Privacy Notice for Job Applicants

Last Update: September 2024 Previous version

THIS JOB APPLICANT PRIVACY NOTICE ("NOTICE" OR "PRIVACY NOTICE") IS APPLICABLE TO THE COMPANIES WITHIN DLOCAL AND IS INTENDED FOR INDIVIDUALS APPLYING FOR A POSITION AT DLOCAL. FOR THE PURPOSES OF THIS PRIVACY NOTICE, THE COMPANIES WITHIN DLOCAL ARE COLLECTIVELY REFERRED TO AS THE DLOCAL GROUP ("DLOCAL").

dLocal is committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you during the recruitment process, in accordance with the EU General Data Protection Regulation and the UK GDPR as applicable (collectively referred to as the “GDPR”). dLocal equally has regard for local data protection laws and will adhere to such laws where applicable.

1. INTRODUCTION

The dLocal company that sponsors the job position (“we”, “us”, “our”) is a Controller. You are dLocal’s Job Applicant (“you”, “your”). This means that we determine how we hold and use personal information about you.

This Notice applies to current and former Job Applicants. This Notice does not form part of any contract of employment or other contract to provide services.

2. INFORMATION WE MAY COLLECT (OR RECEIVE) ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of personal data or sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation.

We may collect, store, and use the following categories of personal information about you:

Contact details (such as full name, addresses, telephone numbers, and email addresses);
Demographic information (such as date of birth, gender);
Professional or employment-related information, which may include:
1. Professional and education information (such as education background, job title, skills, work experience and/or curriculum vitae (“CV”), photograph, references, employee records and appraisals);
2. Psychometric and ability test results, where it applies;
3. Interview records;
4. Current salary and salary expectations;
5. Any personal information you may have added deliberately on your CV, resume, cover letter;
6. Background screening information and results;
7. Work permit status (such as residency, and related information).
Data from public profiles;
Other information necessary for making a recruitment decision or otherwise voluntarily provided by you; and
Online activity information such as devices and browsers across our website and usage data associated with those devices and browsers; including IP address, browser types, language used and pages visited. Please see our Cookie Policy for more information.

We may also collect, store, and use the following “special categories” of personal information such as information about criminal convictions and offences but only in the context of fraud or security checks when this is necessary to comply with applicable laws or with any applicable financial services standards or requirements.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

3. HOW YOUR PERSONAL INFORMATION IS COLLECTED

We collect personal information about Job Applicants through the application and recruitment process, either directly from candidates, employment-oriented online services, sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties such as former employers.

4. HOW WE WILL USE INFORMATION ABOUT YOU

We will process your personal information only when we have one or more lawful basis which allow us to. In accordance with this Privacy Notice, dLocal may use your personal information in order to:

make a decision about your recruitment or appointment (Lawful Basis: necessary for our legitimate interests);
manage your application process (Lawful Basis: your consent, to comply with our legal obligations and necessary for our legitimate interests);
verify the accuracy of the information that you have provided us (for example by performing reference checks) (Lawful Basis: to comply with our legal obligations and necessary for our legitimate interests);
perform background check where necessary and applicable given the job position (Lawful Basis: to comply with our legal obligations and necessary for our legitimate interests);
maintain records for future job openings that might match your profile (Lawful Basis: your consent and necessary for our legitimate interests);
deal with legal claims and/or defending potential legal claims (Lawful Basis: necessary for our legitimate interests);
as required or authorised by applicable law (Lawful Basis: to comply with our legal obligations).

How We Use Particularly Sensitive Personal Information

“Special categories” of personal information or sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

If You Fail to Provide Personal Information

If you fail to provide certain information when requested, we may not be able process your application and to enter into an employment agreement with you, or we may be prevented from complying with our legal obligations.

Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. AUTOMATED DECISION-MAKING

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

Where we have notified you of the decision and given you 21 days to request a reconsideration;
Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights;
In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights;
It is not prohibited under local data protection laws.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

6. DATA SHARING

Why Might We Share Your Personal Information with Third Parties?

We may have to share your personal information with third parties, including third-party service providers and other entities at dLocal. We will share your personal information with third parties where required by law, where it is necessary to administer our recruitment relationship with you, or where we have another legitimate interest in doing so. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

Which Third-Party Service Providers Process Your Personal Information?

“Third parties” includes third-party service providers (for example recruiting and HR tools) and other entities within our group.

How Secure Is Your Information with Third-Party Service Providers and Other Entities?

All our third-party service providers and other entities at dLocal are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When Might We Share Your Personal Information with Other Entities in the Dlocal Group?

We may share your personal information with other entities in our group for system maintenance support and hosting of data.

What About Other Third Parties?

We may also need to share Personal Data with government authorities (for example, regulatory authorities, enforcement authorities, and other governmental agencies).

Transferring Information Abroad

We may transfer abroad the personal information we collect about you to process your application. There are appropriate safeguards to maintain an adequate level of protection for your personal information by any and all foreign parties which may receive them from dLocal.

Regarding the international transfer of Personal Data, we will implement GDPR standards on data transfers. Where applicable, we will follow local regulations.

7. DATA SECURITY

We have put in place a range of security measures to protect the security of your information. Details of these measures are available upon request.

Please be aware that communications over the Internet, such as emails/webmails, are not secure unless they have been encrypted. Your communications with us may route through a number of countries before being delivered. This is the nature of the World Wide Web/Internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

We will use reasonable endeavours to implement appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

8. DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we might anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. If you are unsuccessful with the application process, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

9. YOUR RIGHTS

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the application process with us.

Under certain circumstances, by law, you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us;
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it;
Request the transfer of your personal information to another party.
Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to further process your application. We will advise you if this is the case.

How to Exercise Your Rights

Please click on this LINK and fill out the form to submit your request. Requests submitted through other channels may require you to provide additional information to enable us to deal with the request.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your access request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Time Limit to Respond.

We try to respond to all legitimate requests within one month starting from the date your identity is deemed to be confirmed. Occasionally it may take us longer than a month if your request is particularly complex, or you have made several requests. In this case, we will notify you and keep you updated.

10. CONTACT DETAILS

If you have any questions about this Privacy Notice or how we handle your personal information, please contact the DPO at dpo@dlocal.com You have the right to make a complaint at any time to the relevant data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please consider contacting us in the first instance.

11. CHANGES

We reserve the right to amend or edit this Privacy Notice from time to time to reflect changes in dLocal’s business or practices, and we encourage you to review this Privacy Notice periodically. We may change the Privacy Notice at any time by posting the changed Privacy Notice on the dLocal website or the point of collection of your personal information.