Recruitment and Selection Plataform Privacy Notice for Candidates

Gupy is deeply committed to privacy and safeguarding your Personal Data. As such, we provide this Privacy Notice, encompassing all essential information on when and why Gupy processes your Personal Data, while also elucidating your rights when you use Gupy Recruitment and Selection as a candidate in selection processes.


Your data is consistently collected in line with this Privacy Notice and in adherence to pertinent data protection laws, notably the General Data Protection Law.

Definitions

Talent Pool: a repository where details of candidate individuals who have previously applied for positions at the Client Company and/or have been invited by the Client Company to join their respective Talent Pools are stored;

Controller: a natural or legal person, public or private, accountable for decisions concerning the processing of personal data. In the context of Gupy Recruitment and Selection, both the Company and Gupy primarily serve as Controllers regarding Candidate Data.

Data: Personal data and/or Sensitive data;

Personal Data: information pertaining to an identified or identifiable natural person;

Sensitive Personal Data: Personal data concerning racial or ethnic origin, religious beliefs, political opinions, union membership, or membership in religious, philosophical, or political organizations, data relating to health or sex life, and genetic or biometric data when linked to a natural person;

Client Company: a company that engages the services offered by Gupy, particularly services related to Gupy Recruitment and Selection;

Data Protection Officer (DPO): an individual appointed by the controller and processor to serve as a communication conduit between the data controller, data subjects, and the National Data Protection Authority (ANPD);

Gupy: GUPY TECNOLOGIA EM RECRUTAMENTO LTDA, registered under CNPJ number 23.514.668/0001-52, headquartered at Avenida Paulista, 1079, Bela Vista, in the city of São Paulo, State of São Paulo, ZIP code 01.311-200. Manager of Gupy Recruitment and Selection;

Gupy Recruitment and Selection: denotes Gupy's Recruitment and Selection Platform, a tool utilized by Client Companies to manage their Selection Processes, featuring artificial intelligence to organize resumes of individuals applying for positions based on their alignment with job requirements;

Artificial Intelligence: a computational system capable of learning and executing tasks typically requiring human intelligence;

LGPD: General Data Protection Law - Law No. 13,709, dated August 14, 2018;

Processor: a natural or legal person, public or private, responsible for processing personal data on behalf of the controller;

Candidate Individuals: individuals who apply and express interest in occupying a particular position or role through selection processes for Client Companies;

Talent Portal: a database where various Client Companies can view your resume and invite you to other selection processes, subject to your consent;

Selection Process: comprises a set of techniques aiding in the selection of the most suitable candidates for a specific job opening. It facilitates the identification of skills, competencies, and profiles most compatible with the position and the company's culture.

Who are we?

Gupy is the proprietor of Gupy Recruitment and Selection and serves as the Controller when processing your personal data.

Who is the Data Protection Officer (DPO)?

Name: Renata Benjamin Gonçalves
E-mail: privacidade@gupy.com.br 

What data is collected? For what purposes? 

Gupy processes  your data to allow you to participate in selection processes conducted by Client Companies that utilize Gupy Recruitment and Selection and to integrate the talent pools of such companies.

We do not collect unnecessary personal data, and we will not process your information in any way other than as specified in this Notice. We take your privacy very seriously and will never sell your data.

TYPE OF DATA  PURPOSES

HOW DATA IS COLLECTED

Identification Data: Full name and/or social name, email, country of origin, CPF (Brazilian tax identification number), phone number, and date of birth. 

Gupy uses this data to register you on the platform, authenticate your identity, contact you, and ensure you are of the minimum age to use our services. If you wish, you can provide the link to your LinkedIn and Facebook profiles.

Additionally, they may be used to:

i) Address matters related to the use of Gupy Recruitment and Selection, including but not limited to, access issues and irregularities in your account;

ii) Invite you to participate in usability surveys for Gupy Recruitment and Selection and satisfaction surveys regarding Selection Processes, suggestions for improvement, and development of new products;

iii) Send marketing or advertising communications according to your interests, in cases where consent is not required;

iv) Share your resume with Gupy's Client Companies through Gupy's Talent Portal, with your consent when requested;

v) Send rich materials and gifts, with explicit and specific consent from the owner, using their address.

These data may also be used by the Client Company to:

i) Invite Candidates previously registered in their Selection Processes, whether ongoing or not, to participate in other open positions that match their profile and skills, always considering the Candidate's benefit and interest in being hired;

ii) Contact you regarding the progress of your Selection Process, to inform you about new vacancies that may be of interest;

iii) Allow you to contact our support or the Client Company to resolve doubts regarding the process;

iv) Allow Client Companies to directly contact you via email or WhatsApp;

v) Allow you to participate in an internal recruitment process.

Provided by the data subject themselves at the time of registration on Gupy Recruitment and Selection.
Professional Data:
Resume data such as academic background, employment history, professional experience, and professional interests. 
We use this data to enable you to build your resume and facilitate the Client Company to recruit and select Candidates based on the criteria they have defined for the positions. Provided by the data subject themselves at the time of applying for the position.

Data for Selection Process:
Responses to additional questions inserted by the Client Company, interview videos, and test results.

The Client Company uses this data according to the criteria it has internally established for the recruitment and selection process.

For the execution of the selection process, the Client Company may:

i) Request additional information that it deems necessary for the process through additional questions, which may be configured by the Client Company as eliminatory;

ii) Request the recording of a video interview (for more information on this step, please refer to the Platform's Terms of Use);

iii) Request that you respond to tests, selected by the Client Company considering the specifics of the position you intend to apply for, such as profile tests and knowledge tests. Such tests may be provided by Gupy or by partner companies, which in this case are responsible for the analysis and result, which are only made available and stored by Gupy;

The information provided through additional questions is collected and processed at the sole decision and responsibility of the Client Company.

Attention! It is possible to reuse test scores, as well as reuse videos.

When the Client Company is a financial institution or an insurance company, in accordance with legal norms and regulations of the Central Bank of Brazil and the Superintendence of Private Insurance - SUSEP, your data may, subject to the internal policies of the Client Company, be collected by such companies for a possible analysis related to illicit practices such as money laundering and terrorism (Circular No. 3978 from BACEN and Circular No. 612/2020 from SUSEP).

Provided by the data subject themselves at the time of applying for the position or during the stages of the selection process.

Navigation Data: Information about your device, records of access to the internet application (such as IP, date, and time), platform usage time, access duration, clicks, and searched terms. We use this data to monitor the operation of Gupy Recruitment and Selection, conduct analyses for improvements, operationalize new products and services, and fulfill legal and administrative obligations.   Automatically collected through cookies and other similar technologies during the use of Gupy Recruitment and Selection. For more information, please refer to our Cookie Notice

Sensitive Data:
Health data (whether you are a person with a disability) and diversity data (gender identity, sexual orientation, color or race, and the most appropriate treatment pronoun for you).

We use this data to:

i) Enable diverse and inclusive hirings for Client Companies. If you declare yourself as a person with a disability, Client Companies may request a medical certificate to validate this information and ensure that Selection Processes for people with disabilities are fair and that inappropriate applications are quickly identified. However, this submission is not mandatory and will be done with your consent, which can also be revoked at any time;

ii) Carry out affirmative actions by Client Companies to promote the hiring and inclusion of people from diverse groups in the job market.

Important: The filling of health data and diversity data is not mandatory, and its use will only be done with your consent, which can be revoked at any time. 

Provided by the data subject on the Platform, with consent.

Companies interested in your profile may also use some of your personal data to invite you via email to register on Gupy Recruitment and Selection and apply for one of its positions, and may enter potential Candidate data into Talent Banks - provided that they are collected in compliance with applicable laws.

Attention! Gupy Recruitment and Selection is FREE for candidates, and Gupy does not charge any fees for your participation in selection or admission processes. Therefore, do not make any payments related to Selection Processes for opportunities received through communication channels and social networks. To learn more about how to prevent job scams and fraud, read the article https://www.gupy.io/blog-do-emprego/vagas-falsas and consult the FAQ of frequently asked questions by clicking here.

Gupy does not receive resumes from candidates to participate in our clients' Selection Processes through means other than Gupy Recruitment and Selection. Therefore, resume files occasionally received by email or other communication channels will be deleted as soon as possible.

We do not tolerate discrimination! 

At Gupy, Candidates are not unlawfully discriminated against in any way, regardless of the personal data collected. However, hiring decisions are made by the Client Company.

What is the legal basis for the use of personal data? 

Depending on the purpose, Gupy may process your data based on legitimate interest or consent. For any purpose where your consent must be collected under the law, data processing will depend on your free and unequivocal expression.

In specific situations, we may base data processing on the execution of a contract, compliance with legal and regulatory obligations, and the regular exercise of rights.

Treatment of Teen Data 

Gupy processes personal data of individuals from 14 years old, considered adolescents by law, for participation in Selection Processes for young apprenticeship positions. Such data is processed in the exclusive interest of the teenager and after their submission.

In this treatment, the need for full protection required by the Child and Adolescent Statute and the Constitution will always be considered, with the aim of promoting the physical, social, moral, and psychological development of the adolescent provided by the apprenticeship contract.

About the use of Artificial Intelligence

How does Artificial Intelligence work?

During the process of posting a new vacancy, the recruiter establishes various essential and desirable requirements, such as education, experience, field of work, whether the position is in-person or remote, among others.

Analyzing such requirements, the profile of the Client Company, the resume, and other information provided by the candidate (in their profile and during registration for that specific process), Gupy's artificial intelligence presents to the recruiter the candidates who have applied for that position, organizing them based on the affinity that such criteria have among themselves, in order to give more opportunities to the most compatible candidates with the position.

This organization of candidates is not static and changes throughout the Selection Process, according to new applications or withdrawals and, especially, with the interaction of the recruiter regarding the resumes, which gives Artificial Intelligence more information about the company's preferences.

It is worth noting that Artificial Intelligence does not eliminate any resumes analyzed, nor does it make approval or rejection decisions regarding them. Every decision made during the Selection Process is made directly by the recruiter and/or the manager responsible for the position.

In addition to this support to the recruiter in the resume screening stage, AI also evaluates candidates registered in a company's talent pool and, for each available position, makes recommendations of the most suitable candidates. Such recommendations serve only as a suggestion to the recruiter, and the decision to include or not include a candidate in a specific selection process is the responsibility of the professional conducting the recruitment.

What data does Artificial Intelligence analyze and for what purposes? 

Gupy AI only analyzes the resume information of candidates and analyzes the job information to determine, based on such data, how compatible a candidate is with a particular position - presenting this result to the recruiter in the form of resume sorting.

Sensitive data and/or information about gender, sexual orientation, age, race, and ethnicity are not read (in fact, we exclude textual gender markers to avoid any bias in this aspect). For example, if the candidate indicates that their current position is "lawyer," the AI will only read "lawyer," making it impossible for it to identify gender.

Attention! Gupy AI does not read identification data or diversity data, nor does it use them for learning or improvement.

How does Gupy prevent the occurrence of biases in Artificial Intelligence? 

A bias is a biased way of thinking, i.e., a disproportionate weight against or in favor of a particular group of people, culture, or action, which can often be considered unfair due to unequal treatment.

To prevent biases in Artificial Intelligence, Gupy adopts several measures, such as:

a) Adoption of guiding principles that guide the development of Gupy AI;

b) Our data science team is composed of diverse individuals to ensure the representation of different social segments in the development of AI;

c) Does not analyze gender markers of the words you enter. For example, Artificial Intelligence will read "engineer," regardless of whether the resume contains the word "engineer" or "engineer." This means that, for Artificial Intelligence, your gender identification does not matter; this information will not be considered;

d) Constant human monitoring of Artificial Intelligence activities through audits and bias analyses, conducted by a diverse and inclusive team of data scientists, to ensure the safety and reliability of its results.

What does Artificial Intelligence not do?

Gupy AI acts in a specific and targeted manner in its activities and will never:

i) Eliminate, approve, or move a candidate in the selection process. No decision is made by AI in screening candidates. Decisions related to this stage of the selection process are made by the recruiter, who is supported by the information provided by Artificial Intelligence but is free at all times to ignore it and follow their own criteria. It is the recruiter who decides who will proceed to the next stages, who will be interviewed, and who will be hired or not;

ii) Behavioral profile analysis;

iii) Correction of tests performed by you - the scores assigned to various tests are considered by Artificial Intelligence, but the relevance of such scores in sorting applications depends on the company's previous behavior when analyzing the results of previous tests. Gupy AI does not analyze behavioral profile tests, tests of behavioral factor indicators, and the Integrity indicator;

iv) Sending automatic messages about the result of the selection process. The feedback on the processes is provided by the Client Company.

To learn more about how Gupy AI works in selection processes, see our official Positioning by clicking here.

What are your rights regarding the privacy of your data?

At Gupy, your rights are taken seriously! Your main rights under the LGPD are:

i) Confirm the existence of data processing by Gupy;

ii) Request access to your data and obtain detailed information on how Gupy processes this data, including sharing, purpose, form, and duration of processing;

iii) Correct incomplete, incorrect, or outdated data directly in your profile or resume;

iv) Portability - you can request a copy of your data in an easy-to-read format to facilitate migration to another service provider;

v) Eliminate unnecessary, excessive data or data processing that does not comply with the law, you can request its elimination;

vi) Request information about sharing your data;

vii) Revoke, at any time, the consent given to us through the Platform;

viii) Request a review of fully automated decisions or profile settings that affect your interests, provided they have been made based on 100% automated processing of your data;

ix) Object to processing or request account deletion: you have the right to object to data processing when not based on your consent and if Gupy is not fulfilling legal obligations. In this case, you can delete your account directly from your profile, which may take up to 10 business days, during which you cannot create a new account to prevent fraud. Some data may be kept to comply with Gupy's legal or regulatory obligations and to defend our rights in any legal disputes;

x) File a complaint with the National Data Protection Authority.

How to request service for a right?

To exercise any of your rights listed above, open a request by clicking on the link:

Gupy Data Subject Portal

Attention! In this channel, we do not handle Platform support requests.

With whom do we share the collected data? 

Gupy shares your data with:

i) Client Companies when you apply for a Selection Process (such companies, as Controllers, may share your Data with HR consultancies). If the company conducts Selection Processes or shares Data outside of Gupy Recruitment and Selection, it will be fully responsible for the independent uses it makes;

ii) Companies belonging to the Gupy's economic group in cases of merger, acquisition, or sale, when there is a purpose for it. In this case, the purpose will be informed in the respective privacy notice;

iii) With authorities/government agencies, in cases of judicial measures or processes, investigations, etc;

iv) With Gupy Admission to enable your hiring process when the Client Company uses this service (to learn more, check the Gupy Admissions Privacy Notice);

v) With job boards for job posting and partners through integrations that can be used independently by the Client Company or through Gupy;

vi) With suppliers and service providers (and only if strictly necessary), called Operators by the legislation, that we hire to help us carry out our activities, which are:

Supplier Service Provided Location
Amazon Web Services Storage and processing of data in the cloud Virginia, USA
Primeira Escolha Provision of tests Brazil
MailGun Email delivery San Antonio, Texas, USA
Zendesk Support channel  Oregon, USA

Such providers have been carefully selected, have strict confidentiality agreements and obligations related to the protection of your data, and may only process them for the purposes of providing the service contracted by Gupy. Other specific legal demands may lead to the sharing of personal data, including for the defense of our rights and interests in any kind of conflicts or to comply with determinations of competent authorities.

As the Data Controller, Client Companies may share your information with their partners and other Operators contracted by them, depending on the characteristics and strategies of their selection processes and people management. In this case, for more information about the processing of your data, you should consult their respective privacy notices.

International transfer of personal data 

Gupy may transfer your personal data outside of Brazil, specifically to the United States or countries of the European Union, if the Client Company or the Operators have servers in those countries.

We observe all guidelines established by current legislation and adopt best practices in security and privacy to ensure the integrity, confidentiality, availability, and privacy of your personal data throughout the process. Our relationships with such companies are governed by contracts that include obligations for the protection of data and information security appropriate to the nature of the personal data processing we perform and compatible with the requirements of Brazilian legislation.

Information security measures 

We are deeply concerned with the privacy and protection of your personal data. Therefore, we adopt technical, administrative, and organizational security measures and best practices to protect our systems and databases, using the best technologies available on the market – including the use of antivirus software, data encryption, anonymization of personal data, access control, firewalls, implementation of information security policy, software solution architecture with intrusion prevention, and HTTPS usage, institutional measures (Privacy and Data Protection Governance Program), training and awareness of employees, protection against unauthorized access, among others.

However, despite our efforts, considering the nature and architecture of the internet (which includes elements that are not under our control), it is impossible to guarantee that malicious actors will not gain access to or misuse personal data, as it is an inherent risk in the use of computerized systems.

Where and for how long will we keep your data?

Your Personal Data is stored in the cloud by Amazon Web Services, whose server is located in the state of Virginia, United States.

We store your Personal Data only for as long as necessary to achieve the purposes for which they were collected.

When you apply for a Selection Process, you become part of the Talent Bank of the Client Company, and your Personal Data will be kept there even after the Selection Process is completed. If you wish to leave a Talent Bank of a specific company or want to stop sharing your resume with Gupy's Client Companies on Gupy's Talent Portal, you can change the privacy settings directly in your profile.

At any time, you can also request the deletion of your account, and thus, your data will be removed or anonymized.

If your account remains inactive, meaning no access or login for a period exceeding 5 years, your data will be anonymized, and your account will be permanently deleted.

For more information on the procedures for deleting your data here at Gupy, check the complementary material available in the Help Center, by clicking here.

Important! The processing of personal data is an essential condition for you to participate in the Selection Processes for which you have applied. If you request the deletion of your account, you will immediately lose access to our Platform's services and will be prevented, for security reasons, from registering again for a period of 10 days. This measure is necessary to prevent fraud in the selection and recruitment processes, as well as to prevent the duplication of a candidate's registrations.

Even after the account deletion request, some information may be retained for legal or regulatory compliance purposes or to protect Gupy's or third parties' rights, including in any judicial disputes.

Additionally, when you are hired by a Client Company, Gupy needs to keep such information stored to enable companies to fulfill their labor obligations or for the regular exercise of rights in any judicial disputes. In this case, we can only delete your data with the express authorization of the Client Company that hired you.

Also, consult the Privacy Portal, where you will find easily accessible information on how Data is used by Gupy.

Updates

This Privacy Notice may be updated at any time, and such changes will be published in our services and can be checked whenever you want. Therefore, we recommend periodically visiting this page to be aware of the modifications. If significant changes requiring new authorizations from you are made, you will be notified through Gupy Recruitment and Selection.

Previous versions

20/03/2024 - Updated Version
07/12/2023 - Privacy Notice - 6th version
07/12/2022 - Privacy Notice - 5th version
19/08/2021 - Privacy Notice - 4th version 
14/04/2021 - Privacy Notice - 3rd version 
05/02/2021 - Privacy Notice - 2nd version 
14/07/2020 -
Privacy Notice - 1st version