WARNING OF
PRIVACY

Privacy Notice to Employees

Privacy Notice to Employees

1. INTRODUCTION

i3Com & Media, ahead i3com, is committed to protecting the privacy and security of the personal/professional data of its candidates, interns, trainees, employees – with an employment relationship, without an employment relationship and outsourced workers –, hereinafter referred to simply as “Employee” or “Collaborators”.

This Privacy Notice to Employees, hereinafter referred to as PRIVACY NOTICE, is directed to the Employee, who should read it carefully, considering that it presents the context in which the i3com will process your personal/professional data, so that you are aware of how and for what purposes the i3com will use your personal/professional data and what your rights are with regard to the protection of your respective personal/professional data. Therefore, the i3com suggests to all your employees, reading this PRIVACY NOTICE, in order to avoid ignoring it.

In this PRIVACY NOTICE the Employee is informed: (1) about which personal/professional data are processed by i3com; (2) for what purposes and for how long they are used and stored; (3) with whom they can be shared; (4) the extent of privacy and level of security of personal/professional data; (5) what Users’ rights are in relation to the processing of their personal/professional data.

Other information and notifications may be sent to Users in the future, regarding activities related to the processing of personal/professional data by i3com.

Unless otherwise stated, the i3com is responsible for processing the personal/professional data provided by the Employee. It is the top priority of i3com respect your rights to data protection.

2. DATA COLLECTION AND STORAGE

A i3com may collect personal/professional data, including sensitive personal data, belonging to one or more data categories listed below:

I. Full name;
II. Gender and gender identity;
III. Date of birth;
IV. Nationality;
V. Birthplace;
SAW. Date of naturalization, if applicable;
VII. Home telephone number;
VIII. Cell phone number;
IX. Emergency contact;
X. Marital status;
XI. Full address, including geolocation;
XII. Electronic Address (email);
XIII. CPF number;
XIV. RG number;
XV. Voter ID Number;
XVI. Reservist Certificate, if applicable;
XVII. CNH data;
XVIII. Passport Data;
XIX. Visa Data;
XX. Data from the Employment and Social Security Card, including salary remuneration, benefits, among others;
XXI. PIS number;
XXII. Information on union membership, if applicable;
XXIII. Data on the Employee's academic or professional background, including data related to diplomas, certifications or other professional/curricular information (education level, profession, information on professional experience, employment relationship, current and previous positions, performance and performance evaluation, academic training and training, curriculum vitae);
XXIV. Admission and dismissal medical examinations;
XXV. Information about medical or health conditions, including possible disabilities and special needs;
XXVI. Vaccination card, including those of dependents;
XXVII. Date of admission to i3com;
XXVIII. Position and functions performed at i3com;
XXIX. Data related to internal legal inquiry or investigation processes, including in the context of anti-corruption;
XXX. Information of any disciplinary or grievance procedures, including any warnings issued;
XXXI. Date of contractual termination with i3com;
XXXII. Updated Proof of Residence;
XXXIII. Bank information;
XXXIV. Declaration of Exemption from Conflict of Interest;
XXXV. Secrecy and Confidentiality Agreement, Prevention of Unfair Competition and Evasion, Protection of Capital/Intellectual Property;
XXXVI. E-mails, messages in internal systems and records of network use, files in systems, among others;
XXXVII. Electronic identification data from access records (login, access rights, passwords, card number, IP address, date of access and connection times), navigation (browser and pages accessed, links, hyperlinks, content and services clicked on ) and device (hardware model, operating system and device identifiers);
XXXVIII. Information regarding compliance with obligations arising from the employment contract;
XXXIX. Performance management information, including assessments and training;
XL. Information about health and life insurance;
XLI. Name of the Employee's parents;
XLII. Information about the Employee's dependents, such as: name, gender, age, ID, CPF, among others;
XLIII. Information about criminal convictions;
XLIV. Signature, photographs, videos and digital biometric information, collected for i3com security systems;
XLV. Recorded closed circuit television (CCTV) sounds and images;
XLVI. Other relevant information, as applicable and required by law, in order to ensure compliance with obligations as an employer.

Data may be collected directly from Employees, or may be obtained through third parties and ∕ or through publicly available databases, in accordance with applicable legislation.

A i3com does not collect any data that is not necessary for the services provided, or that has a purpose other than those stated.

The collection of personal data can take place in different locations, pages and tabs on the Website, by filling out registration forms, chat, among others.

A i3com undertakes to take the necessary measures so that any sharing of data by third parties or collection from public sources complies with the data protection guidelines established by law applicable to the data subject's location, – eg  General Data Protection Law (LGPD) or General Data Protection Regulation (RGPD) –, and respect the limits of necessity and adequacy of data to fulfill the legitimate purposes informed in this PRIVACY NOTICE.

A i3com will ensure that subsequent use of this information complies with applicable personal/professional data protection laws.

2.1 – DATA UPDATE

It is important that the i3com keep the personal/professional data of Employees accurate and updated. To do so, keep the i3com informed of any changes or inaccuracies.

2.2 – OUTSOURCED PARTIES

In particular, in cases where services are provided by third parties, the i3com You may have access to the labor and social security documentation of the people involved in providing the services, as indicated above, which are the exclusive responsibility of the respective employers. A i3com also carries out processes to check the suitability and background of companies providing services, which may eventually affect personal/professional data of the owners or partners of these companies.

3. PURPOSES AND DURATION OF TREATMENT

A i3com carries out data processing activities, in accordance with the data protection guidelines established by law applicable to the data subject's location, and such data may be used for one or more of the following purposes, namely:

I. Archive and retention of documentation in general, among other contact and communication information with Employees, including information about vacancies, i3com and its businesses, and career advancement opportunities for hired Employees;
II. The selection process for recruiting, selecting and hiring Employees, including checking the Employee's personal and professional history;
III. Compliance with legal or regulatory obligations by i3com, for example, in relation to proving the qualification and qualification of Employees to perform their role;
IV. The execution of the contract between i3com and the Employee, including, as applicable, the exercise of their prerogatives and obligations as a contracting party;
V. Ensure effective administration of people management, based on performance evaluation and workforce management, in order to ensure that Employees are receiving the remuneration or other benefits to which they are entitled;
SAW. Management and fulfillment of employment or service provision contracts, granting benefits to Employees and dependents, as well as legal and regulatory duties of custody and information;
VII. Management of vacations and absences, including Employee leaves and sick leave;
VIII. The investigation of irregularities and illicit acts committed by Employees in the performance of their duties before i3com;
IX. Carrying out institutional training with Employees and procedures related to training management, including Employee learning and development management;
X. Maintaining accurate, updated and detailed records of contracts with Employees, including vacation and absence records, disciplinary processes and contractual rights;
XI. The registration and creation of Employee institutional profiles in the technology systems used by i3com, according to the need to perform their functions;
XII. The inclusion of the Employee as a representative of i3com in contracts, proposals and documents in general;
XIII. Identification and access to i3com’s physical facilities;
XIV. Monitoring activities at i3com facilities, in order to ensure the prevention of fraud and illegal conduct on the part of any Employee;
XV. Ensure the management of i3com's physical and information security, based on monitoring images and any and all access to i3com's devices or electronic systems;
XVI. Ensure the preservation of i3com's assets and economic interests;
XVII. Provide a reference letter at the request of the current or former Employee;
XVIII. Provide information and/or documentation to authorities within the scope of judicial, administrative or arbitration proceedings, in compliance with legal, regulatory or any other duties lawfully required of i3com, or in defense of its rights and legitimate interests.

Only for the purposes below, sensitive personal/professional data may also be processed to:

I. Compliance with legal and regulatory obligations and the exercise of contractual rights and in judicial, administrative or arbitration proceedings;
II. Compliance with obligations under collective labor law, in particular, towards unions to which the Employee is linked;
III. Fulfillment of fiduciary duty by all of its Employees, including reporting and accountability;
IV. Occupational health management, including the management of medical certificates and registration of the Employee's corresponding form and verification of qualification to perform the role with i3com, when applicable;
V. Management of the governance system, including risk and compliance monitoring.
SAW. Information security and intrusion detection;
VII. Access control, based on digital biometric identification in i3com electronic systems;
VIII. The generation of statistics, studies and research, especially those related to corporate sustainability;
IX. Promoting equality, diversity and inclusion at i3com;
X. Collaboration with or compliance with a court order, competent authority or supervisory body;
XI. Any other purposes imposed by law and authorities.

A i3com is aware of the sensitivity of this data and the greater potential impact on your privacy, taking additional protective measures, including against its indiscriminate use.

In certain situations, the i3com You may also contact the Collaborator to obtain their express consent to allow the use of their personal/professional data for specific purposes. In these cases, the i3com will indicate the necessary data and explain how it will be used and for what purposes, so that you can carefully consider whether or not to authorize the use of this data. You can always refuse consent to the use of data in these situations, as they will not be an essential condition of your contract with the company. i3com.

In accordance with national legislation, the i3com will store and process Employee data for the period necessary to fulfill the respective purposes for which it was originally obtained, including to comply with legal and regulatory obligations and to defend the rights of the Company. i3com, including in legal proceedings (judicial, administrative or arbitration), as well as for the fulfillment of contracts and exercise of rights of the i3com and third parties. Even after the end of the contract between the Employee and the i3com, certain personal/professional data of Employees may continue to be processed to fulfill the purposes listed in this PRIVACY NOTICE.

3.1 – RETENTION OF PERSONAL/PROFESSIONAL DATA

A i3com will keep your personal/professional data for as long as necessary to fulfill the purposes described above, unless a longer retention period is required or permitted by law, or is necessary to comply with legal obligations, protect your rights or comply with legal/legal agreements. extrajudicial.

If the Employee has questions about the retention and disposal practices of personal/professional data by i3com, you can contact the communication channel with holders of personal/professional data, from the following email address: info@i3com.com.br.

4. SHARING OF PERSONAL/PROFESSIONAL DATA

A i3com may share your personal/professional data with third parties, only to the extent that is strictly necessary to carry out the purposes listed in this PRIVACY NOTICE and in accordance with one or more hypotheses listed below, namely:

I. If the third party in question is a service provider or commercial partner responsible for the processing of personal/professional data on behalf and in the interests of i3com;
II. If the third party in question is an official public body or entity, regulatory, governmental, police or judicial authority, legitimately requesting information in the context of supervision, audits, processes or regular legal procedures and which constitute legal obligations binding on i3com, or if necessary to comply with legal obligations or to exercise the rights of i3com or third parties;
III. If the third party in question is public bodies and private companies of public interest, for the development of employment contracts, payments and compliance with legal and regulatory obligations of a fiscal, labor, union and social security nature;
IV. In the context of a merger, acquisition and incorporation of assets or corporate/shareholding sale involving i3com;
V. For audit, due diligence and compliance activities;
SAW. With the aim of verifying the Employee’s right to work in the country;
VII. To operationalize payments and enable the contracting of benefits in favor of Employees;
VIII. When i3com has obtained the Employee's free, unequivocal and express consent for data sharing.

A i3com has corporate policies and standards regarding security in sharing data with third parties to comply with legislation and protect Employee privacy.

Some Employees may be located in other locations than their headquarters and, in this case, the i3com adopts additional safeguards to guarantee an adequate level of data protection, in accordance with the legislation of the respective countries.

5. SAFETY AND PLACE OF TREATMENT

A i3com has a privacy and personal/professional data governance program based on policies and rules related to data protection under the constant surveillance of its person in charge of protecting personal/professional data.

A i3com is responsible for adopting and maintaining reasonable security, technical and administrative measures to prevent irregular or illicit processing of Employees' personal/professional data, including unauthorized access, destruction, loss, alteration or communication of data. All data controllers of the i3com are subject to confidentiality obligations.

In addition i3com adopts information classification measures to guarantee the confidentiality, integrity and availability of the personal/professional data it controls, in accordance with the state of the art and best practices in the sector.

A i3com adopts safeguards, including contractual ones, to maintain the rights of Employees, as well as the confidentiality, integrity and security of information. Some personal/professional data of Employees may be processed outside the jurisdiction of the headquarters i3com, but will still comply with the data protection guidelines established by law applicable to the data subject's location.

6. RIGHTS OF THE HOLDER OF PERSONAL/PROFESSIONAL DATA

The following data subject rights may be exercised at any time by the Employee upon request, in accordance with legislation and in accordance with the Corporate Governance practices adopted by i3com:

I. Confirm the existence of processing of personal/professional data;
II. Receive more information about how and why we process your personal/professional data;
III. Access personal/professional data controlled by i3com; IV. Correct incomplete, inaccurate or outdated personal/professional data;
V. Block or delete unnecessary, excessive or processed data that does not comply with the provisions of this PRIVACY NOTICE;
SAW. Request the deletion or anonymization of personal/professional data processed, except when the law authorizes the maintenance of this data for another reason;
VII. Be informed of the public and private entities with which i3com may have shared your personal/professional data;
VIII. Revoke consent, when the processing was carried out based on the holder’s consent;
IX. Review fully automated decisions that affect your interests.

6.1 – EXERCISE OF HOLDER’S RIGHTS

A i3com will facilitate the exercise of rights by data subjects, whenever possible and in accordance with the law and its internal Corporate Governance guidelines. A i3com has a specific communication channel to manage communications with data subjects and enable the exercise of rights.

When the i3com receive a request to exercise any of your rights, the i3com will evaluate the best way to fulfill it, but may stop complying with your request, in whole or in part, if it has a fair reason and in specific circumstances, such as to comply with a legal obligation or the contract it has with you. If you do not receive a response, you can take your request to the national data protection authority.

Employees may make any complaint, request or request for information related to the processing of their personal/professional data, including the exercise of data subject rights.

When the Employee contacts the i3com for the exercise of its rights as holder, the i3com may collect information for the purpose of confirming the identity of the data subject, to the extent of their interest and security.

7. AUTOMATED DECISIONS

We do not intend to make any decisions, based solely on automated processing (i.e. without human involvement), that have a legal or significant effect on Collaborators.

8. CONTACT REGARDING YOUR PERSONAL/PROFESSIONAL DATA

For any questions about the privacy and data protection policies and rules of i3com, regarding the data that the i3com has about you, or any other request or complaint regarding your privacy or your rights listed above, please contact the person responsible for processing personal/professional data, at the following email address: info@i3com .com.br.

The person responsible for processing personal/professional data is the person responsible for complying with the Law and monitoring its performance in relation to it.

9. UPDATES TO THE PRIVACY NOTICE TO EMPLOYEES

This PRIVACY NOTICE aims to provide clarification and transparency regarding the practices of i3com related to the privacy, protection and security of its Employees’ data.

A i3com regularly reviews its Policies to ensure their applicability. Therefore, this PRIVACY NOTICE may be changed, replaced and updated periodically, that is, at any time, so that the i3com may publish new guidelines that may be adopted in its Policies. Collaborators are recommended to periodically revisit the Cookies Policy, the Privacy Policy and Website Terms of Use, the Privacy Policy and General Conditions of Use of the Restricted Area and the Privacy Policy and General Conditions of Use of the User Area, once which are the basis of this PRIVACY NOTICE.

A i3com review and update this privacy information whenever you plan to use personal/professional data for any new purpose. Any changes to this privacy information or expansions in the processing of Employees' personal/professional data will be communicated/notified in advance, through the usual communication channels. In cases where changes or updates have occurred in the management (collection/storage and purposes/use) and rights over the data collected and processed, the data subject will be allowed to revoke their consent if they disagree with the content of the changes. By continuing to browse any of the platforms on the i3com, the data subject agrees to all changes or updates.

All changes must be considered to be immediately applicable and effective, except in the case of communication to the contrary sent by i3com to data subjects.

A i3com will take reasonable measures to communicate Collaborators about updates to the terms of this PRIVACY NOTICE.

This PRIVACY NOTICE was published on May 6, 2024.