Privacy and Data Usage Policy

Last updated: 06th of October, 2025

Our mission is to connect candidates from around the world with companies that use our system to publish and manage their recruitment processes.

Doing this with transparency about which data is used and how companies use it is extremely important. That's why we value and respect this information. The following guidelines are designed to protect your data and, depending on your jurisdiction, describe your rights in accordance with applicable data protection laws.

This Policy clarifies the general conditions for collecting, using, storing, and other forms of processing and protecting personal data on our website www.empregare.com (“Website”), subdomains https://companyName.empregare.com (“Hotsites”), and our Empregare mobile application (“App”), in accordance with current Brazilian legislation on privacy and personal data protection, including, but not limited to, Law No. 12,965 of April 23, 2014 and Decree No. 8,771 of May 11, 2016 (“Marco Civil da Internet”) and Law No. 13,709 of August 14, 2018 (“General Data Protection Law” or “LGPD”).

To maintain direct contact with you, Empregare has designated a Data Protection Officer (“DPO”) to manage our communication channel:

By using, interacting, or registering on our Website, Hotsite, and App, you freely, knowingly, unequivocally, expressly, and fully agree to this Policy. We recommend reading it carefully.

Presentation

We are a recruitment and selection software (ATS and Job Board) where candidates register their resumes and apply for job openings posted by Empregare’s client companies, aiming to be found and/or invited to participate in their recruitment processes.

Our registered users (candidates) share their professional information or identity, find job opportunities, and apply to them, making their data available so companies can contact them for matching job positions.

Considering that the Empregare.com software acts as a bridge between companies and candidates, the candidate data is filled in and made available by them for the companies.

TARGET AUDIENCE

This Privacy Policy applies to Candidates who:

• Access the Empregare Website, Hotsite and/or App;
• Register on the Empregare Website, Hotsite and/or App;
• Purchase digital products on the Empregare Website, Hotsite, and/or App;
• Contact Empregare.

1. What types of information do we collect?

Important: You are not required to provide us with your information. However, without providing certain requested information, you may not be able to access some features.

The nature and purpose of the personal data we collect may vary depending on the area of the Site you access (e.g., when you provide your information to apply for a job or simply when contacting us).

Within the limits permitted by applicable law, Empregare may process the following personal data that you provide:

1.1 CANDIDATE DATA

a) Personal data for filling out the résumé:

b) Sensitive personal data in the résumé completion:

c) Personal data for product acquisition:

2. What do you do with your information

By registering the information listed in item 1 above, the candidate acknowledges that they are making such data available to all companies that are Empregare clients. Candidates may set privacy levels on the Empregare website (as described in item 8 of this Policy).

The candidate may also apply to recruitment processes, respond to company questionnaires and requests, and export their resume to Word or PDF format for submission to non-client companies of Empregare.

The candidate understands that if they do not fill in key data in their resume required for the recruitment process, the company advertising the job may block their participation until the missing information is completed. This feature allows companies to select resumes that align with the advertised job.

If you choose to use the résumé analysis or job interview simulation tools, your personal and résumé data will be processed by these tools to generate insights, such as identifying the strengths and weaknesses of your résumé and simulating interview questions. This data will be used only to improve your experience and preparation and will not be shared with companies.

The use of the tools described above is exclusively for guidance and support purposes. The acquisition and use of these resources do not grant any special prerogative, nor do they guarantee a standout résumé, success in selection processes, or professional placement/re-placement. The responsibility for performance and for the results obtained lies entirely with the user.

3. What do others do with your information?

By registering your résumé on the platform, it will be accessible for consultation by all companies according to the privacy criteria defined by you. The companies, according to their respective plans, may request proofs, tests, documents, reports, among other various documents for recruitment and selection purposes. It should be noted that your access password is individual, private, should not be shared, and companies will not have access to it.

Hiring companies that conduct selection processes through the platform assume the position of independent Controllers of personal data, being responsible for the processing they carry out in accordance with their own Privacy Notices or Policies. Under these conditions, such companies may use the information for legitimate purposes related to recruitment, selection, and talent management, as well as for contacting candidates by e-mail, WhatsApp, or LinkedIn, and for eventual inclusion in their Talent Pools, provided that the limits of applicable law are respected and the data is lawfully obtained.

The data processed within the scope of selection processes may be stored in the databases of the respective companies and made available exclusively to managers, consultants, or other professionals responsible for the analysis and conduction of the recruitment for the positions you applied for, ensuring the adoption of appropriate technical and organizational measures for the protection of this information, in compliance with the current legislation on personal data protection.

For more information, we recommend reading the Privacy Notices or Policies of the Client companies whose positions you want to apply for.

4. How do we use this information?

How we use the data depends on how you configured and opted to set your privacy level, as described in item 8 of this privacy policy.

When applying for jobs or making your resume public, all Empregare client companies may access your resume data.

In addition to the purposes outlined in item 1 of this Policy, information collection aims to maintain and improve the services offered and provide a better experience for you.

Thus, when necessary, the collected data may be used for the following purposes:

1. To connect candidates with hiring companies, ensuring the effectiveness of our platform and services;
2. To make your data and other information available to companies seeking professionals in the job market;
3. To enhance our relationship with you by informing you about news, features, content, updates, and events;
4. To promote our products and services or those of our clients;
5. To contact you through your request via our Help Center;
6. To send you promotional messages, marketing content, market research, service feedback, or messages from our partners;
7. To improve our Website, services, and those of our clients;
8. To comply with requests from government authorities, such as subpoenas, court orders, or legal processes, to establish or exercise legal rights or protect our property;
9. To defend against legal claims or as required by law;
10. To investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical or digital safety of any person and of Empregare, or as otherwise legally required, within the limits permitted by applicable law.

7. When is this information shared?

The information contained in the resume is made available to all companies registered in our database, along with their respective managers or, in the case of consultancies, to their clients, according to the privacy level selected by the candidate as described in item 8 of this Policy.

The information processed by the AI tools will be shared only with the tool providers for the execution of the contracted services. No analysis or report information will be shared with the advertising companies.

When necessary to achieve the purposes described in this Policy, Empregare may share your personal data with the third parties listed below to ensure the proper delivery of the services offered, the security of your personal data storage, and an improved experience with Empregare. Whenever data sharing is conducted, it will be within the limits and purposes of our business, in line with the intended purpose of data processing and in accordance with applicable legal authorization. Your data may be shared with:

1. The system of the company where the candidate may be hired.
2. Third-party software platforms and tools for managing the services provided by Empregare.
3. IT service providers, computing infrastructure companies, and security-focused service companies that support Empregare’s information security and technology improvements.
4. Marketing and communication tools used by Empregare or its clients to keep candidates informed about job-related activities or professional development content.
5. Companies that will process the payments for products purchased by candidates
6. Tax authorities and government, law enforcement, public, and judicial entities for handling complaints, investigations, legal actions, and to comply with legal, regulatory, or tax obligations.

8. How can I manage information about myself?

In your user panel, you can choose how you want to use your account and share your data using the following resume privacy levels:

• Public
  The resume is visible to all companies, agencies, or consultancies advertising on the site when they perform searches.
• Private
  Your contact information will only be available in job applications or when requested in advance by the hiring companies. Only your first name, age, city, and resume data will be visible.
• Invisible
  Your resume will not be found by companies and you will not receive alerts from our system via email or app. Companies will only have access to your information for jobs you apply to, in which case you will receive emails related to those jobs.

9. Rules for Account Maintenance, Deactivation, and Deletion

The Empregare website has rules for the maintenance, deactivation, or deletion of registered accounts, ensuring that information will not remain in our database indefinitely.

Empregare's clients include public agencies as well as private companies, and in some cases, their processes are audited, and the information needs to be maintained and recorded.

If a candidate wishes to DEACTIVATE their account and their access to the site, they can do so through their candidate area, and in settings, click on “deactivate account”. By performing this procedure, the candidate agrees to the following:

1. That their résumé and contact information will no longer be available in new résumé searches by companies;
2. That their résumé information, except for contact details, will remain visible to all companies for which they have applied for a position, thus preserving the companies' internal audit processes and indicators;
3. The candidate is aware that they will no longer receive email information about any jobs related to their profile, including information about jobs for which they had already applied;
4. In the case of account deactivation, Empregare reserves the right to keep the résumé information and other data registered on the site in its database for up to 5 (five) years, and the candidate agrees and is hereby aware that due to audit processes and indicators, the deletion of all their information will only occur after this period;

For your information, Empregare has detailed some rules for the DELETION of your account below:

RULE 1:

Empregare may delete candidate accounts automatically, without prior notice, if the candidate:

• completes their registration incompletely (which means it is below 50% (fifty percent) completion according to the candidate dashboard);
• Does not log in again within the 3 months following this registration;
• Is not registered in any selection process;
• Violates the Privacy Policy, the Terms of Use, or the rules of good faith and conduct in the use of the tool in any way.

RULE 2:

• If the candidate completes their registration (which means it is above 50% completion according to the candidate dashboard);
• Is not registered for any job opening;
• Remains for 1 (one) year without logging into the site;

Empregare will send an email to the candidate informing them that their account will be deactivated in 10 (ten) days. If the candidate wishes to keep the account active, they must follow the instructions received by email. If the candidate does not follow the instructions received, the account will be deleted automatically without prior notice.

RULE 3

Empregare will have up to 7 (seven) business days to proceed with the data deletion, if:

• it receives an account deletion request from the candidate;
• the candidate is not registered for any job opening.

RULE 4

• Account deletion request by the candidate;
• And they are registered for a job opening.

The account will initially be deactivated, and after 5 (five) years without the candidate logging in during this period, the account and all data will be permanently deleted, without the need for prior notice.

For all the above cases in which the account is deactivated, if the candidate logs into the site, the system will issue a request for the candidate's agreement to reactivate the account, and with their “agreement,” the account will be re-established, and the deadlines will be reset.

If the candidate has applied for positions linked to companies subject to audit processes or specific legal requirements, the retention period may be longer than mentioned, in compliance with the determinations of the respective hiring company. In such cases, the definitive deletion of the account and personal data will only occur after the applicable requirements have been met.

10. How We Store and Process Personal Data

Empregare stores collected personal data in a secure, controlled environment to meet specific purposes, as outlined in Items 1 and 4 of this Policy. Collected personal data is kept confidential, with strict access controls through authentication mechanisms.

Empregare adopts technical and administrative security measures to ensure all stored data remains protected. Specifically regarding data collected through our Site, it is stored, processed, and protected using best practices in hosting, processing, and backup, according to the data’s sensitivity.

Nevertheless, the Data Subject should be aware that no internet security system is completely invulnerable to unauthorized access. Empregare’s commitment is to adopt recommended protective measures in line with the current state of the art.

11. How We Respond to Legal Requests or Prevent Harm

We may access, retain, and share your information when responding to support requests through our help channels or in response to legal requests (such as subpoenas, court orders, or legal notices) if we believe in good faith that the law requires us to do so.

We may also access, retain, and share information when we believe in good faith that it is necessary to: detect, prevent, or address fraud or other illegal activities; protect ourselves, our services, you, and others (including as part of investigations); or prevent imminent death or physical injury. For example, we may share account reliability data with external partners to prevent fraud and abuse inside and outside our services.

We may also retain information from deactivated accounts to prevent further abuse or violations of our terms.

12. Communication Policy

We strive to avoid sending unsolicited emails and restrict communications to topics relevant or of specific interest to you.

When you provide us with your data, we may contact you using the communication channels you provided.

If you prefer not to receive certain types of communication, you can access the candidate dashboard and choose the communication channels through which you wish to receive announcements, job alerts, and other messages essential for the correct delivery of Empregare’s services.

Please be aware that various scammers attempt to exploit reputable brands to obtain personal information such as passwords and financial details. Empregare WILL NEVER REQUEST YOUR FINANCIAL DATA VIA EMAIL OR PHONE. IF YOU NOTICE ANY SUSPICIOUS BEHAVIOR, PLEASE REPORT IT through the following link: clicking here.

13. International Transfer of Personal Data

Empregare may transfer some of your personal data to service providers (including cloud providers), partners, and companies located abroad, as well as for job postings outside Brazil. When transferring your personal data outside of Brazil, Empregare will take appropriate measures to ensure the adequate protection of your data, in accordance with applicable data protection laws. This includes signing appropriate data transfer agreements with third parties where necessary.

When client companies or job postings are located outside Brazil, you will be informed through the job listing, which will indicate the destination country. Empregare is committed to maintaining the highest standards of data protection and user privacy, complying with broad legal and regulatory requirements such as the LGPD and GDPR. If you do not agree with international data sharing, we advise you not to apply for the job.

14. How You Will Be Notified of Changes to This Policy

Our Website, or any of its tabs and sections, may be unilaterally terminated, suspended, or interrupted by Empregare at any time, without prior notice. In such cases, we will inform you where the relevant information will be available, which you are entitled to access under applicable law.

This Policy may be updated or changed at any time, and you will be notified of such changes via email, notification in the candidate dashboard, or through our mobile applications.

If you do not accept the new version of the Privacy Policy, you will not be allowed to access your account, and Empregare will deactivate your account, in accordance with Rule 2 described in item 9 above, without prior notice.

15. Links to Other Websites

Our Website may contain links or frames to other websites. These links or frames are intended to offer additional benefits to the content and services we provide to the User.

We clarify that including these links on our Website does not mean that Empregare has knowledge of, agrees with, or is responsible for the content of such linked or framed sites. We emphasize that our intention is only to provide links or frames to reputable and trustworthy companies. Empregare is not responsible for the information, products, and services obtained by the User on those sites, nor for the business practices and privacy policies adopted by those companies. Empregare cannot be held liabl...

Since the linked sites are not part of our Website, we do not control, recommend, or endorse those sites, their content, products, services, policies, or privacy practices. We do not have access to the personal data collected and processed by them or to their advertising policies, cookies, and terms of use. Therefore, we recommend carefully reading the privacy policies and terms of third-party sites.

16. How to Contact Empregare in Case of Questions

To maintain direct contact with you, Empregare has designated a Data Protection Officer to manage a communication channel. If you have any questions related to the personal data processing activities under our responsibility, or any questions or comments regarding this Policy, please contact Gabriela Coelho (“Data Protection Officer”) by clicking here.

We will review your request and respond as soon as possible, considering the deadlines and terms established by applicable law. If immediate fulfillment is not possible, we will provide the legal and factual reasons preventing it.

Empregare is not responsible for the accuracy, truthfulness, authenticity, completeness, or timeliness of the data provided by the Data Subject, nor for any misuse of information published or for fraud resulting from the disclosure of personal passwords.

It is your sole responsibility to provide only accurate, truthful, authentic, complete, and updated information, and to maintain the confidentiality of your password, when applicable, by not disclosing it to third parties.

Access our support and user service channel for any additional questions by clicking here.