Recruitment Privacy Notice

We collect your personal data from the following sources:

• Application for vacancies: through forms that you fill out and resume or curriculum (CVs) - in a file format or link of professional social media websites (such as LinkedIn) - that you send us when you apply for any selection process published on LinkedIn, on our website or other means that lead you to our recruitment platform. We also collect personal data that you provide to us during the interviews.

• CV submission: when you send us your CV or otherwise contact us by email, in person or via Linkedin chats in order to compose our database for application in job or internship opportunities;

   

• Referral: through the indication of Incognia employees and partners who recommend your profile to us so that we can make contact to invite you to participate in any of our recruitment and selection processes or even to schedule an interview;

• Active search: through consultations on the internet, mainly on Linkedin, including with the support of recruitment platforms used by Incognia, we may collect publicly available professional data about you, especially contact information, in order to invite you to participate in our recruitment and selection process for a vacancy related to your profile or even to learn more about your professional profile and proceed with your selection process.

• References: we may obtain information about your background and professional characteristics by contacting any professional reference that you have referred to us or that we have identified as important for obtaining references about you.

We only collect and process personal data related to your professional profile and that are necessary to achieve the processing purposes related to the recruitment and selection process.

The types of data we process depend on the information you make available to us and the information about you that is publicly accessible on your professional network, such as LinkedIn, or other public reference sources.

This data usually includes:

• Name
• E-mail
• Phone number
• Address
• Professional experience
• Academic history
• Gender (for diversity program application purposes, as an optional information)
• Professional network profile
• Professional references
• Information from interviews, technical assessments, or group activities conducted during the selection process.

In case you are approved for the final stage of the selection process and receive your offer letter, depending on your position or area of ​​work at Incognia, additional personal data may be collected for background check analysis purposes, in accordance with Incognia's Background Check Policy. If this check is applicable to you, it will be conducted by specialized suppliers contracted by Incognia, always within the terms and limits of applicable laws, and you will be informed of your eligibility and receive more information about the process and what personal data may be involved.

Other personal data may be collected during the formalization of the employment, internship, or apprenticeship contract, exclusively for compliance with legal, contractual, or regulatory obligations. In certain countries, this formalization may occur with the support of local hiring partners, in which case only the strictly necessary data will be shared to enable the registration of the hiring in accordance with applicable legislation.

By default, we do not collect sensitive personal data during the recruitment and selection process. However, we can collect sensitive personal data about you to the extent permitted to do so by applicable laws (e.g., U.S. equal opportunity laws) and to support our efforts to create an inclusive and diverse work environment. All our data processing, specially when involving sensitive personal data, respects the principles of transparency and non-discrimination.

Your personal data is processed for the exclusive purpose related to the development of the stages of our recruitment and selection process, which includes the following purposes:

• Evaluate your skills, qualifications, and experience for the applied position;
• Conduct interviews, technical assessments, and selection dynamics;
• Identify potential candidates for professional opportunities compatible with their profile, including through active search based on publicly available professional information.
• Establish communication during the recruitment and selection process;
• Based on your consent, send personalized information about future job opportunities;
• Conduct background checks, when applicable, in accordance with the Background Check Policy;
• Execute preliminary contract procedures, if you are approved;
• Support diversity and inclusion programs, in cases where you choose to provide sensitive data (such as gender and race/ethnicity);
• Maintain a history of selection processes for internal management purposes;
• Comply with legal, regulatory, or contractual requirements.

We may also use your personal data for Incognia analytics purposes, including in aggregated, anonimized or pseudonymized form, to improve our selection and recruitment process, as well as augment our ability to attract successful candidates.

As we make all decisions about the processing, we act as Controllers of your personal data.

We use the legal basis of legitimate interests to justify most of the processing of your personal data that we carry out during the recruitment and selection process, unless applicable local laws require the use of another specific legal basis. In such cases, Incognia will ensure that the appropriate legal basis is identified and documented in accordance with the data protection framework applicable to the candidate’s location.

We also make use of the consent base to store your data for a specified period with a view to its application in future new employment and internship opportunities that are suitable for your professional profile. You can always revoke your consent at any time and free of charge.

When you are approved in any selection process, we use the legal basis for the execution of preliminary procedures to the contract or contract execution for the processing of your personal data in order to proceed with the formalization of your employment or internship contract.

In addition, we use the basis of compliance with a legal or regulatory obligation when the processing of your data takes place by virtue of any law or regulation to which we are subject. Other legal bases may be used to justify the processing of your personal data, depending on the related processing purpose and application in each specific scenario.

Certain roles may require specific technical prerequisites or skills which, when not fulfilled, may cause your automatic disqualification from the selection process. For example, if knowledge about a certain system is an essential condition for you to apply for any of our vacancies and you respond that you do not meet those requirements, you will be automatically disqualified. In any case, you can request the review of this automated decision by registering your right request by sending an email to our Data Protection Officer (“DPO”) dpo@incognia.com.

Your personal data may be shared strictly on a need-to-know basis with:

• Recruitment platforms and specialized service providers engaged by Incognia to support specific stages of the selection process, such as application management, technical assessments, or background checks;
• Cloud service providers responsible for securely hosting systems and databases used in the recruitment process;
• Local hiring partners, solely when required to formalize the employment relationship in countries where Incognia does not have a legal entity of its own;

Your data is also shared internally with members of the People (human resources) team, leaders, or other employees/departments that may participate in decision-making during your recruitment and selection process.

Your personal data is stored on internal platforms and tools to which physical, technical and organizational security measures are applied. In addition, your personal data is accessed by a restricted number of employees only when strictly necessary to perform their functions related to the recruitment and selection processes. It should be noted that all our employees sign confidentiality agreements and undergo training on privacy and data protection.

If you are approved and accept an offer of employment with us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific requirements contained in our internal policies, which will be accessible for you after your hiring.

If you are not hired by Incognia, we will store as little personal data as possible, considering a strict limit of the need to achieve the purpose of registering your recruitment activities with us. Your other data will be securely and definitively deleted, unless you have provided your consent to keep them at Incognia for participation in future recruitment and selection processes, when your data will only be kept for the period previously authorized to.

Exceptionally, we may retain some of your personal data for longer for the purposes of audits, accountability, compliance with legal or regulatory obligations, compliance with court orders and the regular exercise of rights in judicial and administrative proceedings.

We adopt technical and administrative measures capable of protecting your personal data from unauthorized access and from accidental or unlawful situations of destruction, loss, alteration, communication or dissemination. We apply access management techniques and appropriate physical, electronic and procedural mechanisms to protect your personal data.

In addition, we have documented and implemented internal policies, controls and procedures to deal with any security incidents.

As a global company, Incognia recognizes and respects the privacy and data protection rights granted to individuals under the laws applicable in each country where we operate.

While the specific scope and conditions of these rights may vary according to local legislation, Incognia is committed to ensuring a consistent level of transparency, access, and control over personal data for all candidates, regardless of their location.

In general, candidates may exercise the rights established under the applicable data protection framework, or other equivalent regulations. Check below a simplified list of your rights, according to the provisions of the GDPR and CPRA:

• Confirmation of the existence of processing of your personal data;
• Know what Personal Data is being collected and with who we share it with;
• Request the deletion of your Personal Data, in some specific cases;
• Access to your personal data;
• Correction of incomplete, inaccurate or outdated data;
• Data portability;
• Deletion of personal data processed with your consent, except in cases provided for by applicable laws;
• Non-discriminatory processing for exercising any rights;
• Right to limit use and disclosure of sensitive personal information;
• Information about the possibility of not providing your consent and about the consequences of your refusal;
• Withdraw your consent;
• Opposition to processing carried out on the basis of legitimate interests;

To access your rights, you must contact our DPO by sending an email to dpo@incognia.com.

If you have any questions, comments, requests or suggestions, you can contact our DPO directly by sending an email to dpo@incognia.com

We may update and change the terms of this Privacy Policy from time to time. On our website you will always find the latest version and, if you want, you can access eventual previous versions by registering a request by sending an email to dpo@incognia.com.

Incognia Inc.

333 W San Carlos St, Suite 600, San Jose, CA 95110

DPO: Dayana Caroline Costa

Deputy DPO: Rayanne Conceição de Almeida Santos

DPO contact: (dpo@incognia.com)