UPSKILL PRIVACY POLICY

 

Learn more about the Privacy Policy and Conduct adopted by Upskill:

ATUALIZADO EM 16/04/2026

1. OBJECTIVES

Process personal data collected by Upskill, directly or indirectly, from all individuals, including but not limited to current, past or potential job applicants, employees, customers, consumers, children, suppliers/vendors, contractors/subcontractors, shareholders or any third parties, with "Personal Data" being defined as any data that relates to an identified or identifiable individual or a person who can be identified by means reasonably likely to be used.

2. APPLICATION

The Data Protection Policy applies to the global organisation of Upskill entities (hereinafter referred to only as "Upskill") for all sizes and activities, in all geographies where we operate in relation to Brazilian data protection law, i.e. the General Personal Data Protection Law (or "LGPD").

3. DESCRIPTION

3.1 Introduction

Your privacy is very important to us. We have developed this National Data Protection Policy so that you understand how we collect, use, store, share, transmit, transfer, delete or otherwise process (collectively "Process") your Personal Data. This National Data Protection Policy describes the measures we take to ensure the protection of your Personal Data. We also tell you how you can contact us to answer any questions you may have about data protection.

3.2 Definitions

 For the purposes of this policy, the following definitions should be considered, when referred to in capital or small letters, plural or singular, with or without bold, for their correct understanding:

• "Personal data": means any information relating to an identified or identifiable natural person. This means that a piece of data is considered personal when it allows the direct or indirect identification of the natural person, for example: name, surname, date of birth, telephone number, e-mail address, etc.
• "LGPD": General Personal Data Protection Law (Law No. 13,709 of 14 August 2018).
• "Processing": any operation carried out with Personal Data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transparency, dissemination or extraction.
• "Legal bases": legal bases are the legal hypotheses provided for in the LGPD that authorise Upskill to process Personal Data.
• "We or our": Upskill Group, hereinafter referred to as Upskill.
• "You": any natural person, as a visitor and/or user of the Upskill services and/or responsible for a Legal Entity (customers and/or suppliers) that accesses or interacts in any way with Upskill.
• "User": collaborators and/or users of the Upskill services.
• "Controller": a natural or legal person, governed by public or private law, who is responsible for decisions relating to the Processing of Personal Data.
• "Our Site": https://www.upskillplatform.com

 

3.3 Identity and details of the controller

 Upskill Platform is a company based in Brazil with no subsidiaries.

 UPSKILL LTDA, registered with the CNPJ under no. 47.520.593/0001-80, with headquarters in the city of Campinas / SP

4. COLLECTION AND PROCESSING OF YOUR PERSONAL DATA

4.1 Compliance with the General Data Protection Act and other legislation

We are committed to complying with any applicable legislation regarding "Personal Data" and ensuring that it is collected and processed in accordance with the provisions of general data protection law and other applicable local laws, if any.

4.2 Legality, fairness and transparency

We do not collect or process "Personal Data" without having a legal reason to do so. We may have to collect and process it where necessary for the performance of a contract to which you are a party or where it is necessary for the fulfilment of a legal obligation to which we are subject, with your prior consent. We may also collect and process your "Personal Data" for Upskill's legitimate interests.

When collecting and processing your "Personal Data", we will provide you with a fair and complete information notice or privacy statement about who is responsible for the Processing of your Personal Data, for what purposes your Personal Data is processed, who the recipients are, what your rights are and how to exercise them, etc., unless it is impossible or requires disproportionate efforts to do so.

Where required by applicable law, we will seek your prior consent.

4.3 Legitimate purpose, limitation and minimisation of data

Your "Personal Data" is collected for specified, explicit and legitimate purposes and will not be processed in a manner incompatible with those purposes.

When Upskill acts for its own purposes, your "Personal Data" is processed primarily for, but not limited to, the following purposes: recruitment management, human resources management, accounting and financial management and related controls and reporting, finance, treasury and tax management, risk management, employee safety management, provision of active directory, IT tools or internal websites and any other digital solutions or collaborative platforms, IT support management, including infrastructure management, systems management, applications, health and safety management, information security management, customer relationship management, tendering, sales and marketing management, supply management, internal and external communication and event management, compliance with anti-corruption obligations or any other legal requirements, data analysis operations, legal corporate management and implementation of compliance processes.

 

4.4 Accuracy and data storage

Upskill will keep processed "Personal Data" accurate and, where necessary, up to date. In addition, we will only retain "Personal Data" for as long as necessary for the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements and, where necessary for Upskill to assert or defend itself against legal claims, until the end of the relevant retention period or until the claims in question have been resolved. If you would like to know more about our specific retention periods for your "Personal Data" set out in our retention policy, you can contact us via email at dados@upskillplatform.com.

4.5 USO DE DADOS OBTIDOS VIA APIs DO GOOGLE (GOOGLE CALENDAR)

• https://www.googleapis.com/auth/calendar.events — criar, atualizar e remover eventos de sessões de mentoria.

• https://www.googleapis.com/auth/calendar.freebusy — consultar disponibilidade do mentor.

• https://www.googleapis.com/auth/calendar.calendarlist.readonly — listar sub-agendas para seleção.

Os tokens OAuth (access token e refresh token) são armazenados de forma criptografada e usados exclusivamente para operações de calendário.

 

4.6 Conformidade com Google API Services User Data Policy

Upskill Platform’s use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Em particular, a Upskill Platform se compromete a:

• Utilizar os dados obtidos via APIs do Google apenas para fornecer ou melhorar funcionalidades visíveis ao usuário.

• Não transferir dados a terceiros, exceto quando estritamente necessário para prestação do serviço ou quando exigido por lei.

• Não usar dados do Google para publicidade segmentada.

• Não permitir que humanos leiam dados do Google, exceto (a) com consentimento explícito, (b) por segurança, (c) para cumprir obrigações legais, ou (d) quando agregados e anonimizados.

Mentores podem desconectar sua conta Google a qualquer momento pelo painel do mentor ou em myaccount.google.com/permissions. Ao desconectar, os tokens são revogados e excluídos.

After the end of the applicable retention period, we will securely destroy your "Personal Data" in accordance with applicable laws and regulations.

 

5.SECURITY OF YOUR PERSONAL DATA

We implement appropriate technical and organisational measures to protect Personal Data from accidental or unlawful alteration or loss, or from unauthorised use, disclosure or access, in accordance with our Group Information and Systems Security Policy.

We take, where appropriate, all reasonable measures based on Privacy by Design and Privacy by Default principles to implement the necessary safeguards and protect the Processing of Personal Data. We also carry out, depending on the level of risk raised by the Processing, a privacy impact assessment to adopt appropriate safeguards and ensure the protection of Personal Data. We also provide additional security safeguards for data considered to be sensitive personal data.

 

6. DISCLOSURE OF YOUR PERSONAL DATA

 We share your personal data in the following circumstances:

• with Upskill entities for the purposes described in this policy;
• with third parties, including certain service providers that we retain in connection with the purposes described in this policy and the services we provide;
• with companies providing services for the prevention of money laundering and terrorist financing checks and other fraud and crime prevention purposes and companies providing similar services, including financial institutions and regulatory bodies with which this personal data is shared;
• with courts, law enforcement authorities, regulators, government officials or lawyers or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
• with service providers we engage inside or outside Upskill, nationally or abroad, e.g. shared service centres, to process Personal Data for any of the purposes listed above on our behalf and only in accordance with our instructions;
• if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets to whom we assign any of our rights and obligations.

7. INTERNATIONAL DATA TRANSFER

 As Upskill has international subsidiaries, if applicable your "Personal Data" may be transferred to recipients located outside Brazil. Personal Data" protection laws vary from country to country, but in the event of an international transfer with recipients located in other countries, Upskill has put in place adequate protection to safeguard your Personal Data and ensure that it is treated securely and in accordance with this Privacy Policy and all applicable Personal Data" protection laws.

8. YOUR RIGHTS

You have the right to access your Personal Data and to request the rectification of any inaccurate or incomplete Personal Data we hold about you. In certain circumstances, you can also request the deletion of your Personal Data or the restriction of its processing, or object to the processing of your Personal Data.

9. CHANGES TO OUR PRIVACY POLICY

We may change our Privacy Policy from time to time to reflect our practices and legal obligations. Any changes to our Privacy Policy will be posted on our website and, where appropriate, we will notify you by other means.

10. CONTACT

If you have any questions or concerns about our Privacy Policy, or the processing of your Personal Data, please contact us:

e-mail dados@upskillplatform.com

11. TERM

This Privacy Policy has been in force since 18 May 2023.

Copyright © 2023, Upskill