Labora Privacy Policy

PÓLEN IMPACTO SOCIAL S.A., sociedade por ações, com sede na Alameda Vicente Pinzon, nº 54, Conjunto 91, Vila Olímpia, na cidade de São Paulo, Estado de São Paulo, CEP 04547-130, inscrita no CNPJ/ME sob o nº 32.146.867/0001-46 (“Labora” ou “nós”), única e exclusiva proprietária dos direitos relacionados à Plataforma Laboratech (“Plataforma”) apresenta a presente Política de Privacidade. Essa Política de Privacidade pretende fornecer aos Usuários (“Usuários” ou “você”) uma visão transparente das nossas práticas relacionadas à coleta, armazenamento e formas de uso de seus dados pessoais.

The terms contained in this Privacy Policy, whenever used with the first letter capitalized, shall have the meaning set forth in this Privacy Policy, in the Terms of Use, or in Law 13.709/2018 ("LGPD"). However, should you still have any questions, we suggest you contact us by e-mail at [email protected].


We offer a platform to promote the inclusion of diversity in the labor market, offering courses and intermediating hiring by partners registered on the Platform.

This Privacy Policy is intended to inform you about the way in which your Personal Data is collected and processed.

Here you will find a short summary of this Policy, but we recommend that you read the complete document:


User Data entered in the Platform for registration; Access Data; Data treated in the Professional Accompaniment; Data related to Courses; Data provided by Users for registration in Opportunities.

Purpose of processing

Registration in an e-mail list; Suggestions of customized job opportunities; Sharing with Partners for the selection of candidates capable of providing Services; Mapping of Skills; Professional monitoring; Communications and alerts by Labora; Improvement and protection of the Platform.

Treatment agents

PÓLEN IMPACTO SOCIAL S.A. – Controladora do tratamento. Alameda Vicente Pinzon, nº 54, Conjunto 91 – Vila Olímpia, São Paulo – SP, CEP 04547-130

Legal basis of the

(i) Consent;

(ii) Contract execution;

(iii) Legitimate interest;

(iv) Fulfillment of legal obligation;

(v) Regular exercise of rights.

of the holder

Confirmation of Treatment; Access to Personal Data; Correction of incomplete, inaccurate, or outdated data; Deletion of Personal Data; Anonymization, blocking or deletion of data; Portability; Information about the possibility of not consenting; Opposition to Data Treatment; Revocation of consent; and Review of decisions taken solely on the basis of Automated Data Treatment.


Appropriate technical and administrative measures, considering the nature of the processing and the sensitivity of the data.

Contact and


E-mail: [[email protected]]

By registering with Labora, you agree and declare that you are aware of all provisions of this Privacy Policy. Therefore, we suggest that you carefully read this document, as well as any updates, before making the decision to use or proceed with the use of the Platform. If you do not agree with any provision of this Policy, you shall not use our Platform.


2.1 In this Privacy Policy capitalized terms will be defined as described below:


Personal Data: means, collectively, all of your personal data, whether sensitive data or not, including, but not limited to, your full name, email, phone number, race self-declaration, gender self-declaration, identification as a LGBTIQ+ person, information if you have a disability, and other related information;


Person in Charge: means the person responsible for acting as a communication channel between Labora and you;


Partners: means companies registered with Labora, which advertise job openings and provision of Services through the Platform.


Platform: means our proprietary software, which offers you Tools such as Courses, Opportunities and Professional Monitoring;

3. What data does Labora collect?

Data Group

How it is collected

What data is collected and processed

User Data entered in the Platform for registration

Provided by Users who wish to register on the Platform.

First Name;

Last Name;



Month of birth;

Year of birth;



Sexual orientation;

Information if transgender;

Information if disabled.

Access Data

Automatic collection of all the Users who access the Platform.

Data processed during Professional Accompaniment

Provided by Users for enrollment in Courses, as well as provided by third parties, Course providers.

Data related to Courses

Provided by Users, using the Labora App.

Data provided by Users for enrollment in Opportunities

Provision by User for enrollment in Opportunities.

From time to time, Labora may ask you to complete and/or update your data, provided that you always have the option of providing it or not.



We will use the Personal Data described in the item above for the following purposes and in accordance with the applicable legal basis:

Data Group

How it is collected

Email list registration

Labora may use your contact data, including email and telephone, to communicate by sending notifications, alerts and other notices related to Labora for use of the Platform.

Suggestion of personalized job opportunities

We may use your data, including sensitive data (such as your diversity characteristics, such as sexual orientation, self-declaration of transgender, if you are a person with a disability), to direct Opportunities on the Platform.

Sharing with Partners for the selection of candidates able to provide Services

While we will offer you Opportunities according to your characteristics and diversities, we will share your Skills and profile data with Partners so that they can evaluate whether you fit the Opportunity offered.

Attention: You acknowledge and agree that whenever you choose to apply for an Opportunity, we will share your Personal Data with Partners and may even share sensitive Personal Data such as your sexual orientation and race.

Skill Mapping

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 can be shared with Partners whenever you apply for an Opportunity.

Furthermore, the summary of your Skills can be accessed by third parties, Labora Users, by accessing your profile at Labora.

Professional Follow-Up

You may enter Data on the Platform providing information about the Service provided. Labora may consolidate this information and share it with Partners so that Partners can better understand the impact of your Services.

Communications and Alerts by 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's use of the Platform.

Enhancement and protection of the Platform

Labora may use Personal Data, including IP data, to detect possible fraud and security incidents on the Platform.

In addition, Labora may use browsing data to improve your experience on our Platform, as well as use access logs to detect errors in our systems.


We will process your Personal Data based on the following legal assumptions: (i) consent; (ii) when necessary to perform a contract to which you are a party; (iii) based on our legitimate interests; and (iv) to comply with legal or regulatory obligations; and (v) to exercise our rights.



We know that your data is extremely important to you and, consequently, to us as well. Therefore, Labora undertakes to do everything possible to keep your Personal Data always safe, including adopting security and protection measures compatible with the nature of the data collected, used, and stored and appropriate market practices. However, Labora cannot guarantee that such security measures will be error-free or that they will not be subject to interference from third parties (hackers, among others). By its nature, despite Labora's best efforts, any security measure can fail, and any data can become public. BY USING THE PLATFORM, YOU EXPRESSLY UNDERSTAND AND ASSUME THAT RISK AND AGREE THAT LABORA SHALL NOT BE LIABLE FOR SUCH DATA LEAKAGE.


All information collected will be stored with a high standard of security on third-party servers located abroad.


By using the Platform, you are aware and agree that we may hire Sub-Operators, national or foreign, who may also process your Personal Data. These Sub-Operators, national or foreign, will be contractually subject to the same security and confidentiality requirements applicable to Labora.



Labora provides tools for Data Subjects to exercise their legal rights over Personal Data, as provided 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 may request that we confirm whether Labora processes your Personal Data.

6.1.2 Access to Personal Data. You may access your Personal Data, including by requesting a copy of the data we process.

6.1.3 Correction of Incomplete, Inaccurate or Outdated Data. You may request amendment or correction of your Personal Data that are incorrect in our database.

6.1.4 Deletion of Personal Data. You may request the deletion of your Personal Data processed by Labora when such Personal Data has been collected and processed based on your consent, through the Platform or by request through the service channels indicated in this Policy.

6.1.5 Information on Sharing. You may request information on which public and private entities we share your Personal Data with, pursuant to this Policy.

6.1.6 Anonymization, blocking or erasure of data: You may request that Labora anonymize, block, or anonymize Personal Data that is excessive.

6.1.7 Portability. You may request that your Personal Data be sent to another service provider.

6.1.8 Information about the possibility of not consenting.You are provided with this Policy and may request through customer service channels information about the possibility of your not consenting to the Processing of Personal Data and its potential consequences, including in relation to the impossibility of providing our services;

6.1.9 Opposition to Data Processing. You may object to the Processing of Personal Data that is founded on a legal basis other than consent.

6.1.10 Revocation of consent. You may revoke your consent for Processing which is founded on a legal basis other than consent.

6.1.11 Review of decisions made solely on the basis of Automated Data Processing. If Labora makes any decisions based solely on automated Processing of Personal Data, you may request that those decisions be reviewed.


Exercise of Rights. The rights mentioned above and others provided for in the applicable legislation may be exercised by you, in relation to your Personal Data, directly through the Platform, according to the functionalities made available on it (such as, for example, tools for accessing and editing Personal Data) or by means of a request addressed to the channel [[email protected]].


Information on data deletion. Please note that we may, due to legal or administrative obligations, be prevented from deleting certain types of Personal Data. In this case, when applicable, we will inform you of such impossibility, proceeding with the deletion of the remaining information that may be deleted. Without prejudice to complying with eventual requests for deletion, which, when possible, will be informed to you, we may be unable to provide our services, totally or partially. Also, after the deletion of Personal Data, we may continue to use them, in a non-individualized and anonymized way, that is, without any personal identification, for the purposes set forth in this Privacy Policy.


Data Retention. We may keep the Personal Data of certain Users for a period longer than that of legal custody, in compliance with any orders from public authorities, to defend ourselves in legal and/or administrative proceedings and in cases in which the Personal Data has been duly anonymized.


Failure to provide consent by Users to this Privacy Policy makes it impossible for us to provide some of our services.



In case of doubt or request to exercise any of the rights described in item 6, you may contact the Person In Charge, as per information below:

Name: Sergio Serapião

E-mail: [email protected]



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 appropriate data security and confidentiality standards are maintained.

8.1.2 New Business. Personal Data may be transferred in the course of an acquisition, sale, merger, corporate reorganization, or other change in control of Labora. In this case, we will ensure that the person, whether an individual or entity, who accesses or assumes control over the data processed under this Policy will also be bound by it. In this way, we can ensure the continued protection of your Personal Data. Finally, we will keep you informed if this transfer implies any change in the Privacy Policy.

8.1.3 Judicial or Administrative Requests. We may share Personal Data in case of a judicial or administrative order.

8.1.4 With the User's authorization. In other cases, if there is a need to share information, we will send you a notification requesting your approval.





IF YOU DO NOT UNDERSTAND ANY PART OF THIS PRIVACY POLICY, you shall contact Labora BEFORE ACCEPTING THE TERMS PROVIDED HEREIN. We are available to clarify any doubts that Customers may have, through the email [email protected].


The terms of this Privacy Policy are governed by and shall be construed in accordance with the laws of the Federative Republic of Brazil and the general provisions of Labora's Terms of Use, of which this Privacy Policy is an integral part.



In order to ensure the privacy of Users, and the security of their data, we are committed to regularly reviewing this Privacy Policy and adapting it as necessary. If changes to this Privacy Policy are implemented, you will be notified and asked to review such changes. If you continue to use the Platform after we announce an update to the Privacy Policy, we will interpret that you have agreed to the changes drafted in this document. If you do not agree to the changes to the Policy, you should refrain from using the Platform.

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