Privacy Notice

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The protection of privacy and personal data reaffirms our commitment to the continuous improvement of the effectiveness of the information security process.

This Privacy Notice is intended to clarify how your personal data is collected, used, shared and stored by Sphere IT.

 

1. Introduction

Sphere IT Solutions Ltda and Sphere IT Serviços Ltda, hereinafter referred to as Sphere IT, take appropriate measures to ensure the protection of personal data collected, received or processed by us.

Sphere IT reserves the right to change this Policy at any time without prior notice, so we recommend that you access this Policy regularly.

 

2. Definitions

Personally Identifiable Information

Personally Identifiable Information is all information related to an identified or identifiable natural person, directly or indirectly, or other specific elements of their physical, physiological, genetic, mental, economic, cultural or social identity.

Examples: name,  CPF, phone number, zip code of residence, weight, height, photos, videos, hobbies, consumption habits, etc.

Sensitive personally identifiable information

Sensitive personal data are all personally identifiable information about racial or ethnic origin, religious belief, political opinion, membership in a union 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.

Processing

Any operation performed with personally identifiable information, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer , diffusion or extraction.

 

3. Access to the website and systems

The treatment of information regarding users of the Sphere IT website and systems will comply with the following guidelines:

• While browsing our website, the following information may be collected: characteristics of the access device, operating system, browser type and version, IP address with date, time and origin, pages accessed, any term entered on the website and/or application , geolocation, among others. The legal basis for this treatment is the legitimate interest.
• The information will be collected, processed and stored in a safe manner, respecting the legal deadline and the best information security practices.
• The information collected will be considered confidential and will only be accessed by authorized and trained people to give them the appropriate treatment.
• The information collected can be used to provide more efficient navigation and targeted to users' needs.
• The information collected can be used to provide more efficient navigation and targeted to users' needs.
• The storage and use of information will enable Sphere IT to offer personalized information and services, according to the characteristics and interests of its users. With this, there may be specific content and advertising offers for each user. To this end, Sphere IT may share the information obtained with contracted companies, always complying with data security principles, requiring compliance with our security and privacy guidelines. Sharing is done for website and data hosting, navigation analysis and marketing campaigns. The legal basis for this treatment is the Legitimate Interest.
• The website and / or system may contain links that direct the user, in his / her sole and exclusive discretion, to third party websites. Sphere IT disclaims any responsibility for the security of browsing on such sites, as well as for the content made available on them.
• Regardless of the direction made on the website and / or system page, these Privacy Guidelines are not applicable to the pages of third party companies, which may have privacy policies different from this one, which are recommended to be read.
• The authentication mechanisms (password, token, etc.) made available for access to our environments are for personal and non-transferable use and should not be shared under any circumstances. Accesses may be blocked in cases of suspected fraud or upon a confirmed request from the user or the company. Sphere IT is not responsible for any damage caused by such sharing.

Cookies can be disabled through browser preferences. Without them, navigation may become limited and some functionality of the sites may be compromised. See the definitions of cookies in each of the browsers.

https://privacy.microsoft.com/pt-BR/windows-10-microsoft-edge-and-privacy / https://support.mozilla.org/pt-BR/kb/desative-cookies-no-firefox-parar-rastreamento / https://support.google.com/accounts/answer/61416?hl=pt-BR / https://support.apple.com/en-us/HT201265

 

4. Cookies

On our website https://www.sphereit.com.br we use Google Analytics, YouTube cookies, advertising cookies and others to track your browsing behavior on our website such as pages visited, return to the website, time of visit, etc. This information is important to us in order to improve the experience of visiting our website and to increase the effectiveness of our website. If you do not agree, simply indicate your preference in the cookie banner on our website.

If you have agreed, but decided to change your option, simply change your preferences in the cookie banner on our website. If you wish to opt out of Google Analytics, there is also the option to install the plug-in Google Analytics Opt-Out Browser Add-On

 

5. Other personally identifiable information collected from customers and visitors

They are provided by you or your employer, by filling out registration requests, contact forms, requests for access to our systems, by contracts, by email, etc. In these ways we collect name, e-mail, telephone numbers, position, CPF and employer. This data is used to communicate with our company and create access to our systems. We send email newsletters to our customers about security advisories and general IT matters, as well as satisfaction surveys. The legal basis of these treatments is the legitimate interest.

Upon entering our company, we collect date and time of entry and exit of the condominium as well as images from security cameras. The legal basis for this treatment is the legitimate interest.

Remote meetings with Sphere IT can be recorded. Whenever a meeting is being recorded, a recording notice will be displayed so that everyone can speak up or eventually choose to withdraw from the meeting. The legal basis of this treatment is legitimate interest.

 

6. Personally identifiable information collected from job applicants

Identification data, such as your name, marital status, nationality, identity, CPF;

personal information, such as date and place of birth and gender;

contact details, such as your home address, home phone, cell phone and personal email address;

Information about your academic background, such as your curriculum, level of education, undergraduate, graduate, specialization, graduate, training, languages, courses, technical skills and competences, membership in associations;

Information about your professional experience, such as your job title, role, previous employers, length of service, job location, department, type of responsibilities, name of supervisor, assignments, start and end date at each previous job, reasons for leaving, employment history (including job titles and previous employers, and reasons for leaving), and letters of recommendation;

Information about your compensation and benefits, such as your base salary, bonuses, commissions, raise amounts, benefits such as health insurance, life insurance and other benefits such as a pension plan;

Performance information and disciplinary measures, such as performance appraisals, evaluation grades, details of internal disciplinary procedures;

Information about your career aspirations, including the intended position, salary expectations, the way in which they became aware of the vacancy, requests for benefits, relocation information, availability for travel;

Notes during interviews, as well as any other data you voluntarily disclose during any interview; and

sensitive personally identifiable information, which in our selection process will only consist of data on people with disabilities or people with special needs, in case the hiring is aimed only at people with disabilities or if some additional action is necessary in the company to make possible hiring.

We may collect personal information that is not directly provided by you, such as:

1. Information provided by recruitment agencies;
2. Other basic information provided or confirmed by academic institutions and training or certification providers;
3. Information collected from publicly available sources

You are under no obligation to send us any information that we request from you. However, depending on the type of information, it may not be possible to proceed with the selection process for a specific position.

Except in relation to your sensitive personal data, we will process your personal data for the purpose of recruitment based on our legitimate interest. Our legitimate interest in this activity is to ensure an efficient recruitment process, and that our vacancies are filled with the most suitable candidates for the roles.

If you are accepted for a role at SPHERE IT, the information collected during the recruitment and selection process will also be used to assist with the admissions process, preliminary procedures related to your future employment contract.

In relation to your sensitive personal data, we will only process your personal data with your free, informed and unequivocal consent, specific to these recruitment and selection activities.

If necessary, Sphere IT may process your personal data to comply with legal or regulatory obligations and to exercise rights, pursuant to article 7, II and VI, and article 11, II, (a) and (d) of the LGPD.

 

7. Sharing and International Transfer of Personally Identifiable Information

Sphere IT contracts third-party companies to provide support and support services. For the correct provision of such services, these third parties process personal data on behalf of, or in collaboration with, Sphere IT. Sphere IT only uses companies that present adequate technical and administrative measures in a way that the treatment meets the requirements of the LGPD and ensures the defense of the rights of the holders. In this sense, the third party is required to comply with the requirements of LGPD – Law no. 13,709/18.

Sphere IT may share your personal data to comply with legal obligations, including, where necessary, to respond to a court order, administrative or judicial proceeding, including, but not limited to, a subpoena, government audit, or search warrant.

Some of the third parties that have access to personal data may be located in other countries or may process data outside Brazil. The level of data protection in some countries may not be equivalent to the level of protection in Brazil. Therefore, we will only transfer your personal data to countries that the National Data Protection Authority (“ANPD”) has decided to have an adequate level of protection, or we will take effective measures to ensure that all recipients of personal data implement an adequate level. of data protection.

Sphere IT will carry out the international transfer of data only to countries or companies that provide a level of personal data protection adequate to the provisions of the General Law on Personal Data Protection. These transfers are carried out for the purpose of storage on third-party servers located abroad.

 

8. Your rights as a data subject

You have the following rights in relation to your personally identifiable information:

Right to confirm treatment and right of access – You have the right to obtain confirmation of the existence of the activity of processing your personal data. If Sphere IT processes your personal data, you have the right of access, that is, to obtain a statement about the categories of personal data processed, the origin of the data and the purposes of the treatment. If your personal data is processed based on your consent, or on a contract between you and Sphere IT, you also have the right to obtain a full copy of the personal data that is processed on the basis of consent or contract.

Right to rectification – You have the right to request the correction of incomplete, inaccurate or out-of-date data about you.

Right to anonymisation, blocking or deletion – In certain cases, when your personal data is unnecessary, excessive or is treated in breach of the LGPD, you have the right to request the anonymization, blocking or deletion of this data.

Right to data portability – In certain cases, as defined and to the extent required by the ANPD, and always respecting the commercial and industrial secrets of Sphere IT, you have the right to the portability of your personal data to another company.

Right to erasure – In cases where your data is processed based on your consent, you have the right to request the deletion of such personal data, except in the cases in which Sphere IT has the right to retain the data under the terms of the LGPD.

Right to information on shared use of data – You have the right to obtain information about the public and private entities with which Sphere IT has shared your personal data.

Right to refuse and revoke consent – Every time we ask for your consent to process your personal data, you have the right to refuse consent. We will always inform you about this right, and about the consequences if you prefer not to give consent to a processing activity. Furthermore, whenever you consent to the processing of your personal data for a specific purpose, you can revoke your consent at any time.

Right to object to unlawful treatment – You have the right to object to any activity of processing your personal data that violates the provisions of the LGPD.

Right to review decisions solely based on automated processing – You have the right to request the review of decisions made solely on the basis of automated processing of personal data that affect your interests, including decisions aimed at defining your personal, professional profile or aspects of your personality.

These rights will be exercised at the express request of the data subject or a legally constituted representative and will be attended to at no cost to the data subject.

Right to petition before the ANPD and before consumer protection bodies  – You have the right to petition against Sphere IT before the National Data Protection Authority – ANPD and before consumer protection bodies, in relation to your personal data.

 

9. Retention period

Sphere IT will keep your personal data for as long as necessary for the recruitment activity, or for the minimum period required by law. We do not keep personal data longer than necessary. But we may, for example, keep your personal data until a statute of limitations has elapsed in the event of any dispute, always based on the applicable legislation.

For the personal data of job applicants, if there is no immediate hiring, we may retain this information for a period of up to 12 months to identify future employment opportunities for which you may be suitable and to contact you to offer the opportunity. participation in the selection process.

 

10. Security of personally identifiable information

We take care of your information with strict security and confidentiality standards, to provide our customers and visitors with a safe and reliable environment. We use tools and technologies to maintain the integrity and confidentiality of your information and protect it from unauthorized access.

In addition, we restrict access to your information to the extent necessary, with strict confidentiality and secrecy obligations and through the adoption of security measures.

 

11. Legal References

• Law 13.709/18 General Personal Data Protection Law (LGPD)
• Law 12.965/14 Civil Law of the Internet

 

12. Contact

Any question related to the Privacy of personal data can be addressed in writing to our Data Protection Officer:

E-mail: dpo@sphereit.com.br

       or by correspondence to:

DPO – Sphere IT
Rua José Versolato, 111 - 18th. floor - Room 1821
São Bernardo do Campo – SP
CEP 09750-730

 

Versão: novembro/2022