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Privacy notice for candidates

 

PRIVACY NOTICE FOR CANDIDATES

Introduction

At Nubank, our goal is to eliminate complexity, and we believe it is crucial for you to understand how we use your personal data. Therefore, we have made this Privacy Notice for Candidates as straightforward as possible. If you still have any questions, we are available through the contact channels indicated in the "Contact Us" section.

This Privacy Notice for Candidates of Nu Pagamentos S.A. – Payment Institution, Nu Financeira S.A. – Credit, Financing and Investment Society, NuPay For Business Instituição de Pagamento LTDA., Nu Invest Corretora de Valores S.A., and other companies in the Nubank economic group, which include its direct or indirect controlling and controlled companies, as well as its affiliates and companies under common control in Brazil (referred to in this document as “Nubank”), was created to demonstrate Nubank's commitment to always handling your personal data securely, privately, and transparently.

This Privacy Notice for Candidates outlines the personal data we collect, how it is used, stored, and shared, and your rights concerning this data when you participate in a selection process to work at Nubank, when you submit your resume, or when you voluntarily register on our platform. By accepting this Privacy Notice for Candidates, you acknowledge that the controller of your personal data, i.e., the company responsible for making decisions related to the processing of your personal data, will be Nubank. For this reason, we recommend that you read the Notice to the end.

❗This Privacy Notice for Candidates does not constitute part of any employment contract or any other type of contract for the provision of services.

  1. Application

This Privacy Notice for Candidates applies to all applicants for positions available at Nubank, regardless of the outcome of the selection process. For regular jobs or internships, you must be over 18 years old. Nubank also allows you to apply for internships and apprentice positions if you are over 16 years old, provided you present written authorization from your parents or legal guardians.

Whenever you encounter a word beginning with uppercase letters in this Privacy Notice for Candidates, it means that such a word has a specific meaning within the Notice.

Whenever there is a reference to “Nubank,” “we,” “us,” or “our(s),” we are referring to the companies that are part of Nubank. Similarly, whenever there is a reference to “you,” “your(s),” or “yourself,” we are referring to You.

The activities described in this Privacy Notice for Candidates only apply to the processing of your personal data in Brazil and are subject to applicable local laws, particularly Law No. 13.709/2018 (General Data Protection Law or “LGPD”), in accordance with its most recent version and any future amendments.

❗If a candidate is approved in the selection process and hired by Nubank, the processing of their personal data will be fully governed by the Privacy Notice for Employees.

2. Personal Data Collected by Nubank

When you participate in our selection process, we will need to collect some of your personal data. You are solely responsible for the accuracy of the data you provide us. In some cases, you provide your data directly to Nubank, but we may also receive it from partners we hire for specific purposes, such as recruiting professionals for certain vacancies. In any case, all processing carried out by Nubank must be justified by one or more legitimate purposes, so Nubank will never process any data under any unjustified or illegitimate pretext.

❗Here at Nubank, we may use ARTIFICIAL INTELLIGENCE tools in the processing of personal data to enhance our selection process, always in compliance with our legal and regulatory obligations and the commitments made in this Privacy Notice for Candidates.

During the selection process, Nubank may collect the following personal data:

  • Registration data (such as full name, date of birth, address, phone number, email address)
  • Information related to your application (such as resume, cover letter, details of previous jobs, employment documents)
  • Information related to your interest in the selection process, such as desired salary, benefit packages, and other work preferences
  • Links to professional social media profiles (e.g., LinkedIn) or to external and personal websites, if you choose to provide them
  • Information obtained through third parties, such as references, recruitment agencies, and background check providers (if applicable)
  • Information obtained during in-person and remote interviews and other stages of the selection process
  • Publicly available information about you (such as in open social media profiles). Nubank is not responsible for the processing of your data carried out by the platforms that disclose them (and which have their own privacy notices)
  • Sensitive personal data (such as ethnicity, race, sexual orientation, disabilities). The submission of this data is optional, and providing or not providing this data will not prejudice you in any stage of the selection process. The data we collect will be anonymous, and the information obtained from them will be used solely to improve internal processes
  • Other personal data that you choose to inform

You are aware that if you do not agree to share some of this data with Nubank, it may be impossible for Nubank to proceed with the selection process.

3.Purposes of Personal Data Processing

In the context of our selection process, Nubank may process your personal data for the following purposes:

  • Manage and control resumes of candidates for available positions
  • Evaluate candidates' skills, qualifications, and interests concerning the selection process and other career opportunities (if applicable)
  • Communicate with candidates about the selection process
  • Conduct personal and professional reference checks and/or background checks (if applicable)
  • Identify illegal, discriminatory behaviors or those that violate our Code of Conduct (if applicable)
  • Generate statistical reports and record the history of candidates
  • Improve our application and recruitment process
  • Develop and promote diversity policies at Nubank
  • Comply with legal and regulatory obligations, including the Brazilian Inclusion of Persons with Disabilities Act (No. 13.146/15)
  • Enable the regular exercise of Nubank's rights

For some positions involving access to our clients' financial data and/or Nubank's strategic data, we will need to conduct due diligence checks (criminal and/or financial). For this specific purpose, Nubank will inform you when the due diligence check is necessary and, if required, will request some additional data, such as your full name, your mother's full name, your birth date, your RG or passport number, and your CPF.

4. Sharing of Personal Data

Nubank may share your personal data if you request it or also with companies that are part of Nubank, with partners, or with regulatory authorities and bodies for different purposes. This data sharing, when necessary, will be done within the limits and purposes of our business and in accordance with applicable law.

Below, we present the main possibilities for data sharing under Nubank's control.

  • Responsible employees: Nubank departments/employees who need access to personal data of candidates to evaluate their applications and enable the conduct of the selection process
  • External service providers: such as platforms and agencies specialized in recruitment and selection, partners who assist in advising on the requirements for hiring a foreign person, partners who provide relocation and moving services (if applicable). These partners have been carefully selected by Nubank and are contractually obligated to process this data in strict accordance with applicable data protection laws
  • Competent authorities' requests: to respond to investigations, legal proceedings, measures related to illegal activities, fraud suspicions, as well as to meet legal reporting requirements, or if otherwise required by law
  • New business ventures: in cases where Nubank is involved in a merger, acquisition, or sale of all or part of its assets

5. Retention and Deletion of Personal Data

When applicable, and even after the conclusion of the selection process, Nubank may store your personal data for an additional period for audit purposes, compliance with legal or regulatory obligations, regular exercise of Nubank's rights, or also for the necessary period according to the legal basis that justifies the data retention. But don't worry: your personal data will always be kept in a secure and controlled environment and will be deleted or anonymized as soon as their maintenance is no longer necessary or justifiable according to the legal bases of LGPD.

6. Your Rights as a Data Subject

As a data subject, the candidate can exercise their rights before the data controllers. We provide below the mechanisms for you to clearly and transparently understand how to exercise your rights:

  • Confirmation of the existence of personal data processing

Being a candidate for an open position at Nubank already means we process your personal data, even if this processing includes, among others, storing personal data in a secure and controlled environment. You can request Nubank to confirm whether it processes your personal data.

  • Access to personal data

You can request Nubank to inform and provide the personal data it holds about you, respecting trade secrets, in accordance with the LGPD.

  • Correction of incomplete, inaccurate, or outdated personal data

If you find that your personal data is incomplete, inaccurate, or outdated, you can request the correction or completion of this data at Nubank. For this, if it is not possible to make the change via the Nubank app, you will need to send a document proving the correct and current form of the personal data.

  • Anonymization, blocking, or elimination of unnecessary, excessive, or non-compliant data

If any personal data is processed unnecessarily, excessively for the intended purpose, or in non-compliance with the LGPD, you may request Nubank to anonymize, block, or eliminate this data, provided it is effectively verified, after internal checks, the excess, lack of necessity, or non-compliance with the law.

  • Elimination of personal data processed with consent

If you have consented to the processing of your personal data for specific purposes (which are not indispensable for participation in the selection process), you may request the elimination of this personal data.

  • Information on third-party data sharing and receipt

You can request that Nubank inform which third parties have shared or received your personal data.

  • Information on the possibility of not providing consent and the consequences of consent denial

If your consent is necessary to participate in the selection process, you can request that Nubank clarify if it is possible to participate in the process without your consent for the processing of your personal data, or what the consequences of non-consent would be.

  • Withdrawal of consent

If you have given your consent for the processing of your personal data for specific purposes (which are not indispensable for participation in the selection process), you can request the withdrawal of this authorization. The withdrawal of consent may impede certain phases of the selection process but does not prevent Nubank from using anonymized data and data whose processing is based on another legal basis under the LGPD.

  • Automated decisions

If Nubank makes decisions that affect your interests based solely on automated processing of your personal data during the selection process, you may request a review of these decisions and an indication of the criteria used in them, preserving trade secrets, the protection of confidential information, and competition preservation. It is important to note that Nubank does not guarantee a different result from the initial decision but ensures that our technological models are consistent and based on legal and ethical principles.

  • Portability and right to petition

When the right to portability is regulated by the National Data Protection Authority (ANPD), you may request Nubank to transfer your personal data to another service provider. Additionally, you have the right to petition the ANPD concerning your personal data.

If you wish to exercise any of these rights, please contact our Data Protection Officer (DPO) at dpo@nubank.com.br. To implement your rights, we may request proof of your identity as a security measure and fraud prevention. It is worth noting that the above rights are not absolute, and we may fulfill them partially or may be unable to fulfill them in specific situations, such as when there is a need to comply with legal and regulatory obligations.

7. International Data Transfer

Your personal data may be transferred to other countries (e.g., when stored by Nubank on cloud computing servers located outside of Brazil). In this case, Nubank follows all requirements established by applicable legislation and adopts best security and privacy practices to ensure the integrity and confidentiality of your personal data.

8. Security Measures

Nubank employs various types of security measures to ensure the integrity of your personal data, such as industry-standard information security practices when collecting and storing personal data. Personal data may also be stored through cloud computing technology and other possible future technologies, always aiming to improve and enhance our services and security.

We have a robust, highly qualified team responsible for ensuring that Nubank adopts the best security practices, including:

  • Multiple factor authentication for information access
  • Security as code to enable automation and quick, efficient responses to security events in the technological environment
  • Encryption for data at rest, in transit, and in use to ensure information integrity
  • Continuous environment monitoring
  • Continuous information security analyses and tests in our systems, conducted by internal and external teams
  • Periodic audits

We also recommend that you always be careful when sharing your personal data on social media or any other public environment. To learn more about digital security, access our blog.

9. Changes to the Privacy Notice for Candidates

Nubank may change this Privacy Notice for Candidates at any time, at Nubank's discretion. To check the effective version date, see the "Last updated" date at the end of this document.

Whenever the Privacy Notice is significantly changed, the changes will be valid, effective, and binding after the new version is published on our website or sent via email. If you continue using our services after changes are made to the Privacy Notice, this means that you agree with the new terms.

10. Contact Us

Under the LGPD, Nubank is considered the "Controller" of your personal data. If, after reading this Privacy Notice for Candidates, you still have any questions, or if for any reason you need to contact us regarding your personal data, you can reach out to our Data Protection Officer (DPO) via email at dpo@nubank.com.br.

We are always available to clarify your doubts and put you in control of your personal data.

Last updated: August 30, 2024