Privacy Policy

From this point onward, you will find everything you need to know about how we will process your personal data and the information you entrust to us. By browsing our platform, using one of our modules mentioned in the User Terms, or using our services, even free of charge and occasionally, we understand that you tacitly accept the way we process and collect your information and personal data.

It is essential that you read and analyze this Policy and only continue interacting on our platform if you fully agree with it. If you disagree, simply contact us: we want to understand why so that we can continuously improve our services and your experience.

To reinforce our commitment to your privacy, we restrict collection to what is truly essential, always in accordance with the latest legislation, to preserve your digital identity and make your experience more useful and enjoyable. Our policy was shaped by the LGPD, so that no aspect is left out.

Throughout this Privacy Policy, the terms “Personal Data”, “Processing”, “Controller” and “Data Protection Officer” have the definitions assigned by the General Data Protection Law (LGPD) – Law No. 13.709/2018. Other definitions have been developed to meet INCICLE’s needs:

• CONTROLLER: INCICLE itself.
• CO-CONTROLLER: a company/institution that subscribes to the services made available by INCICLE.
• ADMINISTRATOR USER: a person designated by the CO-CONTROLLER to operate platform features on its behalf (under the LGPD, “Processor”).
• USER: a natural or legal person to whom the personal data being processed relate (under the LGPD, “Data Subject”).
• THIRD PARTIES: investors, partners, service providers, among others.

If you are a user who accesses and uses the platform and the company/institution with which you are affiliated is an INCICLE customer, that company acts as CO-CONTROLLER and INCICLE as processor in processing those data. The CO-CONTROLLER makes the relevant decisions regarding the purposes and means of processing, and INCICLE acts according to its instructions.

INCICLE only licenses the PLATFORM to registered CO-CONTROLLERS and USERS; there is no other relationship between these parties, so INCICLE cannot be held liable for damage caused to other USERS or third parties. ADMINISTRATOR USERS must be natural persons of legal age and full legal capacity, who are members of the CO-CONTROLLER’s workforce. Noncompliance will result in account access being blocked.

Registration data

Name, surname, email, identification document, CPF, date of birth, gender, employer, job title, company/institution’s field of activity, approximate number of employees, contact telephone number, information on education and professional experience, among others. INCICLE collects only data essential to the activity desired by the user. If it is necessary to collect your biometric data (through a facial photograph), we will do so in accordance with the law.

Using the data collected, INCICLE helps other users find your profile and suggests connections that may be of interest. We also infer information such as: industry, experience level and salary range from job title; age from graduation date; gender from names/pronouns; interests from feed activity; and device recognition to identify you as a user.

Service usage data

Search history, feed, content read, your network of contacts (users you follow and who follow you), connections, group participation, page visits, videos watched, advertisements, among others. Also data from advertising partners, suppliers and media outlets.

The platform allows CO-CONTROLLERS and ADMINISTRATOR USERS to create custom fields for a better experience in the INCICLE world. Thus, other personal data may be collected and processed as defined by them.

Through interaction with the CO-CONTROLLER and other users, the platform identifies, collects and processes data related to professional performance and development, assessments and feedback. This information is used by you and the CO-CONTROLLER to manage your performance; INCICLE does not align or classify users; such profiling is carried out by the CO-CONTROLLER and ADMINISTRATOR USER, and by USERS themselves when interacting.

Sensitive data

To provide the best experience, INCICLE may use data considered sensitive, provided that you consent, and such consent may be withdrawn at any time, such as: racial or ethnic origin, disabilities, photograph, religious belief, political and philosophical identity and opinion, trade union membership, health or sexual orientation data, genetic data, etc.

Usage data

When you browse our platform, we will collect: content accessed or created, pages accessed or searched for, counts of views and intentional or accidental clicks, and other necessary actions.

Location data

Collected automatically through your connected equipment or device, such as your mobile phone’s GPS. We may use them for functions such as notifying connections that you are at a professional event, calculating travel time to a new job, or suggesting nearby users with whom you can connect.

Access logs and equipment characteristics

When you communicate with INCICLE, we automatically collect metadata such as application access logs, IP address, operating system and version, date and time, token and language preference. Although collection is mandatory under Law No. 12.965/2014, these logs will only be provided to third parties pursuant to a judicial demand or with your express authorization.

Cookies

Used to collect and send data about your browsing, for targeted marketing and the creation of behavioral profiles. See the Cookie Policy for more information and to block or control your settings.

All data are treated as confidential and used for the purposes described in this Policy and authorized by you. Data provided for participation in events may be shared with sponsors, subject to consent.

Specific legal demands may lead to data sharing, including to defend INCICLE’s rights or comply with competent authorities and requirements of applicable legislation.

Service providers will use INCICLE for: marketing activities, brand analyses and advertising exclusively for INCICLE; security mechanisms to protect infrastructure; and data storage on cloud servers.

In exceptional situations, we may use data for purposes not provided for in this Policy, provided they are compatible with those established herein and within the user’s legitimate expectations. Uses outside this prerogative will require prior authorization.

When accessing links to partners’ products with their own terms and policies, carefully read their policy before proceeding; this Instrument applies only to our website and services. If you provide third-party information, you must ensure that you have the right to disclose it, including the necessary consent; responsibility rests entirely with the USER who provided such information.

Your data may be visible to other team members with whom you share questionnaires or collaborate, making your experience more complete. When necessary, administrators may view your account data and restrict settings.

In recruitment or admission processes, your data will be shared with those who need to receive them to enable your participation. The ADMINISTRATOR USER and CO-CONTROLLER will receive your data to operate the module with which you are interacting, including the company for which the recruitment process is being conducted, which may communicate directly with you and invite you to other opportunities. By this Instrument, you expressly authorize such sharing.

The CO-CONTROLLER and ADMINISTRATOR USER may not share your data with third parties; if they violate this rule, they may be held civilly and criminally liable for any damage caused to candidates.

Personal data such as name, email, IP address and geographic location will only be shared with partners, service providers and social networks with your permission. Otherwise, they will be preserved and not disclosed. To facilitate service provision, INCICLE may provide partners with information about the reach and effectiveness of activities and tools used, without providing data that could identify users.

Users’ anonymity is strictly guaranteed when reports containing market comparisons are disclosed, with the consent of the CO-CONTROLLER and ADMINISTRATOR USER. Data generated in the tool (such as individual performance reports) belong exclusively to the CO-CONTROLLER, which is responsible for managing and processing confidential information.

The employee user agrees to and authorizes the disclosure of their data on the INCICLE platform, aware that certain performance information may be shared with their direct manager and the management team, provided that such data do not compromise security. They also authorize disclosure of rankings on the platform, which aims to promote healthy competition, is not a negative database and may not be used for discriminatory purposes. Irregular practices may be subject to the prescribed sanctions.

In the event of a structural change at INCICLE, data may be transferred to the new owner to ensure continuity of service.

We store the personal data collected only for as long as necessary to achieve the purposes for which they were collected. After this period, your data will be deleted from our database or anonymized (adapted so that they do not identify you), unless there is a legal impediment. In accordance with the User Terms, data will be stored for a minimum period of 05 (five) years.

Your privacy is extremely important to us. We consider all categories of personal data and processing measures in order to adopt appropriate organizational, physical and technical security precautions to protect them.

We adopt regulations, control measures, policies, procedures and guidelines to maintain these measures in accordance with internationally recognized security standards. You are responsible for keeping your password in a secure place and not sharing it. Immediately report any unauthorized use of or access to your account through a secure method.

Under the General Personal Data Protection Law – LGPD (Law No. 13.709/2018), personal data subjects may exercise, where applicable, the rights provided for in the legislation, including:

• confirmation of the existence of processing of their personal data;
• access to the personal data processed;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or deletion of data considered unnecessary, excessive or processed in breach of the legislation;
• data portability, where applicable and subject to the rules of the National Data Protection Authority – ANPD;
• deletion of personal data processed on the basis of consent, subject to the statutory grounds for retention;
• information about the public and private entities with which INCICLE has shared data;
• information about the possibility of not providing consent and the consequences of such refusal, when consent is the applicable legal basis;
• withdrawal of consent, when processing is based on that legal basis;
• objection to processing carried out in breach of the LGPD;
• review of decisions made solely on the basis of automated processing of personal data, where applicable.

The exercise of certain rights may be subject to the limitations and exceptions provided for in the legislation, including cases where INCICLE needs to retain certain information to comply with a legal or regulatory obligation, for the regular exercise of rights or for other legally authorized purposes.

Requests relating to data subject rights may be sent to INCICLE’s Personal Data Protection Officer by email at dpo@incicle.com.

INCICLE may request additional information to confirm the requester’s identity and ensure that personal data are provided or changed only upon request by the respective data subject or their legal representative.

INCICLE may use cookies and similar technologies on its websites and digital services to enable pages to function properly, improve the browsing experience, understand the use of services, maintain user preferences, increase security and, where applicable, support analysis and communication activities.

Cookies are small files or pieces of information stored on the user’s device during browsing and may have different purposes and durations.

Depending on the features available on the website, cookies used by INCICLE may be classified, for example, into the following categories:

• Strictly necessary cookies: used to enable the operation, security and essential features of the website and services. These cookies are necessary to provide the features requested by the user.
• Functionality cookies: used to remember certain user choices and preferences, providing a more personalized experience.
• Performance and analytics cookies: used to understand, in aggregate, how visitors use the website, which pages are accessed and how services can be improved.
• Advertising or marketing cookies: when used, they may help measure campaigns and present more relevant communications, according to applicable preferences and legal bases.

Whenever required by law, cookies that are not strictly necessary will only be used after the user has appropriately expressed their choice.

Users may manage their preferences through the cookie management mechanism made available on the website, where applicable, as well as through their own browser settings. Disabling certain cookies may affect the functioning or availability of some website features.

INCICLE may use services provided by third parties that employ cookies or similar technologies. In such cases, data processing may also be subject to the respective providers’ privacy and cookie policies.

Information obtained through cookies will be processed in accordance with this Privacy Policy, applicable legislation and the purposes presented to the user.

This Policy may be changed at any time. Users, depending on the significance assigned by INCICLE, will be notified through our services or by other means to assess the changes before they take effect. Changes that are not significant may occur without prior notice. Changes will not be retroactive; if you object, you may close your account. Continued use after publication or notification will imply agreement to the updated terms as of the effective date.

We value transparency and a commitment to protecting our users’ digital identity. When connecting to the platform, you provide basic registration data; during the INCICLE experience, automatically and voluntarily, you provide us with additional data such as location and device characteristics.

Our collection also includes information from other sources, cookies (see the Cookie Policy to block or control them). If contacts or calendars are synchronized with INCICLE services, we will access your address list and meetings to expand your network.

Users and third parties may publish content that includes information about you (articles, posts, comments and videos). INCICLE may collect public information about you (news and professional achievements) and make it available as part of the services, if authorized in your settings.

We receive personal data when other users: import or synchronize contacts or calendars; associate contacts with profiles; scan and upload business cards; send messages, invitations or connection requests; enable email account synchronization. We may also collect “email header” information associated with profiles.

When you use services of CO-CONTROLLERS and partners (current/potential employers and applicant tracking systems), we will also collect your personal data such as job title and work email.

INCICLE offers Premium Solutions with customized messaging and alert mechanisms. Unless disabled, subscribers may export information from your profile (name, job title, company and location) to manage leads. Premium Solutions customers may store information about you (résumé, contact details or sales history), subject to those customers’ policies.

When a company purchases our services, it provides us with employees’ personal data and eligibility information. We will obtain, for example, contact information for administrators of the “INCICLE Page” and authorized users of recruitment, sales or learning products.

Among the features of the INCICLE Platform, upon your registration we will automatically:

• Allow access to, use and exploration of all website and service features, connecting you to products and services simply and reliably.
• Create new services, products and features and analyze fit and the formalization of partnerships to improve our services or strengthen their security.
• Send notices about our services, such as support, alerts, notifications and updates, with transparency and control over your data.
• Improve and assist with security controls for the website and products and monitor compliance with this Policy and the Information Security Policy.
• Analyze user traffic to improve commercial and promotional initiatives and provide personalized experiences through commercial proposals, advertising and marketing.
• Generate statistical analyses of service use and the behavior of business segments to better understand needs and interests.
• Allow legal due diligence to enable investment rounds, mergers, acquisitions or asset sales, within information security standards.
• Comply with legal obligations and respond to requests from competent authorities.

Depending on your privacy settings, your profile will be fully visible to all users. It may also be displayed to other users, and it will be possible to configure the degree of connection with those who view the profile, any subscriptions held, the use of services, access channels and search types (name or keyword); this influences the availability and visibility of certain fields.

INCICLE services allow information and activities to be viewed and shared through posting, following, liking and commenting, among others. Examples:

• When you publish an article, other users may view it and share it on their profiles, including your name and photograph (if provided).
• Information published on company or organization pages may be viewed by all visitors.
• When you join a user’s network of contacts (a person, company or organization), you become visible to third parties and the page owner as a follower.
• When you interact (like, share, comment), other users will see your name, profile and profile photograph, if provided.

The CO-CONTROLLER may view how you use the services provided for your work (for example, as a recruiter or sales agent) and information related to your job title. Activities such as job searches and personal messages are confidential and are not shared with the CO-CONTROLLER unless you choose to share them.

The CO-CONTROLLER may offer access to our modules, and the ADMINISTRATOR USER may assess and manage the use of services. Depending on the modules, we will request permission to share relevant profile data or your use of non-corporate services with the CO-CONTROLLER. Your job searches will not be shown to the CO-CONTROLLER unless that is your wish.

Your profile may be linked to services of other companies (Twitter, Facebook, Instagram, LinkedIn, etc.). This link allows access to your profile and those of your contacts, posts, shares and conversations across multiple platforms. It may also appear, in abbreviated form, in search tools, email and calendar applications, social media aggregators and talent and lead managers.

Services of other platforms may access your profile when it is linked, making your personal data available to them. The sharing is displayed on a consent screen at the time of linking. Remember: services of other companies have their own privacy policies and may use your data differently from ours.

You may revoke the link at any time. To make services more relevant, we share data with partners, for example, personalizing feeds or job recommendations based on learning history. We may also combine information internally between services covered by this Policy. Profile information may remain outdated on those services until the cache is updated.

To provide excellent services, we engage third parties specializing in payments, maintenance, auditing, analysis, fraud detection, marketing, development, etc. They will have access only to the necessary information and are prohibited from disclosing it or using it for other purposes.

Data generated in the tool (such as individual performance reports) belong exclusively to the USER and the CO-CONTROLLER, who are responsible for managing and processing confidential information. The employee agrees to and authorizes disclosure of their data on the platform, aware that some performance information may be shared with their direct manager and the management team, usually Human Resources.

One of INCICLE’s services is the administration of online tests, used to map your profile, potential and general knowledge. The test may be retaken every 06 (six) months and will be used for all recruitment processes in which you participate. The period may vary according to the recruitment process.

In addition to self-assessment, the result assists CO-CONTROLLERS and ADMINISTRATOR USERS in selecting candidates and is available only to the person who took the test and the company/institution conducting the process. Comments or recommendations made by CO-CONTROLLERS and ADMINISTRATOR USERS are accessible exclusively to them.

Registration with INCICLE is unique: the profile will be used in all recruitment processes for which you apply. When you register as a result of a recruitment process, you will already have access to all INCICLE Platform features.

If one of the CO-CONTROLLERS is located in another country, data and information may be transferred internationally with all necessary protection, through secure protocols. Your data may also be transferred to Amazon Web Services (AWS), where they will remain stored in encrypted form. For greater security, we will check beforehand whether the recipient country reflects the adequate level of data protection required by law.

We will back up your data regularly and frequently in one or more geographically dispersed locations. These backups generally ensure that no more than 12 (twelve) hours of data are lost, even in the event of a disaster. We regularly test backups and disaster recovery procedures to ensure that systems and data can be restored in a timely manner.

The partial invalidity of this Policy will not affect the part considered valid; the obligations are severable from one another. If any provision is considered unenforceable by a court of competent jurisdiction, it will be considered individually and the others will remain in full force and effect.

We may refuse to host calendars, public activities, event content, posts and articles, and may terminate users who participate in activities that violate our policies, including:

• Publication of illegal content, such as defamation, or activities that promote illegal behavior.
• Use of any tool to gain unauthorized access to other users’ data.
• Copyright infringements.
• Use of any space to send spam or transmit malicious code or viruses.
• Incitement to hatred, violence or discrimination.

The content of public posts must be accurate and generally appropriate for all ages.

INCICLE provides an optional integration with Google Calendar that allows the USER to connect their Google account and view, within the INCICLE Calendar, the events in their primary calendar.

To use the integration, the USER must authorize the access requested by Google. INCICLE will request permission to view events in the primary calendar, through the scope (calendar.events.readonly), as well as the email address associated with the connected Google account. INCICLE does not request permission to create, change, edit or delete events in Google Calendar.

Events are queried directly from Google when the USER accesses INCICLE’s integrated Calendar, exclusively to enable their display within the platform. Depending on the information made available by Google, the title, date, time, location, description, guests, meeting link, recurrence and reminder may be displayed.

To maintain the authorized connection, INCICLE stores only the access tokens issued by Google and the email address of the connected account. INCICLE does not store event content, does not use this information for advertising or to train artificial intelligence models, does not sell it and does not share it with third parties.

No person at INCICLE reads event content, except with the USER’s express authorization, for example, during support assistance, for security reasons or to comply with a legal obligation.

The USER may revoke the integration at any time through the system itself by accessing Calendar + Integrate calendar + Manage integrations and deleting the connected account. At that point, INCICLE permanently deletes the stored tokens and asks Google to revoke the access granted. Authorization may also be revoked directly in the Google account settings, through:

https://myaccount.google.com/permissions

INCICLE’s use and transfer to any other application of information received through Google APIs will comply with the Google API Services User Data Policy, including the Limited Use requirements.

InCicle's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Use of the integration is subject to these INCICLE Terms of Use and Google’s applicable policies. If there are any questions relating to the integration or the processing of information obtained through Google APIs, the USER may contact dpo@incicle.com by email.

Rafael Giupponi Ribeiro is our Personal Data Protection Officer. For questions, data subject requests or the exercise of rights provided for in the LGPD, contact us at the email address below.

dpo@incicle.com