Privacy Policy

Yes Talent is committed to protecting privacy and personal data. Below, we present our Privacy Policy, containing all the information so that you (“User[1]”) know about the use, by Yes Talent, of personal data collected at our electronic addresses, such as: https:/ /yestalent.com.br (the “Site”) and on our vacancy portal at https://yestalent.com.br/candidatos (the “Vacancies Portal”) and/or by accessing and registering, whether or not you attach your curriculum vitae, in our Talent Bank contained in links originating from the aforementioned electronic addresses, hereinafter referred to as “websites”. It is worth noting that, for the purposes of this Policy, Personal Data is data related to the identified or identifiable natural person – that is, it does not apply to data relating to legal entities.

By requesting contact with us, downloading materials and content available on the website and/or applying for vacancies advertised by Yes Talent through our vacancies portal, you are in agreement with this Privacy Policy and our Terms of Use. This indicates that you You are aware of and agree to the collection and processing of your data by Yes Talent in accordance with the following policy.

1. Personal data collected and how we use it

1.1. We collect the following categories of personal data from our clients, candidates and visitors to our websites:

1.1.1. Personal data – Included in this category are classes of data that identify a candidate and their personal characteristics. Examples of this are: names, addresses, job titles, employer, contact details, age, date of birth. We may collect names, email addresses and contact information from visitors who register on our institutional portal. For our clients, we may collect information about the client’s business, such as: company name, size, number of employees, type of business, contact information and other data relevant to carrying out our recruitment and selection consultancy work.

1.1.2. Education and professional training information – Included in this category are matters that relate to the education and professional training of a potential candidate. Examples of this are academic data, qualifications, skills, training and professional experiences.

1.1.3. Employment information – Included in this category are matters related to the candidates’ employment. Examples are job title, employer and career history, recruitment and intercompany transaction details, attendance data, career potential, professional profile or other information necessary to determine a candidate’s professional suitability for the professional opportunities we are working on for our clients.

1.1.4. Financial information – Included in this category are matters relating to a candidate’s financial affairs. Examples are income, salary, benefits, bonuses, expected salary or other information necessary to evaluate a candidate’s professional adherence to vacancies worked for our clients. For our clients, the information may also include salary expectation information and data that can assist in designing the best salary proposal for the chosen finalists.

1.1.5 Goods or services provided – Included in this category are classes of data relating to goods and services that have been provided. Examples are details of the goods or services provided to our customers.

1.1.6 IT Information – Included in this category is all information relating to a candidate’s use of technology or software, including IP addresses, any information about the mobile or computing device a candidate is using, location data collected from those devices , connection data and social media handles.

1.1.7 Special Categories – Included in this category are classes of data that are considered confidential data, personally identifiable information, or sensitive personal data under applicable law. This category of personal data is generally collected to meet legal requirements or to determine suitability for employment.

1.1.8 We may also collect personal data about your contacts, such as email addresses. If you believe that one of your contacts has provided us with your personal data and would like to request that it be removed from our database, please contact us at privacy@yestalent.com.br and we will forward you a link to view your personal data and even delete your data from our database.

1.2 Personal data is collected and used for Yes Talent’s legitimate business purposes and to fulfill the Company’s contractual and legal obligations, including establishing, managing and providing the recruitment and selection service to our clients. Personal data is used by Yes Talent for the purposes described in this Privacy Policy or for additional purposes that Yes Talent has advised you and/or for which Yes Talent has obtained your consent regarding the use or disclosure of your personal data . Specifically, we use the personal data collected only for the following purposes:

1.2.1 Provide services to our customers.

1.2.2 Facilitate services provided to our customers.

1.2.3 Maintain records of each candidate’s career and future career interests.

1.2.4 Maintain records of customer information regarding vacancies conducted.

1.2.5 Manage a client’s accounts, including payment that may vary depending on the salaries of hired candidates.

1.2.6 Respond to a customer’s service or support requests.

1.2.7 For marketing, promotional and sales purposes.

1.2.8 For data security purposes.

1.2.9 For machine learning purposes and improving our job portal and website.

1.3.0 Yes Talent does not use personal data for automated decision making.

1.3 We will only share your personal data with third parties in the manner described in our customer contracts and this Privacy Policy. By third parties we can understand our customers and our suppliers. We do not sell your personal data to third parties. Furthermore, our employees are trained and subject to confidentiality obligations and only have access to personal data on an as-needed basis.

1.4 We may email information about job market updates or job offers to our candidates and/or website visitors in accordance with the Terms of Use and the terms described in this Privacy Policy.

1.5 Yes Talent will not use or disclose your personal data, except (i) to the extent necessary to provide its services to clients, enabling their participation in selection processes for which we are our clients’ agents. For these purposes, Yes Talent uses information management system providers, namely Workforce Cloud Tech, 28 Mohawk Avenue, Norwood, NJ 07648, United States of America, under the trade name RecruitCRM. RecruitCRM has a GDPR compliance certificate. Individual client or client candidate records may be viewed or accessed by RecruitCRM employees or authorized agents for the purpose of (i) providing the Service and related professional services to clients or client candidates, (ii) resolving a problem support affecting any of them, (iii) as required by law, as determined by RecruitCRM in its sole discretion, judicial proceeding, subpoena, legal process or binding court order. We also reserve the right to disclose your personal data when we believe, in our sole discretion, that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, subpoena, court order or legal process.

1.6 Personal data may be disclosed or distributed to another party with whom Yes Talent enters, or may enter, into a corporate transaction. If Yes Talent is acquired in a merger, acquisition or sale of all of its assets, you will be notified via email, on our Site and/or by a prominent notice on our Service of any change in the use of your data personal data, as well as any choices you may have in relation to your personal data. Disclosure of personal data to another party as set forth herein may involve the transfer of such personal data outside of the state, province, country or other jurisdiction in which Yes Talent stores and processes personal data, subject to Yes Talent taking steps to ensure that such transfers are made only in compliance with applicable laws. In the unlikely event of bankruptcy, insolvency or liquidation, the database containing personal data may be treated as an asset of Yes Talent and may be subject to transfer to third parties.

1.7 Marketing: Yes Talent may also ask website visitors who register on the Institutional Portal to provide certain information, such as email addresses, in order to use and receive content from the website. Yes Talent will provide such visitors with the ability to opt-in or opt-out of future communications from Yes Talent as required by applicable law. If you wish to stop receiving this information, please update your email preferences using the “Unsubscribe” link found in the emails we send to you or by contacting us at privacy@yestalent.com.br

2. How we use cookies, log files, social media plugins and other embedded content tracking technologies

2.1 Technologies such as cookies or similar technologies are used by Yes Talent and our partners, affiliates or service providers. These technologies are used to analyze trends, administer the site, track users’ movements, and gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

2.2 Log files: We gather certain information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date and time stamp, clickstream data, files viewed on our website (e.g. HTML pages, graphics, etc.), to analyze trends together and manage the website. We link these automatically collected data sets to personal data that you may already have stored.

2.3 Cookies: We may use cookies to remember user settings (e.g. language preference) and to authenticate you when you visit the Site or use the Service, as appropriate. The following information will help you understand the different types of cookies used:

2.3.1 Strictly necessary cookies are necessary for the operation of the Site. This includes, for example, cookies necessary to improve the presentation and content of the website.

2.3.2 Session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. Session cookies only exist during an online session. They disappear from your computer when you close your browser software or turn off your computer.

2.3.3 Targeting cookies that store the username of a connection, the referring user if using the referral network and the referral source for the Site.

2.3.4 The following third-party, performance and targeting cookies may be used:

LinkedIn: The site uses LinkedIn cookies to populate application information when the candidate wishes.

Google Analytics: The website uses Google Analytics cookies to track anonymous interactions and visits.

2.3.5 Strictly necessary cookies are necessary for the website to function. You can set your browser to block or alert you about these cookies, but some parts of the site will not work.

2.4 Opt-out: You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. Many browsers allow activation privately, with cookies always being deleted after the visit. Depending on each browser, this private mode may have different names. The following is a list of the most common browsers that support the recommended minimum level of TLS 1.2 encryption. Each browser type has a different name for “private mode”:

Internet Explorer 11 and later versions = In Private

Safari 7 and later = Browsing / Private Browsing

Opera 17 and later versions = Browsing / Private Browsing

Mozilla Firefox 27 and later = Browsing / Private Browsing

Google Chrome 30 and later = Incognito browsing

2.5 Social media (features) and widgets: Our website includes social media features such as LinkedIn. These features may collect your IP address, the page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are hosted by third parties or directly on our website. Your interactions with these features are governed by the privacy statement of the company that provides them.

2.6 Embedded content from other websites: Articles on this website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves exactly the same way as if the visitor had visited another website. These websites collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

3. Access to personal data controlled by Yes Talent

Yes Talent recognizes that candidates have the right to access their personal data and to withdraw consent to the use/processing of their personal data. We recommend that a candidate seeking to access, or seeking to correct, amend, delete or receive a copy of personal data, forward their query to Yes Talent. If requested to remove a candidate’s data, we will respond within 30 days or as required by applicable law. Candidates can also send these questions or requests directly to Yes Talent, at no cost to them, by contacting privacy@yestalent.com.br or through direct contact with their trusted Yes Talent Consultant.

4. Data retention by Yes Talent

We will retain personal data for as long as a customer’s account is active or as necessary to provide our services to customers as required in customer contracts and/or for as long as Yes Talent needs the personal data to fulfill the purposes for which the Company initially collected it , unless otherwise required by applicable law or court order. We will also retain this personal data as necessary to comply with our legal and/or contractual obligations, comply with court orders, resolve disputes, and enforce our agreements. When the purpose for which Yes Talent is processing personal data is fulfilled, expires or ends, Yes Talent will delete all personal data in accordance with our customer contracts, this Privacy Policy and applicable law. If we are unable to delete your personal data, we will inform you why, subject to any legal restrictions.

5. Data Security

Yes Talent, through its information management provider (RecruitCRM), employs reasonable and appropriate security measures to protect against the loss, misuse and alteration of the personal data it processes. When the Service is accessed using Microsoft Internet Explorer versions 8.0 or higher, Transport Layer Security (TLS) technology protects information using server authentication and data encryption to help provide safe and secure personal data during transport. The information management provider also implements an advanced security method based on dynamic data and encoded session IDs and hosts the Service in a secure server environment that uses a firewall and other advanced technology to protect against interference or access by external intruders. Finally, the information management provider provides individual usernames and passwords that must be entered each time a Yes Talent employee logs into the system. These safeguards help protect against unauthorized access, maintain data accuracy, and provide for the appropriate use of personal data. However, no method of transmission over the Internet, or method of electronic storage, is one hundred percent (100%) secure, however. Therefore, we cannot guarantee absolute security. If you have any questions about security on our Service, please contact us at privacy@yestalent.com.br.

6. No services for minors

We do not knowingly collect information from minors. To use the Site, you must be the age of legal majority in your place of residence. By using the Site, you represent that you are at least the age of legal majority in your place of residence. We do not use an application or other mechanism to determine the age of users of the Site. All information provided to us will be treated as if it were provided by an adult. We will make commercially reasonable efforts to delete information associated with a minor as quickly as possible if we learn that a minor has submitted information about themselves to us.

7. Do Not Track Disclosure (DNT – Do Not Track)

There are many methods by which web browser signals and similar mechanisms can indicate your choice to opt-out of tracking. But we may not be aware of or able to honor all of these mechanisms. Because there is not yet a common understanding of how to interpret web browser-based “Do Not Track” (DNT) signals other than cookies, we may not respond to undefined DNT signals on our websites or online services. More “do not track” information is available at www.allaboutdnt.org regarding this information.

8. Divisibility

The invalidity or unenforceability of any provisions of this Privacy Policy in any country will not affect the validity or enforceability of any other provision of this Privacy Policy, which will remain in full force and effect.

9. Changes to this Privacy Policy

We may update this privacy statement to reflect changes in our information practices that will be effective upon posting. If we make material changes to this policy, we will notify you here, by email or by means of a notice through our usual communication channels prior to the change becoming effective. We recommend that you periodically review this page for the latest information about our privacy practices.

10. The Privacy Policy of our information management system

RecruitCRM, the company providing Yes Talent ‘s information management system, has certified its compliance with the United States Privacy Shield Framework (https://www.privacyshield.gov) and is also committed to subjecting all personal data it receives from data exporters in any member state of the European Union (EU), Switzerland or European Economic Areas (EEA), under the Privacy Shield Framework, to its applicable Privacy Shield Principles. More information about RecruitCRM’s privacy policy can be found at the link: https://recruitcrm.io/legal/privacy

11. Data Protection Officers

Yes Talent has appointed its Data Protection Directorate, responsible for issues related to privacy and data protection. Those responsible for data protection can be contacted by email Privacy@yestalent.com.br or by mail: Yes Talent, Ed. Continental, Rua Olímpicos, 205, 4.ofloor, Vila Olímpia, 04.551-000, Attn: Data Protection/Legal Directorate.

Any questions or complaints related to Yes’s Privacy Policy or the handling of personal data can be directed to: privacy@yestalent.com.br or by mail: Yes Talent, Ed. Continental, Rua Olímpicos, 205, 4th floor, Vila Olímpia, 04.551-000, A/C:: Information Security / Legal Department. Furthermore, you have the right to lodge a complaint with your local data processing authority.

12. Definitions

Candidates – includes professionals who have applied or been selected for any roles advertised or promoted by Yes Talent and/or candidates who Yes Talent reasonably considers to be interested in being considered for any roles, including permanent, part-time and temporary positions and self-employment roles with Yes Talent Clients (including candidates who intend, or who Yes Talent can reasonably consider may wish, to become Temporary Workers); as well as people who spontaneously submitted a CV to Yes Talent, not related to a specific vacancy. Individual contractors, self-employed people and employees of suppliers or other third parties who apply for roles with Yes Talent Clients or as part of a job offer or who will otherwise be treated as candidates for the purposes of this Privacy Policy.

Clients – this category covers clients and others to whom Yes Talent provides services in the course of its business or whom Yes Talent reasonably considers to be interested in our services.

Delete – Yes Talent, since its inception, was born with a commitment to adhere to the GDPR legislation that gave rise to the LGPD in Brazil. Therefore, since the owner of personal data is the candidate, we have ways for the candidate to actually request Yes Talent to delete their personal information from its database system at any time. To do so, the candidate simply needs to contact the Consultant responsible for their application and/or send an email to privacy@yestalent.com.br requesting exclusion. Or, the professional may request a link to access your profile within the database to check your information. In this link, there is also a button that allows the candidate to delete their personal data.

GDPR – The General Data Protection Regulation 2016/679 is a regulation of European law on privacy and protection of personal data, applicable to all individuals in the European Union and European Economic Area that was created in 2018. It also regulates the export of personal data outside the EU and EEA.

General Personal Data Protection Law (LGPD) – a Brazilian legal instrument that aims to harmonize and complement existing legislation in Brazil on data protection. Any references to the Law should be interpreted in conjunction with existing national data protection legislation.

Managed Service Provider Programs (PSG) (MSP) – Customer outsourcing the management of external staff (including freelancers, independent contractors and temporary employees) to an external recruitment provider.

Other people Yes Talent may contact – may include candidates and emergency contacts and Yes Talent Personnel references. We will only contact them in appropriate circumstances.

Potential Candidates – candidates with whom Yes Talent has had no previous contact but who Yes Talent reasonably considers to be interested in our services and, in particular, in being considered for any roles advertised or promoted by Yes Talent, including positions permanent, part-time and temporary roles and independent work roles with Yes Talent Clients.

Recruitment Process Outsourcing (EPR) Services (RPO) – complete or partial outsourcing of the recruitment process of permanent employees to a recruitment provider.

Personnel – includes employees, former employees, interns and former interns involved (or who have accepted an offer to become involved) directly in Yes Talent’s activity, as well as certain employees currently or previously involved in the activity of providing services to Yes Talent (although they are not considered employees). For these purposes, we also include Yes Talent employees involved in work on client sites in accordance with the terms of EPR or PSG agreements. For clarity, “Personnel” does not include candidates hired by Yes Talent for the purpose of being placed with clients not covered by an EPR/PSG contract. These candidates are treated in the same way as Yes Talent candidates and are covered by this Privacy Policy. Likewise, independent contractors and consultants performing services for Yes Talent are covered by the definition of a “Supplier” for the purposes of this Privacy Policy.

Suppliers – refers to partnerships and companies (including sole traders) and non-standard workers such as independent contractors and self-employed people, who provide services to Yes Talent. In some circumstances, Yes Talent will subcontract the services it provides to Clients or third party suppliers who perform the services on Yes Talent’s behalf. In this context, suppliers who are individual contractors, self-employed or employees of suppliers will be treated as candidates for data protection purposes. Please note that in this context, Yes Talent requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections addressed to Candidates) to their employees.

Systems – includes telephones, computers, Internet and Wi-Fi systems, software and portals, accounts and/or networks owned, controlled or used by Yes Talent to transmit, make and/or receive communications or otherwise used in the course of the Yes Talent activity, including candidate portal software and CRM systems.

Temporary Relationship – this means our contractual relationship with Temporary Workers while they are directly hired by us. As defined by the Temporary Work Law (Law No. 6,019/1974).

Temporary Workers – individuals who are employed or contracted by Yes Talent for the purpose of carrying out temporary work for a Client. If you are a Temporary Worker, we will also continue to process your personal data as a Candidate for the duration of your temporary work and thereafter, in accordance with the terms of this Privacy Policy. As defined by the Temporary Work Law (Law No. 6,019/1974).

Website Users – anyone who accesses any of the Yes Talent websites.

[1] Natural person to whom the personal data that is subject to processing refers.