Privacy Policies - GeekHunter

PRIVACY POLICY

1. Purpose

GeekHunter LLC (“GeekHunter”, “we”, “us”, or “our”) values the privacy of its users and is committed to protecting personal data in accordance with applicable data protection and privacy laws. Depending on the context and the location of the data subject and/or our customers, such laws may include, where applicable: (i) Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados Pessoais – “LGPD”, Law No. 13.709/2018), (ii) the EU General Data Protection Regulation (“GDPR”, Regulation (EU) 2016/679) and, where relevant, the UK GDPR, and (iii) the California Consumer Privacy Act as amended by the CPRA (“CCPA/CPRA”) and other applicable U.S. federal and state privacy laws.

This Privacy Policy (“Policy”) explains how GeekHunter collects, uses, shares, transfers, retains, and protects personal data in connection with our websites, applications, and recruitment-related services (collectively, the “Services” or the “Platform”).

1.2. Scope of Application

This Policy applies to all individuals whose personal data we process, including:

Professionals/Candidates: individuals who use GeekHunter to seek job opportunities or participate in recruitment processes (for client companies or internal GeekHunter positions).
Company Users: recruiters, employees, and/or administrators of client or partner companies who use the Platform to attract professionals and/or conduct recruitment processes.
Integrated Third Parties: providers of technical tests, video conferencing tools, job partners, external recruiters, and other partners connected to the Platform.
Visitors: individuals who browse our websites or pages without registering.

GeekHunter processes personal data of Professionals primarily located in Brazil, while providing Services to client companies located in Brazil, the United States, and the European Economic Area (“EEA”) (and, where applicable, the United Kingdom). The applicable data protection framework may depend on (a) the location of the data subject, (b) the location of the client company, and (c) the nature and purpose of the processing activity.

1.3. Conditions of Use and Relationship with the Terms

By using our services, you declare that you are over 18 years old, as well as emancipated or duly represented/assisted if legally incapable.

If you do not agree with this Policy, we recommend not using our services. This Policy complements the Terms of Use. In case of conflict, the applicable legislation shall prevail.

2. DEFINITIONS

For purposes of this Policy:

“User” means any individual who uses or visits GeekHunter’s websites and/or applications.
“Professional” or “Candidate” means a User who uses GeekHunter to search for opportunities or apply for job positions offered by client companies or by GeekHunter.
“Company User” means a User who uses GeekHunter to attract, manage recruitment processes, and hire professionals.
“Personal Data” means any information that identifies or can reasonably identify an individual (e.g., name, email, phone number, identifiers, resume data).
“Sensitive Personal Data” means data that receives heightened protection under applicable law (e.g., racial or ethnic origin, religious beliefs, political opinions, trade union membership, health, sexual life, genetic or biometric data, and—where applicable—precise geolocation).
“Controller” means the entity that determines the purposes and means of processing personal data.
Processor” means an entity that processes personal data on behalf of a Controller.
“Joint Controllers” means two or more Controllers who jointly determine the purposes and means of processing.
“Talent Database” means the database composed of Professional profiles registered or enriched through the Platform, accessible by GeekHunter and, in certain situations, by client companies, according to the purposes described in this Policy and the applicable terms.
“Legal Basis” means a lawful ground that permits processing personal data under applicable law.
“Consent” means freely given, specific, informed, and unambiguous indication of the data subject’s wishes, where required by applicable law.
“AI (Artificial Intelligence)” refers to automated resources applied by GeekHunter to support interviews, enrich profiles, generate recommendations, perform matching, detect fraud, and optimize Services.

References to “Controller”, “Processor”, “Joint Controllers”, “Personal Data”, and “Sensitive Personal Data” shall be interpreted in accordance with applicable law (including the LGPD and GDPR, where applicable).

3. ROLES IN DATA PROCESSING

Depending on the context, GeekHunter may act as a Controller, Joint Controller, or Processor under applicable law.

Data processed by GeekHunter and intelligence generated by the system (such as metrics, market analyses, matching outputs, reports, and aggregated insights) are owned by GeekHunter and may be shared with clients to support recruitment and selection decisions, subject to this Policy and applicable law.

Data processed outside the Platform (exports, integrations with other systems, or use in external tools) are the sole responsibility of the client company, which may adopt its own privacy policies and processing purposes and must respect the rights of data subjects under applicable law.

Candidates may exercise their rights with GeekHunter and, where applicable, with the client company that received their data (for example, when the client company acts as a Controller for its own talent pool).

3.1. WHEN GEEKHUNTER ACTS AS A CONTROLLER

GeekHunter generally acts as a Controller when it defines the purposes and means of processing, such as:

Creating and managing a profile/account on the Platform;
Maintaining the Talent Database;
Providing customer service and support;
Measuring usage, performance, and security metrics;
Institutional communications and product updates;
Marketing activities, when applicable and subject to applicable law (including opt-in/opt-out requirements).

GeekHunter acts as a Controller for personal data of Professionals contained in the Talent Database, which are processed to create, maintain, and improve Professional profiles and may be shared with client companies for legitimate recruitment and selection purposes, in accordance with this Policy.

3.2. WHEN GEEKHUNTER ACTS AS A JOINT CONTROLLER

GeekHunter may act as a Joint Controller with a client company when we jointly determine the purposes and means of processing, such as when Candidates apply for a specific recruitment process through a dedicated job page on the Platform.

In cases of joint control, each party is responsible for the processing it performs, according to its own decisions and legal obligations under applicable law.

3.3. WHEN GEEKHUNTER ACTS AS A PROCESSOR

When a client company manually or via integration (e.g., API) uploads Professional data to the Platform for the client’s own recruitment purposes, the client company typically acts as the Controller for that data and GeekHunter acts as a Processor, processing the data on the client’s documented instructions and subject to a data processing agreement or equivalent contractual terms, as required by applicable law

4. COLLECTION AND USE OF PERSONAL INFORMATION

4.1. INFORMATION COLLECTED FROM COMPANY USERS

Company Users provide personal data through forms and workflows operated by GeekHunter for registration and Platform usage. Examples include:

MOMENT	CATEGORY OF PERSONAL DATA	PURPOSE
Contact information	Name, corporate email, phone number	To register and manage Company User account
Account and access information	Login credentials (where applicable), role, permissions	To operate the Platform and provide support; To connect recruiters with Candidates participating in selection processes;
Technical data	IP address, device identifiers, cookies, and log data.	To maintain security, prevent fraud, and monitor system performance; To comply with legal obligations and enforce our agreements.

LEGAL BASES:

We rely on one or more legal bases depending on the context, which may include performance of a contract, legitimate interests, compliance with legal obligations, and/or consent where required by applicable law.

4.2. INFORMATION COLLECTED FROM PROFESSIONALS/CANDIDATES

The Professional acknowledges that they provide their information consciously and voluntarily through forms or websites/applications operated by GeekHunter.

In some cases, clients may request specific recruitment services from GeekHunter aimed at promoting diversity within their companies. To make these services possible, it may be necessary to collect sensitive personal data related to specific demographic categories. We emphasize that GeekHunter does not support discriminatory practices and that this type of data processing occurs exclusively on behalf of the Client, with the purpose of fostering more diverse and inclusive environments.

In diversity-related initiatives requested by clients, GeekHunter may collect sensitive personal data (e.g., disability status) only with your specific, highlighted, and optional consent, for the purpose of promoting affirmative actions. Refusal to provide such consent will not affect the use of the platform, and the professional may withdraw consent at any time.

If a candidate chooses to directly send GeekHunter sensitive information, such submission may be interpreted as acknowledgment and agreement regarding the processing of such data, in accordance with this Privacy Policy.

When the Professional registers and/or fills out forms made available by GeekHunter, the requested personal data will be kept confidential and used exclusively for the purposes that justified their collection, as illustrated in the following table:

MOMENT	CATEGORY OF PERSONAL DATA	PURPOSE	LEAGAL BASIS
Simplified Job Application	Full Name; Email; Mobile Number; LinkedIn; Desired Salary; Resume; Desired Employment Type (CLT, Contractor, Internship).	To obtain the minimum necessary information about the candidate so that the client company can communicate and proceed with the selection process	Consent
Contact/Profile Registration	Name; Work location availability; City and state of residence; Phone number; Gender; Resume; Portfolio link; and Social Networks (LinkedIn, GitHub, Stack Overflow, Personal Website, Portfolio).	To obtain the minimum necessary information about you in order to properly tailor your resume and forward it to potential companies, ensuring the consistency of your profile on the platform.	Consent
Contact/Profile Registration	Information on whether the user is a PwD (Person with Disability).	To enable potential employers to meet job requirements related to diversity quotas, in accordance with the CLT (Consolidation of Labor Laws – Decree-Law No. 5.452/43) and Law No. 8.231/91.	Consent
Contact/Profile Registration	Profile Photo.	To improve organization in the recruitment and selection process for potential companies.	Consent
Field of Work, Experience, and Education	Last and/or Current Salary; Desired Salary; Job Title; Current and/or Previous Employer; Education Level; Certificates; Known Technologies and Skills; Programming Languages.	To build your resume and, consequently, to better direct your profile during recruitment and selection processes for potential employers.	Consent
Access Information	IP Address, Cookies, etc.	To optimize the functionality of our website and the job search results for users based on their geographic location.	Legitimate Interest
Home	Email*	To provide access to content and receive hiring tips (Newsletter), as well as to maintain a communication channel with the user and organize their information in the search for job opportunities.	Consent

When applying for a job, the professional becomes part of both the GeekHunter Talent Database and the recruiting company’s own talent database. This allows the professional’s data to be retained even after the conclusion of the selection process.

By registering through a GeekHunter subdomain, the professional may choose—at the time of registration or later—to keep their profile public across the entire talent database or restricted only to the specific job of interest. At any time, the professional may also request the deletion of their data from the GeekHunter platform.

The client company, in turn, may choose not to keep its pool of professionals—originating exclusively from its own recruitment processes—in this Talent Database. In such cases, it may request the removal of that visibility. However, this decision will also result in the loss of access to GeekHunter’s Talent Database, limiting the company’s ability to view available profiles beyond those directly registered in its own processes.

GeekHunter also automatically collects certain information through cookies and similar technologies when visitors access our website. Such data may include: internet protocol (IP) address, browser type, internet service provider, source and destination URLs, operating system, date and time of access, search terms, location and language preferences, device-associated identifiers, and system configuration details.

4.2.1. COOKIES AND SIMILAR TECHNOLOGIES

GeekHunter may automatically collect information through cookies and similar technologies when visitors access our websites. Such data may include IP address, browser type, ISP, referring/exit URLs, operating system, date/time of access, search terms, language preferences, approximate location, device identifiers, and system configuration data. You can manage cookies through your browser settings and, where applicable, through our cookie banner or preference center.

4.3. INTEGRATION WITH THIRD-PARTY SERVICES

Some procedures depend on integration with third-party services (such as LinkedIn, WhatsApp, email providers, and telecom operators). Processing by those third parties is governed by their own privacy policies and terms. GeekHunter is not responsible for third parties’ independent processing.

4.4. AI-ASSISTED INTERVIEWS AND PROFILE ENRICHMENT

4.4.1. VOICE, VIDEO, OR TEXT INTERVIEWS SUPPORTED BY AI

GeekHunter may conduct video, voice, or text interviews supported by AI agents. We may collect:

Interview content and transcriptions;
Technical metadata (date, time, duration, language, device type, IP address);
Automatically generated notes and inferences (e.g., extracted skills, estimated seniority, job match scores, key topics, quality indicators).

4.4.2. AUTOMATIC PROFILE ENRICHMENT

To keep profiles complete and up to date, we may supplement information using:

Publicly accessible sources (e.g., professional profiles and public web pages), in compliance with applicable law and platform settings; and
Connected accounts authorized by the user (we do not collect passwords; connections can be revoked at any time).

4.4.3. PURPOSES

Data collected through AI-assisted interviews and enrichment may be used to:

Update and maintain accurate Professional profiles;
Support screening, matching, and recruitment decision-making for client processes;
Provide job recommendations, communications, and support;
Generate anonymized/aggregated statistics and market insights;
Improve service models, workflows, fraud prevention, and security.

We process interview and enrichment data based on one or more lawful bases, including performance of a contract or pre-contractual steps, legitimate interests in improving Services and ensuring security, and consent where required. For sensitive personal data, we obtain explicit consent or rely on another lawful basis permitted by applicable law.

4.4.5. SHARING WITH CLIENT COMPANIES

We make available to client companies only the information necessary for the selection process. Sensitive data and internal notes that are not essential to the stated purposes remain restricted to GeekHunter, unless sharing is required by law or explicitly authorized by the Candidate, where applicable.

4.4.6. AI PROVIDERS AND RESTRICTIONS

We may use service providers acting as Processors for transcription, natural language processing, verification, and infrastructure. We require confidentiality, security, and restrictions on use for their own purposes, including prohibitions on using Candidate data for provider model training, unless express, explicit, and specific consent is obtained from the data subject where required by applicable law.

4.4.7. ACCESS AND RETENTION OF TRANSCRIPTS

Professionals may request access to interview transcripts associated with their profile by contacting our DPO at dpo@GeekHunter.com.br. We retain transcripts and related data as long as necessary to fulfill the stated purposes and legal timeframes. Upon request and where no other legal basis justifies retention, we delete or irreversibly anonymize such data. If deletion is not possible due to legal obligations, fraud prevention, security, or legal claims, we restrict processing to essential purposes and retain only the minimum necessary, informing the legal grounds when required.

5. SHARING AND PROCESSING OF USERS’ PERSONAL INFORMATION

5.1. CIRCUMSTANCES FOR SHARING

GeekHunter may disclose personal data to third parties in the following situations, as permitted by applicable law:

Client Companies: when you apply to a recruitment process on the Platform or when your profile is made visible to employers in the Talent Database according to your settings and the Platform flow;
Companies within the Howdy.com Inc. corporate group (our parent company), including in mergers, acquisitions, or sales, where there is a legitimate purpose and appropriate notices are provided;
Vendors and service providers (Processors) who assist in providing the Services (e.g., hosting, analytics, communications, support);
Job posting platforms and integrated partners used to publish openings or perform recruitment steps;
Authorities or government agencies where required by law, legal process, or to protect rights and safety;
Administrative purposes such as research, planning, service development, security, and risk management.

5.2. PROCESSORS

Currently, to ensure the proper execution of GeekHunter’s services, Users’ Personal Data are shared with the following processors:

PROCESSORS	PURPOSE	PRIVACY POLICY
SendGrid	SendGrid – Email delivery service	Privacy Policy
AWS	AWS (Amazon Web Services) – Cloud storage and infrastructure	Privacy Policy
Google Cloud	Google Cloud – Cloud storage and infrastructure	Privacy Policy
Freshworks	Freshworks – Customer support and service management	Privacy Policy
Colmeia.cx	Colmeia.cx – Automated messaging and customer service tool	Privacy Policy
Hubspot	HubSpot – CRM (Customer Relationship Management) tool	Privacy Policy
Superlógica	Superlógica – Financial billing and subscription management tool	Privacy Policy
Sentry	Sentry – Monitoring and error tracking tool	Privacy Policy
Change for Lemlist	Change for Lemlist – Prospecting and outreach tool	Privacy Policy
Metabase	Metabase – Data intelligence and analytics workflows	Privacy Policy
Nekt AI	Nekt AI – Data intelligence platform	Privacy Policy
LinkedIn Recruiter	LinkedIn Recruiter – Candidate search (TRaaS – Talent Recruitment as a Service)	Privacy Policy
Clicksign	Clicksign – Digital contract signing and management	Privacy Policy
Convenia	Convenia – HR and payroll management system	Privacy Policy
Videoask	VideoAsk – Virtual interviews and English proficiency validation	Privacy Policy
openai	OpenAI – Resume and interview analysis	Privacy Policy
Twillio	Twilio – SMS, WhatsApp, and messaging: large-scale text messaging, automations, and notifications; Voice calls: VoIP and PSTN communications.	Privacy Policy
Google Workspace	Google Workspace – Internal document storage and processing	Privacy Policy
Start Carreiras	Start Carreiras – Virtual interviews powered by AI	Privacy Policy
Hackerrank	HackerRank – Technical interviews and assessments	Privacy Policy
RD STATION	RD Station – Marketing management tool	Privacy Policy

In cases where Personal Data is shared with third parties, all entities mentioned in items I to V must use the shared Personal Data in a manner consistent with and limited to the purposes for which it was collected (or for which the User has previously given consent), in accordance with this Privacy Policy, other applicable website or country-specific privacy statements, and all relevant data protection and privacy laws.

5.3. FINANCIAL INSTITUTIONS AND INSURANCE COMPANIES (BRAZIL-SPECIFIC)

Where a client company is a financial institution or insurance company subject to Brazilian regulatory requirements, the Candidate’s data
may be consulted for compliance analyses related to illicit practices such as money laundering or terrorism financing, as required by applicable law.

6. INTERNATIONAL DATA TRANSFERS

GeekHunter operates a global platform and may transfer, store, and process personal data in countries other than the data subject’s country of residence, including the United States and other jurisdictions where our service providers operate.

Where required by applicable law, GeekHunter uses appropriate safeguards for international transfers, which may include data processing agreements, standard contractual clauses, contractual commitments, and/or other lawful transfer mechanisms recognized under the LGPD, GDPR, or other applicable regulations. We also implement technical and organizational measures designed to protect personal data during transfer and at rest.

7. LEGAL REASONS FOR DISCLOSING YOUR DATA

In certain circumstances, GeekHunter may disclose personal data to the extent necessary to comply with applicable law or legal process, or where we believe in good faith that disclosure is necessary to:

Comply with legal obligations and lawful requests;
Investigate, prevent, or take action regarding suspected illegal activities, security issues, or fraud;
Enforce our agreements and policies;
Protect the rights, property, and safety of GeekHunter, our users, and the public;
Respond to legal claims or participate in judicial, administrative, or arbitration proceedings;
Facilitate corporate transactions (sale, merger, reorganization, liquidation, dissolution).

Where permitted, we may challenge requests we consider excessive, vague, or issued by an incompetent authority.

8. SECURITY OF PERSONAL INFORMATION

GeekHunter and its providers employ administrative, technical, and organizational safeguards designed to protect the confidentiality, integrity, and security of personal data. Despite these measures, no system is completely secure. Users understand that risks may remain due to factors beyond our control.

In the event of a security incident that may create significant risk or harm, we will take steps to mitigate its effects and notify relevant authorities and affected individuals when required by applicable law.

9. DATA RETENTION

GeekHunter retains personal data for as long as necessary to provide the Services and fulfill the purposes described in this Policy. We may retain data after deletion requests or account closure when necessary to:

Comply with legal or regulatory obligations;
Resolve disputes;
Maintain security and prevent fraud or abuse;
Establish, exercise, or defend legal claims;
Enforce our agreements.

When retention is no longer necessary, we delete or irreversibly anonymize personal data, subject to applicable law and technical feasibility.

10. LEGAL BASES FOR PROCESSING

GeekHunter processes personal data only where a lawful basis exists under applicable law. Depending on the context and jurisdiction, our lawful bases may include:

Consent (where required);
Performance of a contract or taking steps at the request of the data subject prior to entering into a contract;
Compliance with legal obligations;
Legitimate interests (such as operating and improving the Platform, ensuring security, preventing fraud, analytics, and providing relevant job opportunities), where such interests are not overridden by the data subject’s rights and freedoms.

EEA/UK NOTICE: For data subjects located in the EEA or the UK, GeekHunter relies on lawful bases under GDPR/UK GDPR Article 6, and—where relevant—Article 9 for special category data. You may object to processing based on legitimate interests as described in Section 11, subject to applicable law.

11. RIGHT TO ACCESS AND CONTROL YOUR PERSONAL DATA

GeekHunter offers Users options regarding their personal data, which may include:

Deletion: request deletion of certain personal data, subject to Section 9 and applicable law.
Correction: request updates or corrections where data is inaccurate.
Objection or restriction: request that we stop or limit certain processing, subject to legal bases and obligations.
Access and portability: request a copy of your personal data in a commonly used format, where required by applicable law.
Consent withdrawal: withdraw consent where consent is the lawful basis; withdrawal does not affect processing already carried out.

EEA/UK: You may also have the right to lodge a complaint with a supervisory authority.

U.S. (INCLUDING CALIFORNIA): Depending on applicable law, you may have rights to access, delete, correct, and receive information about data sharing practices, subject to exceptions.

To exercise rights, contact our DPO at dpo@GeekHunter.com.br. We will respond within the timelines required by applicable law.

12. POLICY REVISIONS

We may update this Policy from time to time. If we make material changes, we will post the updated Policy on our website and update the Effective Date above.

13. CONTACT

For privacy questions or requests, contact our Data Protection Officer (DPO) at dpo@GeekHunter.com.br.

14. PREVIOUS VERSIONS

Previous versions may be made available upon request.

GeekHunter LLC | Effective Date: February 6, 2026