Last updated: 12/16/2024
Purpose
The purpose of this Privacy Policy is to describe the personal data collected, how it is used, stored, and shared, as well as users’ rights regarding this information. This Privacy Policy was established to demonstrate Ninecon’s commitment to handling personal data securely, privately, and transparently.
This website is maintained and operated by NINECON CONSULTORES ASSOCIADOS LTDA, referred to in this policy as “Ninecon.”
Ninecon collects and uses personal data belonging to individuals who use this website. In doing so, the company acts as the controller of such data and is subject to the provisions of Federal Law No. 13,709/2018 (Brazilian General Data Protection Law – LGPD).
Ninecon is committed to protecting the personal data of users of this website and, therefore, provides this Privacy Policy, which contains important information about:
● Who is authorized to use the website;
● What data is collected and how this information is used;
● Users’ rights regarding their personal data; and
● How to contact the personal data processor.
Please read this Privacy Notice carefully, as it will help you understand what we do with the information we collect.
Who May Use the Website
This website is intended for use by individuals who are at least eighteen years old.
Data Collected and Purpose of Collection
The website collects and uses users’ personal data in accordance with the provisions set forth in this section.
Personal Data Expressly Provided by the User
The following personal data is collected as users provide it while using the website:
● Full name;
● Phone number;
● Email address;
● CPF (Brazilian Individual Taxpayer Registry);
● Resume/CV;
● Date of birth;
● Job title;
● Salary expectations; and
● LinkedIn profile.
The collection of this data takes place at the following times:
● When the user fills out the Contact form; or
● When the user fills out the Careers page form.
The data provided by users is collected for the following purposes:
● To contact users regarding their interest in Ninecon’s services or products;
● To process registrations for webinars and courses, when applicable; and
● To review and process resumes submitted by individuals interested in joining Ninecon companies.
Sensitive Data
Sensitive personal data from users will not be collected, as defined in Articles 5 and following of the Brazilian General Data Protection Law (LGPD).
Therefore, no data related to racial or ethnic origin, religious beliefs, political opinions, membership in trade unions or religious, philosophical, or political organizations, health or sexual life information, or genetic or biometric data linked to a natural person will be collected.
Cookies
Cookies are text files automatically downloaded when a user accesses and browses a website. Their primary purpose is to identify devices, user activities, and preferences.
Cookies do not allow any files or information to be extracted from the user’s hard drive. They also cannot be used to access personal information that has not been voluntarily provided by the user or generated through the way the user interacts with the website’s features.
Website Cookies
Website cookies are those sent to the user’s device exclusively by the website itself.
The information collected through these cookies is used to improve and personalize the user experience. For example, cookies may be used to remember user preferences and choices, as well as to provide personalized content.
Third-Party Cookies
Ninecon’s partners may place cookies on the devices of users who access the website.
These cookies are generally intended to allow partners to provide personalized content and services to users accessing the website, based on browsing data collected through their interaction with the site.
Users may obtain more information about third-party cookies, how the data collected through them is processed, and access descriptions of the cookies used and their characteristics by visiting the website’s cookie management tool and the respective third parties’ Privacy Policies, as listed below:
● Google Analytcs: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
● Cloudflare: https://www.cloudflare.com/pt-br/privacypolicy/
● Cookie Script: https://cookie-script.com/legal/privacy-policy
● Google Tag Manager: https://policies.google.com/privacy?hl=pt-BR
● Facebook Pixel: https://www.facebook.com/privacy/policies/cookies/?entry_point=cookie_policy_redirect&entry=0
● Youtube: https://www.youtube.com/intl/ALL_br/howyoutubeworks/our-commitments/protecting-user-data/
● Google Maps: https://policies.google.com/privacy
The entities responsible for collecting cookies may share the information obtained with third parties.
Cookie Management
Users may object to the use of cookies by the website by disabling them when they begin using the service, following the instructions below:
When accessing the website, users have the option to accept or refuse cookies.
However, disabling all cookies will not be possible, as some of them are essential for the proper functioning of the website.
In addition, disabling cookies that can be turned off may impact the usability of the website, since information used to personalize the user experience will no longer be available.
Coleta de dados não previstos expressamente
Eventualmente, outros tipos dedados não previstos expressamente nesta Política de Privacidade poderão ser coletados, desde que sejam fornecidos com o consentimento do usuário ou que a coleta seja permitida com fundamento em outra base legal prevista em lei.
Em qualquer caso, a coleta dedados e as atividades de tratamento dela decorrentes serão informadas aos usuários do site.
Sharing Personal Data with Third Parties
We do not share the personal data of website users with third parties. However, Ninecon may disclose such data when necessary to comply with legal or regulatory obligations, or in response to an order issued by a public authority.
How Long Personal Data Will Be Stored
The personal data collected by Ninecon will be stored and used for the following periods:
The personal data collected is stored for as long as the user remains a client, prospect, or candidate interested in joining Ninecon’s workforce, or while using the company’s products and services. Throughout the entire period in which Ninecon stores personal data, such data will be maintained in a secure and controlled environment, in accordance with each established process and its intended purpose, while complying with legal obligations.
Personal data retention periods will not exceed the time strictly necessary, always considering the purposes and legal justifications for data processing.
In accordance with applicable law, Ninecon uses personal data for as long as necessary to fulfill the purposes established by law. The company may retain personal data for auditing purposes, compliance with legal or regulatory obligations, the regular exercise of Ninecon’s rights, or for the period required under the legal basis that justifies data retention.
Once the processing of personal data has ended, such data will be deleted within the scope and technical limits of the activities, except in situations where retention is permitted under applicable law.
Legal Bases for the Processing of Personal Data
Each personal data processing activity must have a legal basis, meaning a legal justification that authorizes it, as provided for under the Brazilian General Data Protection Law (LGPD).
All of Ninecon’s personal data processing activities are supported by a legal basis permitted under applicable law. More information about the legal bases used for specific personal data processing operations may be obtained through the contact channels provided at the end of this Policy.
User Rights
Users of the website have the following rights, as provided by the Brazilian General Data Protection Law (LGPD):
● Confirmation of the existence of data processing;
● Access to personal data;
● Correction of incomplete, inaccurate, or outdated data;
● Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
● Data portability to another service or product provider, upon express request and in accordance with regulations issued by the national authority, subject to commercial and industrial confidentiality;
● Deletion of personal data processed based on the data subject’s consent, except in cases provided by law;
● Information about public and private entities with which the controller has shared data;
● Information about the possibility of refusing consent and the consequences of such refusal; and
● Withdrawal of consent.
It is important to note that, under the LGPD, there is no general right to delete data processed based on legal grounds other than consent, unless the data is unnecessary, excessive, or processed in violation of the law.
How Data Subjects May Exercise Their Rights
If data subjects whose personal data is processed by Ninecon need to exercise their rights, they may do so by contacting our Data Protection Officer (DPO).
DPO Contact Information:
Name: Athena Security Ltda
Responsible Party: Thiago Cabral (CEO of Athena Security)
E-mail: dpo@ninecon.com.br
To ensure that the user seeking to exercise their rights is, in fact, the data subject related to the request, Ninecon reserves the right to request documents or other information that may assist in properly verifying the user’s identity, in order to protect our rights and the rights of third parties. However, this will only be done when absolutely necessary, and the requesting party will be provided with all related information.
Security Measures for the Processing of Personal Data
Ninecon implements technical and organizational measures designed to protect personal data against unauthorized access and against situations involving destruction, loss, misuse, or alteration of such data.
The measures adopted take into account the nature of the data, the context and purpose of the processing, the risks that a potential breach could pose to the user’s rights and freedoms, as well as the standards currently adopted in the market by comparable companies.
Among the security measures adopted, we highlight the following:
Ninecon uses advanced security technologies to ensure the protection of collected personal data, the website, and related systems. The data collected and all website connections are encrypted, prioritizing both security and user experience.
In addition, Ninecon follows ISO 27001 and ISO 27002 standards in order to adopt the highest technical standards for Information Security, ensuring the protection of both personal and non-personal data belonging to our users.
Even with the adoption of Information Security best practices, incidents caused exclusively by third parties may still occur — such as hacker or malicious cyberattacks, or situations involving user misconduct, for example when users themselves share their data with third parties. Although Ninecon is responsible for the processing of users’ personal data, we disclaim liability in exceptional situations such as those mentioned above, over which we have no control.
In any event, should any security incident occur that may result in relevant risk or harm, we will notify the affected parties and the Brazilian National Data Protection Authority (ANPD) in accordance with the provisions of the Brazilian General Data Protection Law (LGPD).
Complaint to the Supervisory Authority
Without prejudice to any other administrative or judicial remedy, data subjects who believe they have been harmed in any way may file a complaint with the Brazilian National Data Protection Authority (ANPD).
Changes to This Policy
This version of the Privacy Policy was last updated on: 12/16/2024.
We reserve the right to modify these terms at any time, especially to adapt them to any changes made to our website, including the introduction of new features, or the removal or modification of existing ones.
Whenever changes are made, our users will be notified accordingly. We recommend that you review this Privacy Policy frequently, or whenever you have questions, in order to stay informed about any updates or changes.
This Privacy Policy will be reviewed and updated on an annual basis.
How to Contact Us
If you have any questions regarding this Privacy Policy or the personal data we process, please contact our Data Protection Officer through one of the channels listed below:
E-mail: dpo@ninecon.com.br
Phone: +55 (11) 2177-1100
Address: Alameda Araguaia, 2044, Building 1, 11th Floor, Alphaville, ZIP Code: 06455-000, Barueri, São Paulo, Brazil.