Privacy & cookies policy
Privacy Policy
At COMBINE GLOBAL RECRUITMENT, privacy and security are priorities, and we are committed to being transparent in how we treat the personal data of our users/clients. Therefore, this Privacy Policy establishes how customer information or information from others who access or use our website and products is collected, used, and transferred.
By using our services, you understand that we will collect and use your personal information in the ways described in this Policy, under the norms of the Federal Constitution of 1988 (art. 5, LXXIX; and art. 22, XXX – included by EC 115/2022), Data Protection norms (LGPD, Federal Law 13.709/2018), consumer provisions of Federal Law 8078/1990, and other applicable rules of Brazilian law.
Thus, COMBINE GLOBAL RECRUITMENT is committed to the provisions of this Privacy Policy.
What data do we collect about you (or your company) and for what purpose?
Our company collects and uses some of your personal data to enable the provision of services and to enhance the user experience.
1.1. Personal data provided by the holder
Full Name
Phone
1.1. Business data provided by the holder (when a company)
Corporate Name
CNPJ or EIN (legal employer number)
Email for invoice submission
Contact phone
How do we collect your data?
In this regard, your personal data is collected as follows:
Via LinkedIn
Via email contact
Via telephone contact
2.1. Consent
We process your personal data based on your consent. Consent is the free, informed, and unambiguous expression by which you authorize COMBINE GLOBAL RECRUITMENT to process your data.
In line with the General Data Protection Law, your data will only be collected, processed, and stored with prior and explicit consent.
Your consent will be obtained specifically for each purpose described above, highlighting the commitment to transparency and good faith of COMBINE GLOBAL RECRUITMENT towards its users/clients, in compliance with relevant legislation.
By using the services of COMBINE GLOBAL RECRUITMENT and providing your personal data, you are aware of and agree with the provisions of this Privacy Policy, and you are familiar with your rights and how to exercise them.
You can revoke your consent at any time, without any cost.
It is important to note that revoking consent for data processing may result in the inability to properly perform some functionalities of the site or product that depend on the operation. Such consequences will be informed in advance.
What are your rights?
COMBINE GLOBAL RECRUITMENT ensures its users/clients the rights as data subjects as outlined in Article 18 of the General Data Protection Law. Thus, you may, at any time and without any cost:
Verify the existence of data processing, either in a simplified manner or in a clear and complete format.
Access your data, requesting it in a legible copy either in printed form or through a secure and reliable electronic method.
Correct your data by requesting its editing, correction, or updating.
Limit your data when unnecessary, excessive, or processed in non-compliance with the law through anonymization, blocking, or deletion.
Request the portability of your data, through a report of registration data that COMBINE GLOBAL RECRUITMENT processes on your behalf.
Delete your data processed based on your consent, except in cases provided by law.
Revoke your consent, thereby disallowing the processing of your data.
Inform yourself about the possibility of not giving your consent and about the consequences of refusal
.
How can you exercise your rights as a data subject?
To exercise your rights as a data subject, you should contact COMBINE GLOBAL RECRUITMENT through the following available means:
luiz@combinegr.com
To ensure your correct identification as the data subject of the data being requested, we might ask for documents or other proofs that can verify your identity. In this case, you will be informed in advance.
How and for how long will your data be stored?
Your personal data collected by COMBINE GLOBAL RECRUITMENT will be used and stored for the time necessary to provide the service or to achieve the purposes listed in this Privacy Policy, taking into account the rights of the data subjects and the controllers.
In general, your data will be kept for the duration of the contractual relationship between you and COMBINE GLOBAL RECRUITMENT. Once the storage period for personal data ends, they will be removed from our databases or anonymized, except for legally provided situations in Article 16 of the general data protection law, namely:
I – Compliance with a legal or regulatory obligation by the controller;
II – Study by a research institution, ensuring, whenever possible, the anonymization of personal data;
III – Transfer to a third party, as long as the requirements for data processing provided in this Law are met; or
IV – Exclusive use by the controller, with third-party access being forbidden, and provided the data is anonymized.
That is, personal information about you essential for meeting legal, judicial, and administrative determinations and/or for the exercise of the right to defense in judicial and administrative processes will be retained, notwithstanding the deletion of other data.
The storage of data collected by COMBINE GLOBAL RECRUITMENT reflects our commitment to the security and privacy of your data. We employ technical measures and solutions capable of ensuring the confidentiality, integrity, and inviolability of your data. Furthermore, we also have security measures suitable for risks and controlled access to stored information.
What do we do to keep your data safe?
To keep your personal information secure, we utilize physical, electronic, and managerial tools aimed at protecting your privacy.
We implement these tools considering the nature of the personal data collected, the context and purpose of the processing, and the risks that potential breaches would pose to the rights and freedoms of the data subject.
Among the measures we employ, we highlight the following:
– Only authorized personnel have access to your personal data.
– Access to your personal data is granted only after a commitment to confidentiality.
– Your personal data is stored in a secure and reliable environment.
While COMBINE GLOBAL RECRUITMENT is committed to adopting the best practices to prevent security incidents, it’s important to note that no online platform is entirely secure and risk-free. Despite our robust security protocols, third-party issues might arise, such as cyberattacks by hackers or even due to negligence or imprudence of the user/client.
In the event of security incidents that might pose a significant risk or damage to you or any of our users/clients, we will notify the affected parties and the National Data Protection Authority in accordance with the provisions of the General Data Protection Law.
6.1. About the RISK MANAGEMENT COMMITTEE
COMBINE GLOBAL RECRUITMENT has a risk management committee aimed at analyzing potential frauds and vulnerabilities. If any breaches are identified, the affected parties will be notified and informed about next steps and new actions for data protection and security.
With whom can your data be shared?
To ensure the preservation of your privacy, COMBINE GLOBAL RECRUITMENT will not share your personal data with any unauthorized third parties.
Your data may be shared with our business partners.
These partners only receive data as necessary for the provision of contracted services, and our agreements are guided by Brazilian data protection standards.
However, our partners have their own Privacy Policies, which might differ from this one. Additionally, there are other circumstances where your data might be shared, such as:
I – Legal determinations, requests, or court orders from competent judicial, administrative, or governmental authorities.
II – Corporate transactions like mergers, acquisitions, and integrations.
III – To protect COMBINE GLOBAL RECRUITMENT’s rights in any conflict, including legal disputes.
7.1. International Data Transfer
Some third parties with whom we share your data may be located or have facilities in foreign countries. Nonetheless, your personal data will still be subject to the General Data Protection Law and other Brazilian data protection legislations.
In this regard, COMBINE GLOBAL RECRUITMENT commits to always adopt efficient cybersecurity and data protection standards, doing its utmost to ensure compliance with legislative requirements.
By agreeing to this Privacy Policy, you consent to this sharing in accordance with the purposes described herein.
Modification of this Privacy Policy
The current version of the Privacy Policy was formulated and last updated by: COMBINE GLOBAL RECRUITMENT.
We reserve the right to modify this Privacy Policy at any time, especially due to adaptations to any changes in our product or in the legislative scope. We recommend that you review it frequently.
Any changes will take effect upon their publication on our website, and we will always notify you of any changes.
By using our services and providing your personal data after such modifications, you consent to them.
Liability
COMBINE GLOBAL RECRUITMENT provides for the liability of agents involved in data processing procedures, in accordance with articles 42 to 45 of the General Data Protection Law.
We commit to keeping this Privacy Policy updated, respecting its provisions and ensuring its compliance.
Additionally, we also pledge to seek technical and organizational conditions aptly suited to protect the entire data processing procedure.
Should the National Data Protection Authority require us to take measures regarding data processing carried out by COMBINE GLOBAL RECRUITMENT, we commit to following them.
Disclaimer
As mentioned in Topic 6, although we adopt high security standards to prevent incidents, no online platform is entirely risk-free. In this regard, COMBINE GLOBAL RECRUITMENT is not responsible for:
I – Any consequences arising from the negligence, recklessness, or lack of expertise of users regarding their individual data. We guarantee and are responsible only for the security of data processing and compliance with the purposes described herein. It should be noted that users are responsible for the confidentiality of their access data.
II – Malicious actions by third parties, such as hacker attacks, unless proven negligent or deliberate conduct by COMBINE GLOBAL RECRUITMENT. In the event of security incidents that may pose significant risk or damage to you or any of our users/clients, we will notify the affected parties and the National Data Protection Authority and take the necessary actions.
III – Untruthful information provided by the user/client in the necessary registrations for the use of COMBINE GLOBAL RECRUITMENT’s services; any consequences arising from false or bad-faith information are solely the responsibility of the user/client.
Data Protection Officer
COMBINE GLOBAL RECRUITMENT provides the following means for you to contact us to exercise your rights as a holder: luiz@combinegr.com.
If you have questions about this Privacy Policy or about the personal data we process, you can contact our Personal Data Protection Officer through the following channels:
Daniel de Castro Rodrigues Garcia (CPF 375765628-89)
daniel@rh-in.com
