Rules of Security and Privacy

Qulture.Rocks

This addendum is part of the Global Privacy Policy - UOL Group. If the USER accesses Qulture.Rocks’ website ("Site") and/or uses the cloud services platform made available by Qulture.Rocks for performance management and other related activities ("Platform"), the following provisions apply.

Other definitions used throughout this document, such as "Digital Services," "User," and "Customer," shall have the same meanings ascribed to them in Qulture.Rocks’ Terms of Use.

I. What Personal Data do we process, for what purpose and on which legal basis?

The categories of Personal Data we collect and process vary depending on the relationship and interaction we have with you, the data you choose to share with us or that you determine should be collected and processed by Qulture.Rocks, among other circumstances.

Other personal and professional information may be collected in addition to the data collected as provided in the Global Privacy Policy - UOL Group. The following forms of data processing use additional data, which will be listed below:

Purpose	Personal Data
Making the Platform and Digital Services available to the Client and its Users If you are a User accessing and using Qulture.Rocks' Platform and Digital Services, then the company for which you work is a Client of Qulture.Rocks. In such cases, the Client acts as the Controller and Qulture.Rocks as the Processor of this data. This means that it is the Client who makes the relevant decisions about the purposes and means of processing the Personal Data, and Qulture.Rocks acts on the Client's instructions to make the performance management solutions for the Platform and Digital Services available to the Client and its Users.	For registering and enabling accounts on the Platform: Name; CPF; Email address. Other personal and professional information that can be filled in by the Client or directly by the User (according to settings established by the Client): Nickname; Area; Position; Date of last job movement; Date of admission; Date of termination; Date of birth; Department; Salary Range; Training; Photo; Identifier; Location; Reason for termination; Job Level; Country of residence; ID; Sex; Genre. The Platform also allows Clients to create custom fields. Therefore, other Personal Data may be collected and processed, as defined by the Client, as Controller.
Advertise and Process job openings. You can apply for job openings at Qulture.Rocks and the registration and monitoring of the recruitment process will occur through the Applicant Portal in the Gupy Software.	Information about whether the applicant is a person with a disability; Data on whether the candidate belongs to any underrepresented groups in society..
Enabling your participation in Teachable, HR Rocks or another of our initiatives. When you register or enroll in any Teachable activity, course or training, HR Rocks event, or other of our initiatives and events, we process your Personal Data to enable your participation.	Company you work for; Position; Area of activity of the company; Approximate number of employees of the company.
Sending you promotional information. When you browse and/or download material made available on our Site, when you participate in activities we promote, or when you contact us, we collect and use certain Personal Data about you to send you offers, promotional material and further information about Qulture.Rocks’ services. In addition, we use third party advertising platforms (e.g. Google Ads, Facebook Ads, Linkedin Ads) to identify your potential interest in activities, products and services such as those offered by Qulture.Rocks, and we also use the data that these platforms share with us to promote our services and send our newsletter.	Corporate e-mail; Corporate Phone; Area of activity of the company; Approximate number of employees. Linkedin; Audio and video recording for internal quality control, which will occur only in specific cases, guaranteeing the holder the right to delete this data upon request.
Promote customer service excellence and strengthen the Qulture brand. During your relationship with Qulture.Rocks customer service, we may request data with the intention of improving the customer service experience or promoting the Qulture.Rocks brand, for example, inviting you to trainings and benchmarkings, sending promotional and/or institutional content, maintaining a communication channel, and sending promotional gifts.	When we send a promotional gift or to improve the product's user experience: Addresses of the company or platform administrator; Phone number of the company or platform administrator; Position; T-shirt size; Shoe size; Existence of some restriction;
Conduct research and receive feedback to improve the Platform and Digital Services. When you send us feedback about Qulture.Rocks, whether by email, chat or other channel, we will treat the data provided by you to improve our services. We may also conduct surveys of business contacts (leads) or users of our products or services to improve our products, services and activities.	All data used is already listed in the Global Privacy Policy - UOL Group

To find out what is the legal basis for the Processing of your data on the Platform and Digital Services, please consult the person in charge of Qulture.Rocks at the Client (your company) who registered you as a User of the Platform.

The Platform and Digital Services collect and process certain data related to your professional performance and development, assessment by your managers and colleagues, among other profile and classification information about you. Such data is collected and/or generated from your interaction with the Client and other Users on the Platform and Digital Services. This information is used by you and the Client to manage your performance and professional development. Qulture.Rocks does not profile or classify Users - such profiling or classification is performed by the Client and the Users themselves, when interacting with each other through the Platform and Digital Services.

II. Do we handle sensitive Personal Data?

By default, we do not handle sensitive data on the Platform and do not advise Clients to handle it through the Platform. In case the Client collects sensitive data in customizable fields of the Platform, it shall ensure that all provisions on the treatment of sensitive data in the LGPD are being complied with.

In our selection process, job applicants may indicate whether they have a disability of any kind, as well as whether they belong to a group that is underrepresented in society. This data may include sensitive data relating to the health or sex life of the candidates. Therefore, we will process such data when the data subject consents or in the cases provided for in Article 11 of the LGPD. This data will be used only for the purpose of participation in the selection process and compliance with affirmative actions.

III. With whom do we share your Personal Data?

In addition to the provisions of clauses 2.6., 3.2. and 3.2.1. of the Privacy Policy, Qulture.Rocks uses some additional third party services and platforms to perform its activities

To learn more and access the complete list of third parties with whom your data is shared click here.

IV. How do we use cookies?

In addition to the provisions of clauses 2.4 and 2.5 of the Privacy Policy, more information can be obtained by clicking here.

V. Rights of the Holders

By making the Platform and Digital Services available to the Client and its Users, and by ensuring their security, Qulture.Rocks is merely acting as the processor, on behalf of the Client. For this reason, to exercise such rights to access and use the Platform and Digital Services as a User, you must make the request directly to the Client (i.e. to the company that granted you User access to the Platform and Digital Services). If you send the request directly to Qulture.Rocks, we will forward it to the Client so that the appropriate steps may be taken.

For all other purposes for which Qulture.Rocks acts as a controller (i.e., to communicate with you, to enable your participation in HR Rocks and Teachable, to register for job openings, to send you promotional information, or to receive feedback to improve the Platform and Digital Services), you may contact us by the means defined in the Global Privacy Policy - UOL Group.

VI. How do we handle cases of suspected Personal Data breaches?

We have a security incident policy that provides an action plan for cases of Personal Data breach.

Security incidents

To report security incidents, please send an email to security@qulture.rocks describing as many details of the situation as possible. We will make every effort to respond as quickly as possible.