 54, Conjunto 91, Vila Olímpia, in the city of São Paulo, State of São Paulo, ZIP Code 04547-130, registered with CNPJ/ME under No. 32.146.867/0001-46 (“Labora” or “we”), the sole and exclusive owner of the rights related to the Laboratech Platform (“Platform”), presents this Privacy Policy. This Privacy Policy aims to provide Users (“Users” or “you”) with a transparent view of our practices regarding the collection, storage, and use of your personal data.
The terms in this Privacy Policy, whenever capitalized, will have the meaning established in this Privacy Policy, in the Terms of Use, or in Law 13.709/2018 (“LGPD”). However, if you still have any questions, we suggest you contact us at [email protected].
1. INTRODUCTION
We offer a platform to promote the inclusion of diversity in the job market by providing courses and facilitating hiring through partners registered on the Platform.
This Privacy Policy aims to inform you about how we collect and process your Personal Data.
Here you will find a brief summary of this Policy, but we recommend that you read the full document:
Data
collected
User data entered in the Platform for registration; Access data; Data processed during Professional Monitoring; Data related to Courses; Data provided by Users for application to Opportunities.
Purposes of
Processing
Registration on the email list, Suggestion of personalized job opportunities; Sharing with Partners for the selection of candidates qualified to provide Services; Skills mapping; Professional monitoring; Communications and alerts from Labora; Improvement and protection of the Platform.
Processing
Agents
PÓLEN IMPACTO SOCIAL S.A. – Data Controller
Alameda Vicente Pinzon, No. 54, Suite 91 – Vila Olímpia, São Paulo – SP, ZIP Code 04547-130
Legal Bases for
Processing
(I) Consent;
(II) Execution of contract;
(III) Legitimate interest;
(IV) Compliance with legal obligation;
(V) Regular exercise of rights.
Rights of the
Data Subject
Confirmation of Processing; Access to Personal Data; Correction of incomplete, inaccurate, or outdated data; Deletion of Personal Data; Anonymization, blocking, or elimination of data; Portability; Information about the possibility of not consenting; Opposition to Data Processing; Revocation of consent; e Review of decisions made solely based on automated data processing.
Security
Appropriate technical and administrative measures, considering the nature of the processing and the sensitivity of the data.
Contact and
information
PÓLEN IMPACTO SOCIAL S.A.
E-mail: [[email protected]]
By registering with Labora, you declare that you are aware of all the provisions of this Privacy Policy. Therefore, we suggest that you read this document carefully, as well as any updates, before deciding to use or continue using the Platform. If you do not agree with any provision of this Policy, you should not use our Platform.
2. DEFINITIONS
2.1 In this Privacy Policy, the capitalized terms will be defined as described below:
I.
Dados Pessoais: significa, em conjunto, todos os seus dados pessoais, sejam eles dados sensíveis ou não, incluindo, mas sem limitação, o nome completo, e-mail, telefone, autodeclaração de raça, autodeclaração de gênero, identificação como pessoa LGBTIQ+, informação se possui deficiência, entre outros relacionados;
II.
Data Protection Officer: means the person responsible for acting as a communication channel between Labora and you;
III.
Partners: means companies registered with Labora that advertise job vacancies and service opportunities through the Platform.
IV.
Plataforma: significa o nosso software de propriedade exclusiva, que oferece a você Ferramentas como Cursos, Oportunidades e Acompanhamento Profissional;
3. WHAT DATA DOES LABORA COLLECT?
Data Group
How they are collected
What data is collected and processed
User data entered on the Platform for registration
Provided by Users who wish to register on the Platform.
First Name;
Last Name;
Email;
Phone;
Month of Birth;
Year of Birth;
Race;
Gender;
Sexual Orientation;
Information if Transgender;
Information if Disabled.
Access Data
Automatic collection of all Users accessing the Platform.
Data processed during Professional Monitoring
Provided by Users for enrollment in Courses, as well as provided by third parties, Course providers.
Data related to the Courses
Provided by Users, using the Labora App.
Data provided by Users for application to Opportunities
Provided by the User for application to Opportunities.
Periodically, Labora may request that you complete and/or update your data, and you will always have the option to provide it or not.
4. HOW DOES LABORA USE PERSONAL DATA?
4.1
We will use the Personal Data described in the above section for the following purposes and in accordance with the applicable legal basis:
Data group
How they are collected
Registration on email list
Labora may use your contact information, including email and phone number, to communicate through notifications, alerts, and other notices related to Labora for the use of the Platform.
Customized job opportunity suggestions
We may use your data, including sensitive data (such as your diversity characteristics, such as sexual orientation, transgender self-identification, and whether you are a person with a disability), to direct Opportunities on the Platform.
Sharing with Partners for the selection of candidates qualified to provide Services
At the same time that we offer you Opportunities based on your characteristics and diversity, we will share your Skills and profile data with Partners so they can assess whether you fit the offered Opportunity.
Attention: You are aware and agree that whenever you choose to apply for an Opportunity, we will share your Personal Data with Partners, and we may even share sensitive Personal Data, such as your sexual orientation and race.
Mapping of Skills
Upon completion of Courses and the Services you provide to Partners, Labora will use your Personal Data to create a map of your Skills.
Your Skills may be shared with Partners whenever you apply for an Opportunity.
Additionally, a summary of your Skills may be accessed by third parties, Labora Users, through access to your profile on Labora.
Professional Monitoring
You will be able to input data into the Platform by providing information about the service provided. Labora may consolidate this information and share it with Partners so that they can better understand the impact of your services.
Communications and alerts from Labora
Labora may use your contact information, including email and phone number, to send emails and communications, alerts, notifications, and other notices related to Labora for the use of the Platform.
Improvement and protection of the Platform
Labora may use Personal Data, including IP data, to detect possible fraud and security incidents on the Platform.
Additionally, Labora may use browsing data to enhance your experience on our platform, as well as use access logs to detect errors in our systems.
4.1
We will process your Personal Data based on the following legal grounds: (I) consent; (II) when necessary to execute a contract to which you are a party; (III) based on our legitimate interests; (IV) to comply with legal or regulatory obligations; and (V) to exercise our rights.
5. HOW WE STORE THE COLLECTED INFORMATION.
5.1
We know that your data is extremely important to you and, consequently, to us as well. Therefore, Labora is committed to doing everything possible to keep your Personal Data safe, including adopting security and protection measures compatible with the nature of the collected, used, and stored data, as well as appropriate market practices. However, Labora cannot guarantee that such security measures are error-free or not subject to interference by third parties (hackers, among others). By its nature, despite Labora’s best efforts, any security measure may fail and any data may become public. BY USING THE PLATFORM, YOU UNDERSTAND AND EXPRESSLY ASSUME THIS RISK AND AGREE THAT LABORA WILL NOT BE LIABLE FOR SUCH DATA LEAKS.
5.2
All collected information will be stored with a high standard of security on third-party servers located abroad.
5.3
By using the Platform, you are aware and agree that we may hire Subprocessors, whether national or foreign, who may also process your Personal Data. These national or foreign Subprocessors will be contractually bound to the same security and confidentiality requirements applicable to Labora.
6. RIGHTS OF THE DATA SUBJECTS.
6.1
Labora provides tools for Data Subjects to exercise their legal rights regarding Personal Data, as set forth in Article 13 of the LGPD. In this section, we will describe these rights and how you can exercise them.
6.1.1 Confirmation of Processing. You can request that we confirm whether Labora processes your Personal Data.
6.1.2 Access to Personal Data. You can access your Personal Data, including requesting a copy of the data processed by us.
6.1.3 Correction of incomplete, inaccurate, or outdated data. You can request the amendment or correction of your Personal Data that is incorrect in our database.
6.1.4 Deletion of Personal Data. You can request the deletion of your Personal Data processed by Labora when it has been collected and processed based on your consent, either through the Platform itself or by request through the contact channels indicated in this Policy.
6.1.5 Information about sharing. You can request information about which public and private entities we share your Personal Data with, under the terms of this Policy.
6.1.6 Anonymization, blocking, or deletion of data. You can request that Labora anonymizes, blocks, or deletes Personal Data that is excessive.
6.1.7 Portability. You can request that your Personal Data be sent to another service provider.
6.1.8 Information about the possibility of not consenting. You receive, through this Policy, and can request, through the contact channels, information about the possibility of not consenting to the Processing of Personal Data and its potential consequences, including the inability to provide our services.
6.1.9 Opposition to Data Processing. You can oppose the processing of Personal Data based on a legal basis other than consent.
6.1.10 Revocation of consent. You can revoke your consent for Processing that is based on legal consent.
6.1.11 Review of decisions made solely based on automated data processing. If Labora makes any decision based solely on automated Personal Data processing, you can request that these decisions be reviewed.
6.2
Exercise of rights. The rights mentioned above and others provided for in applicable legislation can be exercised by you, regarding your Personal Data, directly through the Platform, according to the functionalities available there (such as access and editing tools for Personal Data), or by sending a request to the channel [[email protected]].
6.3
Information on data deletion. It is important to emphasize that we may, due to legal or administrative obligations, be unable to proceed with the deletion of certain types of Personal Data. In such cases, when applicable, we will inform you of this impossibility, proceeding to delete the other information that can be erased. Notwithstanding, while fulfilling any deletion requests, which will be communicated to you when possible, we may be unable to provide our services, in whole or in part. Furthermore, after the deletion of Personal Data, we may continue to use it in a non-individualized and anonymized manner, that is, without any personal identification, for the purposes set forth in this Privacy Policy.
6.4
Data retention. We may retain the Personal Data of certain Users for a period longer than the legal retention period, in compliance with any orders from public authorities, to defend ourselves in legal and/or administrative proceedings, and in cases where the Personal Data has been properly anonymized.
6.5
The lack of consent from Users for this Privacy Policy prevents us from providing some of our services.
7. CONTACT WITH LABORA
7.1
In case of any questions or requests to exercise any of the rights described in item 6, you may contact the Data Protection Officer using the information below:
Name: Sergio Serapião
Email: [email protected]
8. SHARING OF DATA WITH THIRD PARTIES
8.1
In addition to the cases already mentioned in this Privacy Policy, Personal Data may also be transferred to third parties in the following cases:
8.1.1 Provision of Services. We may hire third parties to assist us in providing our services, such as cloud storage servers. Any other vendors we use may be replaced at any time, provided that appropriate standards of data security and confidentiality are maintained.
8.1.2 New Businesses. There may be a transfer of Personal Data in processes of acquisition, sale, merger, corporate reorganization, or any other change of control of Labora. In this case, we will ensure that the individual or entity that accesses or takes control over the data processed under this Policy is also bound by it. This way, we can guarantee the continued protection of your Personal Data. Finally, we will keep you informed if this transfer involves any changes to the Privacy Policy.
8.1.3 Judicial or Administrative Request. We may share Personal Data in the event of a judicial or administrative request.
8.1.4 With the User’s Authorization. In other cases, when there is a need to share information, we will send you a notification requesting your approval.
9. OTHER
9.1
BY ACCEPTING THIS POLICY, YOU GIVE YOUR FREE, EXPRESS, AND INFORMED CONSENT TO ALL THE PRACTICES MENTIONED IN THIS PRIVACY POLICY.
9.2
IF YOU DO NOT UNDERSTAND ANY PART OF THIS PRIVACY POLICY, you should contact Labora BEFORE ACCEPTING THE TERMS SET FORTH HEREIN. We are available to clarify any questions that Clients may have, via email at [email protected].
9.3
The terms of this Privacy Policy are governed by and shall be interpreted in accordance with the laws of the Federative Republic of Brazil and in accordance with the general provisions of Labora’s Terms of Use, of which this Privacy Policy is an integral part.
10. UPDATES TO THE PRIVACY POLICY
10.1
To ensure users’ privacy and data security, we are committed to regularly reviewing and adapting this Privacy Policy as needed. If changes are made to this Privacy Policy, you will be notified and should review those changes. If you continue to use the Platform after we announce an update to the Privacy Policy, we will interpret that as your agreement with the changes made to this document. If you do not agree with the changes to the Policy, you should refrain from using the Platform.
Brazil's 1st technology platform for productive inclusion and flex work
RECOGNITIONS:
SUSTAINING ORGANIZATION OF:
