Privacy Policy

Last updated on: March 6, 2023

1. Object

At Kinp Group, privacy and security are priorities and we are committed to transparency in the processing of our users/client’s personal data. Therefore, this Privacy Policy establishes how the collection, use and eventual transfer of information from clients, legal representatives, candidates that we prospect or other people that may be related to our main activity of talent management through recruitment and selection is carried out. 

By using our services and agreeing to data processing, you understand that we will collect and use your personal information in the ways described in this Policy, under Data Protection rules (LGPD, Federal Law 13.709/2018), consumerist provisions of Federal Law 8.078/1990 and other applicable rules of the Brazilian legal system. 

In this way, KINP RECURSOS HUMANOS LTDA, a legal entity governed by private law, simply referred to as "KINP GROUP", registered with the CNPJ, under No. 27.401.536/0001-75, with headquarters located at Av. Queiroz Filho, 1560, room 107, Torre Beija Flor, Vila Hamburguesa, in São Paulo/SP, CEP 05.319-000, in the role of data processing agent collected through the aforementioned channels, is bound by the provisions of this Privacy Policy.

2. Terms and definitions

For a better understanding of this policy, we have listed some of the most important definitions of the General Law for the Protection of Personal Data - LGPD, namely:

  1. Personal data: information related to the identified or identifiable natural person, that is, any data that allows identifying, even indirectly, the natural person to which they belong;
  2. Sensitive personal data: personal data about racial or ethnic origin, religious conviction, political opinion, union affiliation or organization of a religious, philosophical or political nature, data referring to health or sexual life, genetic or biometric data, when linked to a natural person;
  3. Data subject: natural person to whom the personal data object of processing activities refers.
  4. Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  5. Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;
  6. Operador de dados: pessoa natural ou jurídica, de direito público ou privado que realiza o tratamento de Dados Pessoais em nome do controlador e sob suas ordens.
  7. Data Protection Officer (DPO): natural person appointed by the controller, who acts as a channel of communication between the controller and the data subjects and the supervisory authority; which can be contacted via email dpo@kinpgroup.com.

3. Purposes of processing Personal Data 

The main objective of the LGPD is to protect the rights related to the privacy of the Personal Data of individuals, with the assurance that there will be no processing of personal data for discriminatory purposes and in disagreement with those informed to the data subject, or undue and/or harmful treatments. Also determining the legal justifications that instruct the processing of data and establishing the most appropriate procedures to guarantee the privacy and security of the data of the data subject. Therefore, Kinp Group considers as some of its purposes:

  • Satisfactory performance of the Contracts;
  • Due diligence for contracts signed with customers;
  • Enable the provision of its services, mainly through the creation of its talent bank with potential candidates for executive vacancies available at its clients;
  • Guarantee of rights;
  • Compliance with legal obligations;
  • Protect information contained in processes and systems;
  • To serve Kinp Group's legitimate interests;
  • Exceptionally for other purposes, but always based on the legal bases permitted by the LGPD.

Third party services

This Privacy Policy only applies to information provided by Kinp Group. Our services may, eventually, incorporate services provided, and in this way, the information made available to us may be shared with them. However, if a customer has the option of choosing a product/service offered by a third party, or integrating it with Kinp Group's services on his own , he will be subject exclusively to the Privacy Policies of the third party for that product/service, which may contain provisions different from those found in this document.

5. Collected data

5.1. Data you provide us:

5.1.1. On our site

To contact us, you can send a message in the “Contact” tab containing: full name and e-mail address. 

In the “Vacancies” tab, interested parties will be asked to provide the following personal data for application: full name, e-mail address, telephone number, city and other personal data that are, at the candidate's discretion, included in the curriculum sent.

5.2. Data we collect about you:

5.2.1. Talent bank creation and management 

Our main activity is to find qualified professionals who can be integrated into the team of clients who seek us to fill strategic vacancies, especially executive ones. For this purpose, we may collect, primarily through the Linkedin social network, the following personal data: full name, telephone number, e-mail and, in some cases, region of residence. In this framework, Kinp Group declares to be the controller of your personal data.

Urges to point out that we may collect some sensitive data about you, such as: remuneration (salary range) and gender and ethnicity (in cases where it is necessary for affirmative policies and diversity programs, or, even, when integrated, by mere liberality, to the resume you send us). In this context, pursuant to article 11, I, of the LGPD, data will be processed under the legal basis of consent that will be provided by you on our data management platform. 

5.2.2. Completion of registration form (admitted candidates)

In some less numerous cases, we may be responsible for filling out a registration form for admission of the candidate to a vacancy of our clients. In these cases, in addition to the previously mentioned identifying data and personal characteristics, we may have access to the following personal data: CPF, RG, address, among other data required by the form. Please note that, in this case, Kinp Group acts as the operator of your personal data, processing them on behalf of our client and for the purpose indicated by him.

5.2.3. Your device, if you browse our website (users)

When using our website, we may collect information about your computer or device, including your IP address, location, operating system, browser information, information about your visit, your browsing history and how you use our website. These types of data are collected by cookies and related technologies. When accessing our site for the first time from certain jurisdictions, including the Brazilian jurisdiction, you will receive a message notifying you that cookies and similar technologies are in use. By clicking "Accept" you indicate that you understand and agree to the use of these technologies.

Our customers

For the elaboration and contractual execution of an instrument for the provision of our services, we may collect, in addition to data from the entity (legal entity), personal data from its respective legal representative(s), including: full name, address and CPF.

For the sole purpose of performing our services and necessary communications, we may collect data from our customers' employees, including: full name and contact details (e-mail, telephone).

General Provisions:

You are fully responsible for the veracity of the data provided for the purposes described here.

Kinp Group is not subject to processing or treating any of your data if there are reasons to believe that such processing could impute to us any violation of any applicable law, or if you are using our services, products and website for any illegal, illicit purposes or contrary to morality.

The database structured through data collection is the responsibility of Kinp Group, so that its use, access and sharing, when necessary, will be carried out within the limits and purposes described in this 

With whom we share your data

Kinp Group is authorized to share your Personal Data with other data processing agents, if necessary for the purposes set out in this term, subject to the principles and guarantees established by Law No. 13,709/2018, pursuant to art. 7, paragraph 5 of said rule.

Furthermore, Kinp Group uses reliable services and technologies that follow acceptable security standards and are subject to confidentiality and data protection obligations. Your data will be shared with the following third parties, always in accordance with this policy and applicable legislation.

  • Government Authorities: to comply with legal, judicial, administrative determinations and offices of competent authorities, as well as to take or provide legal, judicial and administrative measures to defend our rights set forth in this Policy, including in any judicial or administrative proceeding. It is understood by Government Authorities, police authorities, data protection, public entities and/or other governmental organizations.
  • ClockWork Platform: for the registration and management of data from our talent bank, containing data on current, past and potential candidates, we use the ClockWork service, which here is configured as the operator of the personal data kept therein.
  • Customers: as a direct result of the nature of our activity, we indicate to our clients the names of candidates who meet the established prerequisites, have the necessary qualities and who we believe are in line with the purposes of any vacancy available. 
  • Companies in our trading group: we may share data from our talent bank and customer representatives to the Kinp Group located in the United States, always ensuring that we maintain the same level of security measures undertaken to protect data.
  • Cloud Storage Providers to third-party cloud service providers to host the data processed by Kinp Group. In these circumstances, your Data remains stored and processed by Kinp Group. 
  • Business Partners: to run, improve and grow our business and services, and/or develop new business.
  • Business procedures: we may also share your data in the event of corporate movements, such as, for example, mergers, acquisitions and incorporations involving Kinp Group.

Declaration of non-sharing – It is worth mentioning that Kinp Group, under no circumstances, shares your Personal Data with third parties not listed above. If you receive contact from unidentified third parties, please contact us through the channel indicated in this Policy and we will assist you in investigating the incident.

Storage of personal data

In order to ensure the applicability of information security principles through the introduction of solid and standardized security controls, Kinp Group partners may be asked to implement the same practices, in addition to adopting the culture of privacy and data protection internally.

We use cloud services to store personal data that offer the best security standards in the market, including: Amazon AWS and Microsoft.

The processed data will remain stored in Kinp Group's systems according to the duration of the initial purpose for which they were collected or for other purposes such as compliance with legal and/or regulatory obligations, always taking into account the legal bases provided by the LGPD, being holders duly informed upon request through the channel indicated below for this purpose.  

No que concerne à retenção, os dados de representantes legais de clientes apenas serão eventualmente retidos para cumprimento de obrigações legais/regulatórias ou eventual defesa da Kinp Group em processo judicial, administrativo ou arbitral.

With regard to retention, the data of legal representatives of customers will only eventually be retained for compliance with legal/regulatory obligations or eventual defense of Kinp Group in judicial, administrative or arbitration proceedings. Regarding the data of current, past or potential candidates, for historical and management purposes, your data is stored for an indefinite period on the ClockWork platform used by us. At any time, however, the respective data subject may request the revocation of their consent and deletion of their data, or even delete them directly from their access to said platform, this being an option provided.

8. Your rights as a data subject

Article 18 of the General Law for the Protection of Personal Data establishes the following rights for data subjects:

  1. Confirm with Kinp Group the existence of processing of personal data and obtain, at any time, access to such data;
  2. Request from Kinp Group the correction or update of data that is incomplete, inaccurate or out of date;
  3. Request the deletion of data from Kinp Group systems, within the minimum legal period related to data storage;
  4. Request the traceability of your data by requesting information from public and private entities with which Kinp Group has carried out the shared use of data; 
  5. Request data portability from another service provider;
  6. Request the blocking or deletion of personal data, in case there is unnecessary, excessive collection, or inadequate treatment;
  7. Revoke the consent, after granting it, as well as request the deletion of the data obtained under its protection.

Our goal is to respond to requests made by you as soon as possible, within 15 days. The above rights may be exercised in the manner established by the LGPD, exclusively by the data subject or by his legal representative, through an email to be sent to the address dpo@kinpgroup.com with the following information:

  1. Copy of your identity card;
  2. What is the condition of legal representative and respective proof, if necessary;
  3. Request description.

* For your security, we may need to request additional information from you to help us confirm the requester's identity.

* If applicable, the request will be denied, and the applicant will be informed of the justification (ex. in a request for data deletion, the request will be denied in compliance with the statute of limitations for any legal action or other legal obligation to which we are subject).

9. How Kinp Group protects your information

Kinp Group is committed to protecting your privacy and your Personal Data from unauthorized access, destruction, loss, alteration, communication, disclosure or any form of illegal treatment or in violation of the Law.

We are committed to adopting technical and organizational measures capable of protecting personal data from unauthorized access and situations of destruction, loss, alteration, communication or dissemination of such data.

Kinp Group, however, disclaims responsibility for the exclusive fault of third parties, as in the case of attacks by hackers or crackers that corrupt the security systems to access user data, as well as for the exclusive fault of the user himself, as in the case where that he himself transfers his data to a third party. 

A Kinp Group is also committed to informing the user within an adequate period of time in the event of any type of violation of the security of their personal data that may cause a high risk to their individual rights and freedoms. “Personal data breach” means a breach of security that causes, accidentally or unlawfully, the destruction, loss, alteration, disclosure or unauthorized access to personal data transmitted, stored or subject to any other type of treatment.

Finally, Kinp Group undertakes to treat the user's personal data with complete confidentiality, in compliance with legal provisions. We clarify that, internally, the Personal Data collected is accessed only by duly authorized professionals, respecting the principles of proportionality, necessity and relevance to the objectives of our business.

10. Access and correction of information

If you wish to access and/or update the data provided to Kinp Group, please do not hesitate to contact our team via email: dpo@kinpgroup.com. Also, if you are a current, past or potential candidate, you can directly access and correct the data that is available on the Clockwork platform.

However, we reserve the right to withhold essential information to protect our interests, always supported by the legal bases determined by the LGPD. 

11. Modifications to this Policy

Kinp Group reserves the right to change this privacy policy at any time without prior notice. When we make material changes to this Policy, we may provide appropriate notice under the circumstances by displaying a visible notice on our Platforms or sending you an email if you are registered. As such, it is essential that you ensure that you read any communication carefully, as well as regularly accessing this document.

12. Complementary Policy

By accepting this Policy, you are also subject to our Cookie Policy. Cookie Policy.

13. How to contact Kinp Group about this Privacy Policy

If you have any questions, comments, suggestions or requests regarding this Privacy Policy or the use and disclosure of personal information, please contact us at dpo@kinpgroup.com, so that we can respond to you in a timely manner.