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Global employee, job candidate and job leavers privacy notice

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Last modification: September/2025

Welcome to dentsu Brasil!


  1. INTRODUCTION


1.1. Thank you for connecting with dentsu Brasil. Dentsu (hereinafter referred to in this Policy as "our/ours", "us" and "we") is a business division of the Dentsu Group, a global media group. Through this document ("Privacy Policy" or "Policy"), you will have access to all the possibilities for processing your personal data by dentsu Brasil as a result of your interaction with our website. Therefore, we recommend that you read this Policy carefully.


1.2. We believe that the responsible use of data supports business growth and creates strong relationships between brand and consumer. As a company, we are committed to respecting and protecting the privacy of all individuals with whom we interact. We are committed to being transparent in how we handle personal data at all times, in accordance with applicable privacy and data protection laws.


1.3. This Privacy Policy explains in detail the types of personal data we may collect about you when you interact with us on our website. Dentsu is the data controller of any personal data you provide to us in relation to this website.

Attention!

This Privacy Policy does not apply to the processing of your personal data carried out by dentsu Brasil in the execution of services provided to our clients.


1.4. This Privacy Policy presents the following:


  • Collected personal data
  • How we use your personal data
  • How long we keep your personal data
  • How we protect your personal data
  • How we share and disclose information
  • International transfers between companies and within the Dentsu Group
  • Your rights as a data subject
  • Our responsibility for third-party website links
  • Updates
  • How to contact us

1.5. In the Supplementary Information section of this Privacy Policy, we explain what "personal data" and other terms used in this Policy mean.


  1. PERSONAL DATA COLLECTED


2.1. The type of information we collect will depend on the circumstances and the service you are using. In general, we will collect information related to you and/or your use of the website in the following ways:


2.1.1. Information related to website use: we collect information about how you use our website. This includes information related to the pages you visit on our website, the services or information you search for, and the links and content you choose to access. We may also use the personal information you provide through your use of our website to provide relevant content and inform our marketing strategy. This type of activity is known as "profiling" — using automated means to process your personal data to analyze or predict your preferences, interests, or personal behaviors. You may object to the creation of this type of profile (see section 8 of this Policy below).


2.1.2. Technical data: we collect information about the device(s) you use to access our website. This includes the exclusive collection of mobile device IDs or online identifiers such as Internet Protocol (IP) addresses, which are numbers that can uniquely identify a specific hardware/computer or other network device on the Internet. This information is linked to a cookie ID, which we receive and process. You can find more information about the cookies we use and the purposes for which we use them in our Cookie Notice.


2.1.3. Contact data: we collect contact details when you sign up to receive email alerts, participate in one of our events, download our content, subscribe to our newsletters, or when you request that we respond to a question you have asked. The personal data we collect includes your name, email address, job title, and location.


2.1.4. Marketing and communication data: we collect information about your preferences when browsing our website, requesting to receive our marketing communications, and other preferences you express.


2.2. We do not intend to collect information about minors under 18 years of age. If you have any questions about the privacy of minors in relation to our services, or if you, as a legal guardian, believe that a minor may have entered personal data on our website, please contact us through the contact channel indicated in this Policy. We will delete this information from our records within a reasonable period.


  1. HOW WE USE YOUR PERSONAL DATA


3.1. In addition to when required by law, we use the personal data you provide for the following purposes:

  • to provide the specific information or services you requested;
  • to enable the download of our content;
  • to send newsletters and information related to our brands and services;
  • to respond to your requests and feedback;
  • to analyze and/or improve our services; and
  • to target marketing content or to expand and inform our marketing strategy, according to the mapping of your preferences.


3.2. To ensure maximum transparency regarding our personal data processing activities, we provide you with a description of the legal basis for processing your personal data. Most of the time, the processing of your personal information is based on: a) our legitimate interests; b) when providing the services requested by you; c) your consent, when requested; or d) to comply with a legal or regulatory obligation, within the limits of applicable law.


3.3. In the table below, we provide more information related to the purposes for which we use your personal data and the legal bases on which such uses are supported. Note that we may process your personal data on more than one legal basis, depending on the specific purpose for which we are using your data.


Purpose / ActivityTypes of personal data that may be processedLegal basis for processing
To send information about our Services, such as newsletters or publications, according to your specified preferences(a) Name (b) Email address (c) Company (d) LocationWhere you have requested information, such as newsletters, publications, or event invitations, we send these communications based on your consent. You can opt out of these communications at any time by clicking the unsubscribe link at the bottom of the message.
To improve and develop our website, through statistical analysis of website use, for example, to allow us to improve our Services, offer new features and materials, etc.(a) Technical dataIt is in our legitimate interest to define types of customers for our services, keep our website updated and relevant, develop our business, and inform our marketing strategy.
To provide relevant content to you and measure or understand the effectiveness of the content we provide.(a) Name (b) Email address (c) Company (d) Location (e) Marketing and communications data (f) Technical dataIt is in our legitimate interest to study how customers use our service and engage with our content, as well as to develop our service, expand our business, and inform our marketing strategy.
To provide relevant content and inform our marketing strategy.(a) Name (b) Email address (c) Company (d) Location (e) Marketing and communications data (f) Technical data (g) Website useThis type of activity is known as "profiling". We use automated means to analyze or predict your preferences, interests, or personal behaviors based on your consent. You may object to the creation of this type of profile (see section 8 of this Policy below).
To respond to any questions or comments you send us, as well as to update you with any changes to our terms and conditions/other policies.(a) Name (b) Email address (c) Company (d) LocationWhen necessary for the performance of a contract or pre-contractual procedures at your request, we may respond to communications you send us, inform you about relevant information regarding the services we provide, and use your information.
To obtain information about our products and services relevant to your needs.(a) Name (b) Email address (c) Location (d) Website useIt is in our legitimate interest to map which of our products or services may interest you and talk about them.
To share information with our service providers.(a) Name (b) Email address (c) Website use (d) Marketing and communicationsIt is in our legitimate interest to share your data with trusted third parties who provide us with relevant services for the provision of our website and its features. (e) Technical data
To share information within the dentsu group.(a) Name (b) Email address (c) Location (d) Website useAs dentsu operates as a global media company, it is our legitimate interest to share your data with the dentsu group to efficiently manage our business and provide our products and services, when necessary to achieve the stipulated purpose.
To share information with third parties, such as regulatory and law enforcement agencies(a) Name (b) Email address (c) Location (d) Website use (e) Technical dataWe share your data as necessary to comply with any legal or regulatory obligation to which we are subject* or to satisfy our legitimate business interests, respecting the limits of applicable law.


  • This process involves sharing your personal data, when necessary, to the extent permitted by applicable data protection laws, to respond to requests made by the National Data Protection Authority or any relevant authorities and/or bodies, in order to comply with regulatory and/or legal obligations.


  1. HOW LONG WE KEEP YOUR PERSONAL DATA


4.1. When processing your data, dentsu Brasil will strive to store and keep it protected, in secure and controlled environments, respecting current legislation. For this reason, your personal data will be stored with high levels of security, including access control practices.


4.2. In providing its services, dentsu Brasil always seeks companies that employ a high level of security in information storage, establishing contracts that do not violate the terms of this Privacy Policy.


4.3. We will keep your personal data for as long as necessary to perform our services and in accordance with the period allowed by data protection legislation. After this period, your personal data will be securely deleted or anonymized, so that it can be used for analytical purposes. You can request more information through the contact channel provided in this Privacy Policy.


  1. HOW WE PROTECT YOUR PERSONAL DATA


5.1. Dentsu is committed to continuously implementing physical, technical, and administrative information security measures in the processing of your personal data, in accordance with best market practices. Thus, we seek to protect your data against unauthorized access, accidental or unlawful situations of destruction, loss, alteration, communication, or any form of improper or unlawful processing.


5.2. In this sense, dentsu allows your personal data to be accessed by its employees and other third parties only to the extent necessary for them to perform their activities, according to express instructions and under a contractual obligation of secrecy and confidentiality of the personal data processed.


5.3. In our partnerships with other companies or service providers, we always seek to ensure that the same level of protection for personal data is implemented and enforced.

 

  1. HOW WE SHARE AND DISCLOSE YOUR INFORMATION


6.1. Information shared with our third-party service providers: we may use third parties to perform business functions on our behalf, such as sending newsletters, hosting our online services, and customer relationship management. We will only disclose the information necessary to allow these third parties to perform their services. Our service providers are contracted to comply with our instructions, and we require them not to use your personal data for purposes other than those indicated here.


6.2. Information shared with other parties: when required or permitted by law, personal data may be provided to third parties, such as regulatory bodies and public entities, in response to a court order or subpoena, in response to a police request, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, in accordance with the requirements and limits of applicable law.


6.3. We do not sell or rent your personal data to third parties.


  1. INTERNATIONAL TRANSFERS BETWEEN COMPANIES AND WITHIN THE DENTSU INTERNATIONAL GROUP


7.1. Dentsu is a media group with global operations, composed of several companies. Therefore, we may periodically disclose your personal data within our group of companies, provided there is a need to fulfill the provision of our requested services to you or to comply with legal and regulatory obligations of dentsu or when we have your specific and informed consent.


7.2. Some of our group companies are located outside Brazil, but we always ensure the security of such disclosures and transfers in accordance with applicable privacy and data protection laws.


7.3. We will only transfer your personal data outside Brazil in cases where there are adequate levels to protect the integrity and security of any processed information and compliance with applicable privacy and data protection laws.


7.4. We may also store your personal data on servers located outside the national territory, including, but not limited to, cloud computing servers that follow internationally accepted standards for personal data security.


7.5. In the cases mentioned above, dentsu undertakes to comply with applicable legislation to ensure the protection of your personal data, through practices such as entering into appropriate contractual agreements.


7.6. You can request more information about the measures used for these transfers through the contact channel provided in this Privacy Policy.


  1. YOUR RIGHTS AS A DATA SUBJECT


8.1. Dentsu will adopt appropriate technical and organizational measures to fulfill its obligations regarding your rights as a data subject. In this sense, we are committed to enabling, as best as possible, your rights as provided by law, which are:


a. Confirmation: right to be informed about the existence of data processing.


b. Access: right to request access to your personal data, including a description and copy of your personal data and the reason why we are processing this data, unless a legal exception applies.


c. Correction: right to request the alteration of data when it is incomplete, inaccurate, or outdated.


d. Restriction: right to object or request the anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data.


e. Portability: right to request the transmission of processed data to you or a third party, including another service provider, in a structured, commonly used, and machine-readable format. This right applies only to personal data you have provided to us.


f. Deletion: right to request the deletion of personal data processed based on your consent. Note that we may be required to retain certain personal data by law and/or for our own legitimate business purposes, but when we do, we will inform you.


g. Information: right to be informed about the public and private entities with which your data has been shared and about the possibility of not providing consent and the consequences of this refusal.



h. Withdrawal of consent: right to withdraw consent, when processing depends on your consent, at any time, through express manifestation, by a free and facilitated procedure. Withdrawal of your consent does not affect the lawfulness of processing carried out up to the time of withdrawal or affect our right to continue collecting, using, or disclosing your personal data when such collection, use, or disclosure of personal data is permitted by applicable laws without consent.


i. Review: right to review decisions made solely based on automated processing of personal data that affect your interests, including decisions intended to define your personal, professional, consumer, and credit profile or aspects of your personality.


j. Petition: right to petition regarding your data against the controller before the National Data Protection Authority. We will do our best to resolve any complaint. However, if you believe we have not resolved your complaint, you may complain to the National Data Protection Authority.


8.2. If you wish to stop receiving marketing messages sent by dentsu Brasil, you can, at any time, unsubscribe from these messages through the opt-out link within the message sent.


8.3. If you object to the processing of your personal data, even if this processing is supported by our Legitimate Interest (or that of third parties), including for direct marketing or profiling purposes, we will stop processing the information to which you objected, unless we have compelling legitimate reasons to continue such processing.


8.4. If you exercise the above rights and there is any doubt regarding your identification, we may ask you to provide information from which we can have assurances as to your identity, in order to ensure adequate security in responding to data subject requests.


8.5. If you are interested in exercising any of the rights listed above, you can contact dentsu through the contact channel indicated in this Policy.


  1. OUR RESPONSIBILITY FOR THIRD-PARTY WEBSITE LINKS


9.1. This Privacy Policy is limited to personal data collected by dentsu on our own website. We provide links within this site to other sites, including social media sites such as Facebook, Twitter, and LinkedIn. If you follow these links, you should use those sites in conjunction with the applicable privacy and user notices, as their data practices are outside the scope of this Privacy Policy. In addition, we cannot have responsibility or control over the information collected by any third-party site and cannot be responsible for the protection and privacy of any information you may provide to any third parties.


  1. UPDATES


10.1. This Privacy Policy may be updated periodically to reflect changes in the law, best practices, or a change in our practices regarding the processing of personal data. The date of the most recent version will appear at the top of this page. If you do not agree with the changes, do not continue using our services and avoid sharing your personal data with us. You should check this notice frequently for updates.


10.2. Any modification to this Policy that impacts previously provided consent or implies a financial burden for you will be communicated by dentsu in advance. However, any change made for legal reasons or due to new features of a service will take effect immediately.


10.3. You may stop using the services at any time. Likewise, dentsu may also stop providing the services to you at any time, as well as include or create new limits to the services.


10.4. If you do not agree with any changes to this Policy, you should stop using the services. Otherwise, continued use of the services will constitute your acceptance of the new version of the Policy.


  1. HOW TO CONTACT US


11.1. If you have any questions about this Privacy Policy, about our data processing practices, or if you wish to exercise any of the rights mentioned in this Privacy Policy, contact our Data Protection Officer ("DPO") at:


brasil.dpo@dentsu.com


Data Protection Officer: FAS ADVOGADOS IN COOPERATION WITH CMS

Responsible: Danilo Roque


SUPPLEMENTARY INFORMATION


In this Supplementary Information section, we explain some of the terminology used in this Privacy Policy.


"Data controller" – the person or company responsible for decisions regarding the processing of personal data, such as who controls the purposes and means of processing personal data.


"Personal data" – any information related to you or that allows your identification.


"Sensitive personal data" means any personal data relating to racial or ethnic origin, religious belief, political opinion, union or religious affiliation, membership in philosophical or political organizations, data relating to health or sex life, genetic or biometric data, when related to a natural person.


"Anonymized data" means any personal data related to an individual who cannot be identified, considering the use of reasonable and available technical means at the time of processing to make the data anonymous.


"Processing" – means the handling of data, including but not limited to collection, handling, storage, disclosure, and deletion.


"Profiling" – use of automated means to process personal data, in order to discover information about people, such as analyzing or predicting their work performance, reliability, economic situation, personal preferences, interests, behavior, location, or movements.


"International transfer" – sending personal information outside Brazilian territory (for example, storing it on equipment located outside Brazilian territory) or allowing someone outside Brazil to access this information.