Privacy Notice - Axians Portugal Recruitment and Employer Branding
Date of publication: 01-07-2026
This Privacy Notice explains how Axians Portugal group companies and related Axians entities process personal data in connection with recruitment and employer branding carried out through our career site (the “Career Site”) and related sub-sites, and related applicant tracking system (“ATS”) activities, including the use of artificial intelligence (“AI”) features made available by Teamtailor. It applies to:
Visitors to the Career Site (“Visitors”).
Individuals who connect with us via our Career Site to create a profile and to receive information about current or future vacancies or opportunities (“Connecting Candidates”).
Individuals who apply for a position with us, via our Career Site or third-party services (”Applying Candidates”).
Individuals whose profiles we source from public or professional sources (e.g., LinkedIn, employer websites) because we believe their profile may be of interest for current or future vacancies (“Sourced Candidates”).
Individuals whose profiles are referred to us by our employees or partners because they believe the profile may be of interest for current or future vacancies (“Referred Candidates”).
Individuals listed as references by Candidates (“References”).
Employees, contractors or business contacts who refer candidates or participate in recruitment activities, such as interviewers, hiring managers and ATS users, to the extent their personal data is processed in the platform (“Recruitment Users”).
When we use the term “Candidate” in this Privacy Notice, we mean any of Connecting Candidates, Applying Candidates, Sourced Candidates, and Referred Candidates, unless stated otherwise.
This Notice also describes your rights and how to exercise them, and includes regional supplements for Brazil, the United Kingdom and the United States in Section 13, which apply where relevant.
1. Who is responsible for your data and how to contact us?
When we say “Axians”, “we” or “us” in this Privacy Notice, we refer to the Axians Portugal group companies and related entities recruiting through this Career Site or through the relevant sub-sites. The employing entity or recruiting entity named in each job post is the organisation responsible for deciding why and how your personal data is processed (“controller” under the GDPR or applicable data protection law) for your application.
For general Connect profiles or talent-pool registrations made on a specific sub-site, the Axians entity operating that sub-site acts as the responsible organisation until your profile is linked to a specific position or opportunity with a named employing or recruiting entity.
You can contact Axians about privacy matters at privacidade.axianspt@axians.com. You can contact our Data Protection Officer (“DPO”) at dpo.axianspt@axians.com. Postal address for DPO correspondence: Edifício Atlantis, Avenida Dom João II, 44 C, Piso 5, 1990-095 Lisboa, Portugal.
The registered office and contact details of the employing or recruiting entity for a given vacancy are displayed in the job post and in the footer of the corresponding sub‑site, and may differ by country (e.g., Portugal, Luxembourg, United Kingdom, Brazil, United States).
2. What personal data do we process?
All individuals
Device information - If you visit our Career Site, we will collect information about your device, such as IP address, browser type and version, session behaviour, traffic source, screen resolution, preferred language, geographic location, operating system and device settings/usage.
Technical and statistical data - If you visit our Career Site, we will collect technical and statistical data about how you use the site, such as information about which URLs you visit, and your activity on the site.
Communications data - We will collect and store your communications with us, including the information you provided in the communication. This may include the content of emails, messages on social media, the information you add to your account with us, surveys, etc.
Contact details - Such as your name, email address, telephone number and postal address.
Candidates
Application data - Information you provide to apply or include in your candidate profile, such as your CV, cover letter, work samples, letters of recommendation, education, qualifications, professional experience, skills, certifications, language skills and the names/contact details of the references you choose to list.
Recruitment process data - Information created during the recruitment process, such as interview notes, assessments and test results, evaluations against role criteria, salary or rate expectations, availability, candidate status, interview recordings and transcripts, meeting summaries and AI-generated or AI-assisted recruitment outputs.
Information provided by references - Information we receive from the persons you have listed as your references and, where applicable, from our employees or partners' referrals or other referrers.
Public professional profile data - Information we collect about you from public sources related to your professional experience (e.g., LinkedIn, your current employer’s website), in accordance with Section 3 (sources).
Recruitment Users
Recruitment platform user data - If you are an employee, contractor or business contact who refers candidates or participates in recruitment activities, including as an interviewer, hiring manager or ATS user, we may process your name, professional contact details, role, permissions, activity logs, comments, evaluations, interview notes, referrals submitted and other actions performed in the platform.
Special category data and sensitive information
We do not request special category data or sensitive information unless it is necessary and lawful for a specific recruitment purpose. You should avoid including information such as health data, racial or ethnic origin, political opinions, religious beliefs, trade union membership, biometric data, sexual orientation, criminal record information or other sensitive information in your application unless specifically requested and legally justified. If such information is provided, we will process it only where permitted by applicable law.
3. Where do we receive your personal data from?
All individuals
From the Career Site. If you visit our Career Site, we will collect technical and statistical information about how you use the Career Site, and information from your device.
Directly from you. Most of the information we process about you we receive directly from you, for example, when you apply for a position with us or connect with us. You can always choose not to provide us with certain information. However, some personal data is necessary in order for us to process your application or provide you with the information you request to get from us.
References
From the person for whom you are a reference. If a Candidate lists you as their reference, we will collect your contact details from the Candidate to be able to contact you.
Candidates
From public sources. We may collect limited professional information about you from public or professional sources, such as LinkedIn or the website of your current employer, where this is relevant and proportionate for recruitment purposes.
From referrals. We may receive information about you from Axians employees, contractors, business partners or other referrers where they believe your profile may be relevant for current or future vacancies or other professional opportunities. Referrers should only provide information that is relevant, accurate and appropriate for recruitment purposes.
From your references. If you provide us with references, we may collect information about you from them.
Data we create ourselves or in cooperation with you. Information about your application and profile is usually created by us, or by us in cooperation with you, during the recruitment process. This may, for example, include notes from interviews with you, assessments and test results, evaluations against role criteria, meeting summaries and other recruitment process data.
Where we have not obtained your personal data directly from you, we will provide you with the information required by applicable data protection law within the applicable timeframe.
4. For what purposes and on what legal bases do we process your personal data?
Protect and enforce our rights, interests and the interests of others, for example in connection with legal claims.
Affected individuals: The individual(s) affected by the legal issue - this may include persons from all categories of individuals listed above.
Categories of personal data used: The categories of personal data relevant to the legal issue, which may include any of the categories listed above.
Legal basis: The legal basis depends on the specific context but will normally be either that the processing is necessary for compliance with a legal obligation to which we are subject; or a balancing of interests, based on legitimate interests pursued by us or by a third party.
Share your personal data with other recipients, for the purposes mentioned in this Section and Section 5 below.
Affected individuals: Varies depending on the purpose of sharing, see Section 5 below.
Categories of personal data used: The categories of personal data necessary for the relevant sharing purpose.
Legal basis: When sharing your personal data with our service providers and with our group companies: A balancing of interests, based on our legitimate interest in creating an effective, smooth and thorough recruitment process for Axians and for our Candidates. When sharing your personal data with authorities, other public actors or otherwise to parties involved in legal proceedings: See the headline just above. Where we share your personal data with clients or prospective clients in connection with client service opportunities, see the relevant purpose below and Section 5.
Collect information about your use of the Career Site, using cookies and similar technologies, as described in our Cookie Policy.
Affected individuals: Visitors.
Categories of personal data used: Device information.
Legal basis: For necessary cookies, a balancing of interests, based on our legitimate interest in being able to provide our Career Site to those visiting it. For cookies used for all other purposes: Your consent. We only place non‑essential cookies with your prior consent, which you can withdraw at any time via the cookie banner or the “Manage cookies” link.
Ensure the security and proper functioning of the Career Site.
Affected individuals: Visitors.
Categories of personal data used: Device information; Technical and statistical data.
Legal basis: A balancing of interests, based on our legitimate interest in providing a safe, secure and properly functioning Career Site.
Analyse how the Career Site and its content is being used and is performing, to get statistics and to improve operational performance.
Affected individuals: Visitors.
Categories of personal data used: Device information; Technical and statistical data.
Legal basis: Your consent, where analytics cookies or similar technologies are not strictly necessary.
Provide you with updates about vacancies and relevant professional opportunities.
Affected individuals: Connecting Candidates and Candidates who have consented to future opportunities or relevant recruitment communications.
Categories of personal data used: Contact details; Communications data.
Legal basis: Your consent where you subscribe to future opportunities, talent pool communications, job alerts or similar recruitment communications. In limited cases, we may rely on a balancing of interests to contact you about a specific role or opportunity that is directly relevant to your professional profile, provided that you can object at any time.
Review profiles and applications sent to us. This also includes communicating with you about your application and profile.
Affected individuals: Connecting Candidates; Applying Candidates.
Categories of personal data used: Contact details; Application data; Communications data; Recruitment process data; and, where relevant, Information provided by references.
Legal basis: Taking steps at your request before entering into a possible employment, contractor or assignment-related relationship with Axians. Where not strictly necessary for that purpose, the legal basis is a balancing of interests, based on our legitimate interest in managing an effective and appropriate recruitment process.
Collect and evaluate your professional profile on our own initiative or following a referral. This also includes communicating with you regarding your profile.
Affected individuals: Sourced Candidates; Referred Candidates.
Categories of personal data used: Contact details; Application data; Public professional profile data; Information provided by references or referrers; Communications data; and Recruitment process data.
Legal basis: A balancing of interests, based on our legitimate interest in finding the best possible candidate for open positions with us. We only source information that is relevant to your professional profile and potential recruitment opportunities. Where we have not obtained your data directly from you, we provide the required transparency information within the applicable timeframe and offer an easy opt-out.
Contact you directly about future vacancies and relevant professional opportunities (talent pool).
Affected individuals: Candidates.
Categories of personal data used: All the categories of personal data listed above may be used for this purpose.
Legal basis: Your consent.
Record the interview(s) with you.
Affected individuals: Candidates.
Categories of personal data used: Communications data and Recruitment process data, including interview recordings, transcripts and meeting summaries.
Legal basis: Your consent. We will inform you before recording or transcribing an interview.
Ask you to complete the test(s) relevant for the position you are considered for, and evaluate the results of the tests.
Affected individuals: Candidates.
Categories of personal data used: Application data and Recruitment process data.
Legal basis: A balancing of interests, based on our legitimate interest in creating an effective, smooth and thorough recruitment process for Axians and for our Candidates. Where a test or assessment is strictly necessary for a role or opportunity you applied for, the legal basis may also be taking steps at your request before entering into a possible employment, contractor or assignment-related relationship with Axians.
Contact you to ask for your participation in surveys.
Affected individuals: Candidates.
Categories of personal data used: Contact details; Communications data; and, where relevant, Recruitment process data.
Legal basis: A balancing of interests, based on our legitimate interest in creating an effective, smooth and thorough recruitment process for Axians and for our Candidates.
Contact a Reference to ask the Reference to provide information about a Candidate, and evaluate the information that the Reference provides.
Affected individuals: References, Candidates.
Categories of personal data used: For References: Contact details; Communications data. For Candidates: Information provided by References.
Legal basis: A balancing of interests, based on our legitimate interest in creating an effective, smooth and thorough recruitment process for Axians and for our Candidates.
Assess and manage your suitability for client service opportunities.
Affected individuals: Candidates.
Categories of personal data used: Application data and recruitment process data.
Legal basis: Where the processing relates to a role or opportunity you applied for, the legal basis is taking steps at your request before entering into a possible employment, contractor or assignment-related relationship with Axians. Where not strictly necessary for that purpose, the legal basis is a balancing of interests, based on our legitimate interest in assessing candidates for services provided by Axians to clients or prospective clients. Where we consider you for future client service opportunities, we rely on your consent.
5. Whom do we share your personal data with?
Our service providers. We share your personal data with our suppliers who provide services and functionality in our employer branding and recruitment process. For example, this includes recruitment service providers and the supplier of our Career Site and related applicant tracking system. This includes Teamtailor AB, which provides the Career Site and ATS platform and acts as our processor. Teamtailor AB may use approved sub-processors to provide the platform and related services.
Our group companies. We share your personal data with our group companies when they provide us with services and functionality for our employer branding and recruitment process, such as access to particular systems and software. If another Axians Portugal group entity or related Axians group entity is the prospective employer for a role you apply to, we may share your data with that entity for recruitment purposes under this Notice.
Internal recruitment teams and authorised users. Your personal data may be accessed by Axians employees, contractors and other authorised users involved in the recruitment process, where necessary for their role, such as HR teams, recruiters, hiring managers, interviewers, business unit managers and technical reviewers.
Companies providing cookies on the Career Site. If you consent, cookies are set by companies other than us, which will use the data collected by these cookies in accordance with their own privacy policy. You can find information about which cookies this applies to in our Cookie Policy.
To authorities and other public actors - when we are ordered to do so. We will share your personal data with authorities and other public actors when we have a legal obligation to do so. This may include labour, tax, immigration, equality, data protection, judicial or law enforcement authorities.
To parties involved in legal proceedings. If needed to protect or defend our rights, we share your personal data with public authorities or with other parties involved in a potential or existing legal proceeding. This can, for example, be in the case of discrimination claims.
Mergers and acquisitions. In connection with a potential merger, sale of company assets, financing, or acquisition of all or part of our business by another company, we may share your personal data with other parties involved in the process.
Axians clients and prospective clients. Where relevant to a client service opportunity, we may share limited and relevant candidate information with Axians clients or prospective clients, subject to data minimisation and confidentiality safeguards, so that they can assess your suitability for a project, service, tender, assignment or opportunity.
6. When do we transfer your personal data outside of the EU/EEA, and how do we protect it then?
We always strive to process your personal data within the EU/EEA area where possible.
However, some of our service providers process your personal data outside of the EU/EEA. We also use suppliers whose parent company, or whose subcontractor’s parent company, is based outside the EU/EEA. In these cases, we have taken into account the risk that the personal data may be disclosed to countries outside the EU/EEA, for example because of an authority request.
In cases where another recipient of your personal data (as described in Section 5 above) is based outside the EU/EEA, this will also mean that your personal data is transferred outside the EU/EEA. This may include Axians or group entities, candidates, service providers, sub-processors, integrations, clients or prospective clients located in countries such as the United Kingdom, Brazil, the United States or other countries outside the EU/EEA.
When we, or one of our suppliers, transfer your personal data outside the EU/EEA, we will ensure that a safeguard recognized by the GDPR is used to enable the transfer. We use the following safeguards:
A decision by the EU Commission that the country outside of the EU/EEA to which your personal data is transferred has an adequate level of protection, which corresponds to the level of protection afforded by the GDPR. In particular, we rely on the EU Commission’s adequacy decision for the US via the so-called EU-US Data Privacy Framework, where the recipient is validly certified, and the transfer falls within the scope of that certification. We may also rely on the EU Commission’s adequacy decision for the UK.
Entering into the EU Commission’s standard clauses with the recipient of the personal data outside the EU/EEA. This means that the recipient guarantees that the level of protection for your personal data afforded by the GDPR still applies, and that your rights are still protected. Where appropriate, we may also carry out transfer risk assessments and implement supplementary measures.
Where personal data is transferred from the United Kingdom, we use transfer mechanisms recognised under UK data protection law, such as UK adequacy regulations, the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, as applicable. Where personal data is transferred from Brazil, we apply the safeguards required under applicable Brazilian data protection law, including contractual safeguards or other lawful transfer mechanisms where applicable.
When your personal data is transferred outside the EU/EEA, we also implement appropriate technical and organizational safeguards to protect the personal data in case of a disclosure. Exactly which protective measures we implement depends on what is technically feasible and sufficiently effective for the particular transfer.
If you want more information about the cases in which your personal data is transferred outside the EU/EEA, you can contact us using the contact details in Sections 10 and 11 below.
7. For how long do we keep your personal data?
All individuals
If we process your personal data for the purpose of being able to protect and enforce our rights, we will keep your personal data until the relevant legal issue has been fully and finally resolved.
Visitors
We keep personal data collected through cookies and similar technologies for the periods set out in our Cookie Policy.
Candidates
If you are a Connecting Candidate or Applying Candidate, we keep your personal data for twenty-four (24) months after the point in time that you connected with us or applied for a position with us. After this time period, we will ask you again whether you give us your permission to keep it for another twenty-four (24) months. If you do not give us permission to keep your data, we will delete it after one hundred (100) days.
If you apply for a specific role but do not consent to being considered for future opportunities, we will not use your candidate profile to contact you about future vacancies or future client service opportunities. However, we may still retain your data for the period described above where this is necessary for managing your specific application, recruitment record-keeping, compliance, responding to your requests or establishing, exercising or defending legal claims.
If you are a Sourced Candidate or Referred Candidate, we will contact you to inform you that we have collected your data, and that you can ask us to delete it. If you ask us to delete your data, we will do so as soon as possible and at least within thirty (30) days. Otherwise, we will keep your data for twenty-four (24) months. After this time period, we will contact you again and ask whether you give us your permission to keep it for another twenty-four (24) months.
If you are hired, we will keep your personal data during your employment, for other purposes than those stated above, which you will be informed of once you have started your employment with us.
References
We keep your personal data for as long as we keep the personal data of the Candidate for whom you acted as a reference, unless we need to keep it for longer to comply with legal obligations or to establish, exercise or defend legal claims.
8. AI Services
We use services that utilise artificial intelligence (AI) (“AI Services”) when processing personal data for the following purposes:
1. Reviewing profiles and applications sent to us. This also includes communicating with you about your application and profile.
2. Collecting and evaluating your professional profile on our own initiative. This also includes assessing and communicating with you regarding your profile.
When processing personal data for these purposes, we use AI Services to:
Generate a summary of the candidate's resume.
Assess a candidate’s profile against criteria set or approved by us, and help organise or prioritise profiles based on how those criteria appear to be met.
Suggest existing candidates in our candidate database who may be relevant for a vacancy or opportunity.
Create first drafts of messages to Candidates, e.g. when a Candidate is not selected for a position.
Draft or suggest job descriptions, job application questions, interview questions, skills, traits and other recruitment content for human review.
Flag potentially discriminatory job application questions for human review.
Translate recruitment questions or recruitment content.
Summarise video meetings held with Candidates, based on the transcript from the video meeting, when there is such a transcript.
Auto-complete particular pre-set interview questions based on the transcript from the video meeting, when there is such a transcript.
Support Axians users through AI-assisted search or Q&A features, where enabled, based on information available in the candidate profile and accessible to the relevant user.
3. Record and transcribe the interview(s) with you.
When processing personal data for this purpose, we use AI Services to:
Transcribe the recording of our interview with a Candidate.
4. Consider you for and contact you about future vacancies and other professional opportunities, including client service opportunities.
When processing personal data for this purpose, we use AI Services to:
Assess which Candidates in our existing pool of Candidates could be suitable for a particular position or opportunity.
The service providers that we use for these AI Services act as our data processors. This means that they may process your personal data only on our instructions and are not allowed to use your personal data for any purposes of their own, e.g. to train their AI models.
We use AI Services to support our own human decision-making, but we do not rely only on AI Services in making decisions that are important for a Candidate’s progress in the application process - see Section 9 below. AI outputs may be incomplete or inaccurate and must be reviewed in context by authorised Axians users before being relied on. We do not make hiring, rejection, interview selection or shortlisting decisions solely by automated means.
Where candidate assessment, matching or suggestions are used, the criteria are defined or approved by Axians users. Axians users should not use criteria that are discriminatory, irrelevant, disproportionate or based on protected characteristics.
Some AI functionalities used for the recruitment process may fall under the “high‑risk” category for employment and recruitment under the EU AI Act. Where such AI functionalities are used in your recruitment process, you may be subject to the use of an AI system that assists Axians users in the recruitment process. We maintain meaningful human oversight, staff training, logging where available, access controls, monitoring of outputs, and use the systems in line with the provider’s instructions. We do not use emotion recognition, facial recognition, or biometric categorisation for recruitment purposes. We also do not intentionally use AI to infer sensitive characteristics.
9. Profiling and automated decision-making
Some recruitment activities may involve profiling, meaning automated processing used to evaluate certain personal aspects relating to a Candidate, such as professional experience, skills, qualifications, application answers, suitability for a vacancy or potential match with future vacancies or client service opportunities. This may occur, for example, when we use:
AI Services to assess which Candidates in our existing pool of Candidates could be suitable for a particular position or opportunity;
automatic triggers or filters, where enabled, based on preset conditions, such as location, resume content, skills or answers to questions; or
assessment of profiles against criteria set or approved by us, and organisation or prioritisation of profiles based on how those criteria appear to be met.
This involves profiling under the GDPR and, where relevant, applicable data protection law.
We do not make decisions based solely on automated processing, including profiling, where those decisions would produce legal effects concerning you or similarly significantly affect you, such as a final decision to reject you, hire you, interview you or progress you to a materially different stage of the recruitment process. Such decisions involve meaningful human review by authorised Axians users.
If you want information about whether we have performed any profiling of your personal data, and information about that profiling where applicable, you can request this information from us - see “Right to access your personal data” in Section 10 below.
If we have performed profiling of your personal data based on a balancing of interests, you can object to this profiling - see “Right to object against our processing of your personal data” in Section 10 below.
10. What rights do you have, and how can you exercise them?
In this section, you will find information about the rights you have when we process your personal data. As described below, some of the rights only come into play when we process your personal data under a particular legal basis.
If you want to exercise any of the rights listed here, we suggest that you:
Visit the Data & Privacy page on our Career Site, where we offer features to let you exercise your rights;
Log in to your account with us, where you can use the settings in the account to exercise your rights; or
Contact us directly at privacidade.axianspt@axians.com.
Right to be informed
You have the right to be informed about how we process your personal data. You also have the right to be informed if we plan to process your personal data for any purpose other than that for which it was originally collected.
We provide you with such information through this privacy notice, through updates on our Career Site (see also Section 12 below), and by answering any questions you may have for us.
Right to access your personal data.
You have the right to know if we process personal data about you, and to receive a copy of the data we process about you. In connection with receiving the copy of your data, you will also receive information about how we process your personal data.
Right to access and to request a transfer of your personal data to another recipient (“data portability”).
You can request a copy of the personal data relating to you that we process for the performance of a contract with you, or based on your consent, in a structured, commonly used, machine-readable format. This will allow you to use this data somewhere else, for example to transfer it to another recipient. If technically feasible, you also have the right to request that we transfer your data directly to another recipient.
Right to have your personal data deleted (“right to be forgotten”).
In some cases, you have the right to have us delete personal data about you. This is, for example, the case if it’s no longer necessary for us to process the data for the purpose for which we collected it; if you withdraw your consent; if you have objected to the processing and there are no legitimate, overriding justifications for the processing. (For the separate right to object, see below).
Right to object against our processing of your personal data.
You have the right to object to the processing of your personal data, which is based on our legitimate interest, by referencing your personal circumstances. You can object at any time to processing for direct marketing purposes (e.g., job alerts/newsletters), and we will honour that objection without delay.
Right to restrict processing.
If you believe that the personal data we process about you is inaccurate, that our processing is unlawful, or that we don’t need the information for a specific purpose, you have the right to request that we restrict the processing of such personal data. If you object to our processing, as described just above, you can also request us to restrict processing of that personal data while we make our assessment of your request.
When our processing of your personal data is restricted, we will (with the exception of storage) only process the data with your consent or for the establishment, exercise or defence of legal claims, to protect the rights of another natural or legal person, or for reasons relating to an important public interest.
Right to rectification.
You have the right to request that we rectify inaccurate information, and that we complete information about you that you consider incomplete.
Right to withdraw your consent.
When we process your personal data based on your consent, you have the right to withdraw that consent at any time. If you do so, we will stop processing your data for the purposes you’ve withdrawn your consent for. However, it doesn’t affect the lawfulness of processing that was based on your consent before it was withdrawn. You can withdraw consent via links in our emails, your account settings, the “Manage cookies” link, or by contacting us.
Right not to be subject to solely automated decisions.
Where applicable, you have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you, unless permitted by law and subject to appropriate safeguards. Axians does not make such solely automated recruitment decisions.
Right to raise a complaint.
If you have complaints about our processing of your personal data, you can raise a complaint with the data protection authority in Portugal. You can find their contact details here.
You can also lodge a complaint with your national data protection authority, which you can find listed here if you are based in the EU. If you are based in the UK, you can lodge a complaint with the Information Commissioner’s Office, here.
11. Where can you turn with comments or questions?
If you want to get in touch with us to exercise your rights, or if you have any questions, comments or concerns about how we handle your personal data, you can reach us by sending an email to privacidade.axianspt@axians.com.
Axians also has a Data Protection Officer (DPO) who monitors our compliance with applicable data protection law and can be reached by email at dpo.axianspt@axians.com.
12. Updates to this Privacy Notice
We update this Privacy Notice when necessary - for example, because we start processing your personal data in a new way, because we want to make the information even clearer to you, or if it’s necessary to do so in order to comply with applicable data protection laws.
We encourage you to regularly check this page for any changes. You can always check the top of this page to see when this privacy notice was last updated.
13. Regional supplements
This Section applies only where the data protection laws of the relevant jurisdiction apply to the processing of your personal data. If there is any inconsistency between this Section and the rest of this Privacy Notice, this Section applies to the extent required by applicable local law.
13.1 Brazil
Where Brazilian data protection law applies, we process your personal data in accordance with the Lei Geral de Proteção de Dados (“LGPD”).
Depending on the context, the legal bases for processing may include consent, performance of preliminary procedures related to a contract, compliance with legal or regulatory obligations, legitimate interests, exercise of rights in judicial, administrative or arbitral proceedings, and other legal bases permitted by the LGPD.
You may have rights under the LGPD, including rights to confirm processing, access data, correct incomplete or inaccurate data, anonymise, block or delete unnecessary or excessive data, request portability, obtain information about sharing, withdraw consent, request deletion of data processed based on consent, and request review of decisions made solely by automated processing, where applicable.
Where your personal data is transferred internationally from Brazil, we apply the safeguards required under applicable Brazilian data protection law, including contractual safeguards or other lawful transfer mechanisms where applicable.
You may lodge a complaint or file a data subject petition with the Brazilian National Data Protection Authority (“ANPD”), where applicable.
13.2 United Kingdom
Where UK data protection law applies, references to the GDPR in this Privacy Notice include the UK GDPR and the UK Data Protection Act 2018, as applicable.
You have rights under UK data protection law, including rights to access, rectify, erase, restrict or object to processing of your personal data, data portability where applicable, and rights relating to automated decision-making.
Where your personal data is transferred from the United Kingdom to another country, we use transfer mechanisms recognised under UK data protection law, such as UK adequacy regulations, the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, as applicable.
You may lodge a complaint with the UK Information Commissioner’s Office.
13.3 United States
Where United States privacy laws apply, additional state-specific privacy rights may be available depending on your state of residence and the context of the recruitment activity.
These rights may include rights to know or access personal information, correct inaccurate personal information, delete personal information, obtain a copy of personal information, opt out of certain disclosures or uses, limit certain uses of sensitive personal information, and not be discriminated against for exercising privacy rights, where applicable.
For candidates in the United States, we may process the categories of personal information described in this Privacy Notice for recruitment, candidate evaluation, communications, compliance, security, analytics and legal purposes.
We do not sell candidate personal information. We do not use candidate personal information for cross-context behavioural advertising unless expressly disclosed and permitted by applicable law.
Where state law requires additional notices, including a California applicant privacy notice, we will provide them at or before the point of collection.