Candidate Privacy Notice

Last updated: January 2, 2025 

Pegasystems is committed to protecting the privacy and security of your personal information. This privacy notice ("Privacy Notice") sets out how we collect your personal data and informs you of how and why your data will be used, specifically for the purposes of the recruitment exercise, and for how long it will be retained. Provides the information that must be provided under the Brazilian General Data Protection Law (LGPD). The notice applies to all applicants (employees, contractors or interns) in Brazil. For any questions about this privacy notice, please see the "Contact Details and Your Complaint Rights" section below. 

Responsibility for your information 
Pegasystems Serviços de Software do Brasil Ltda. and Pegasystems Inc. are "data controllers" of your personal information for the purposes of processing your application.  
 
This means that we are responsible for deciding how we hold and use personal information about you as an applicant for a position at Pegasystems (as an employee, contractor, trainee, or intern). 

The types of information we hold about you 
We collect, store and use the following categories of information about you during our recruitment process: 

• Your name, address, email address, phone number, and other contact information 

• The information you have provided to us in your resume and cover letter 

• Any additional information you provide to us in addition to an application 

• Information included in your profile created on our external careers site 

• Information from interviews and screenings you can go through 

• Details of the type of role you seek, current salary (where relevant) and salary expectations, and other terms relating to compensation and benefits packages or other employment preferences 

• Details of how you found out about the position you are applying for 

• Reference information and/or information received from pre-employment background checks, including information provided by third parties 

• Information related to any previous recruitment and/or employment history with us 

• If we offer you reimbursement of costs incurred by you in connection with the recruitment process and you accept that offer – information necessary to execute that reimbursement; 

• Information relevant to your right to work or to qualify for a traineeship/trainee, including nationality or citizenship, for visa purposes 

• CCTV images when visiting our facilities. 

• In addition, we may observe and process information that you make publicly available on various job sites, such as LinkedIn and GitHub, in connection with the purposes set forth in this Privacy Notice. This information may be considered when evaluating your job application. 

We may also collect, store, and use the following "special categories" of more sensitive personal information: 

• Information about your national origin, where relevant for visa purposes 

• Medical or health information, where relevant 

• Information about criminal convictions and offenses whenever necessary for the function and legally permitted. 

How is your personal information collected? 
We collect personal information about candidates from the following sources: 

• You (the candidate) 

• Our background check provider, from whom we collect the following categories of data: 

• Six-year activity history (including employment history) 

• Full academic record 

• Address verification 

• History of professional qualifications 

• Credit check (for professional, financial, and legal services positions only) 

• Verification of driver's license endorsements (for positions in professional, financial, and legal services) 

• Board Verification 

• Global Watchlist Check 

• Our recruitment service providers with whom we cooperate; 

• Your references, from which we obtain confirmation of your position and dates of employment 

• Any external contractor who advertises a position on our behalf 

• Information about you, including your contact details, your profile and CV (if available) from the following publicly available sources: LinkedIn, Xing, jobsinsaopaulo.com, No Fluff and Twitter 

How we will use information about you 
We will use the personal information we collect about you to: 

• Assess your skills, qualifications, and suitability for the position you are being considered for or other relevant positions we have 

• Use Predictive Index to perform a behavioral assessment; 

• Conduct background and reference checks, where appropriate 

• Communicate with you about the recruitment process, including, where appropriate, information about other potential career opportunities with us 

• Scheduling interviews, including scheduling by AI tool provided by a third party with whom we cooperate 

• Create records related to our hiring process 

• Help you obtain an immigration visa or work permit when needed 

• Review our recruitment practices, including diversity monitoring 

• Reimburse you for costs incurred by you in connection with the recruitment process (where relevant) 

• Comply with legal or regulatory requirements 

If you accept the position with us, the information collected during the recruitment process will be part of your employment record. 
 
It is your responsibility to obtain consent from the references to the processing of your personal information before providing it. 

How we use Sensitive Personal Data, as defined in Article 11 of the LGPD 
We use your Sensitive Personal Data in the following ways, where relevant: 

• We will use information about your disability status to consider whether we need to adjust the recruitment process 

• If relevant, we may use information about your national origin for visa and immigration purposes 

• We will use information about criminal convictions for positions that involve a high degree of trust and integrity, where legally permitted 

• Data related to diversity monitoring only where permitted by law to comply with our legal obligations 

We may only use information relating to criminal convictions where the law permits us to do so. We have appropriate safeguards in place when processing such data, which are required by law. 

Legal basis for processing personal information and sensitive personal information 
Our legal basis for processing your non-sensitive Personal Data is processing necessary for our legitimate interests, including the processing activities described above for our recruitment process and processing to exercise our rights in the event of any judicial, administrative, or arbitration proceedings. Our legal basis for processing your Sensitive Personal Data includes processing based on your consent for us to process your personal information for recruitment purposes. If you do not give your consent to process your sensitive personal data, which is necessary for us to consider your application, we will not be able to take you further in our recruitment process. For example, if we require health-related information for this role and you do not provide relevant details, we will not be able to pursue your application. You have the right to withdraw your consent to this processing at any time. To withdraw your consent, please contact [email protected]. Once we have received your notification that you have withdrawn consent, you will be removed from our recruitment process and, subject to our retention policy, we will securely dispose of your data unless required by law to retain it. 

If you do not provide personal information 
If you do not provide the information when requested, which is necessary for us to consider your application, we will not be able to take you further in our recruitment process. For example, if we require a reference for this position and you do not provide relevant details, we will not be able to pursue your application. 

You will not be subject to decisions that will have a legal or similarly significant impact on you, based solely on automated decision-making. 
  
DATA SHARING 
Why can you share my data with third parties? 
We will share your information with other companies in the Pegasystems group, as well as with limited members of our human resources, IT and finance departments, as necessary in accordance with our corporate structure and the location of our employees responsible for or otherwise participating in the recruitment process. In addition, as relevant, with our background check vendor, our recruiting service providers, our external auditors, and our IP provider. All of our third-party vendors and other group entities must take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only allow them to process your personal data for specified purposes and in accordance with our instructions.  

We may also be required to disclose your information to external third parties, such as local employment authorities, courts, regulatory bodies, and/or law enforcement agencies for the purpose of complying with applicable laws and regulations or in response to legal process. For internship and trainee opportunities, we may also be required to share your data with relevant educational entities to comply with applicable laws and regulations. 

Transfer of information outside Brazil 
We will transfer some of the personal information we collect about you to the following countries/regions outside of Brazil: USA and India (expenses only). There is no adequacy decision by the Brazilian Data Protection Authority in relation to these countries/regions, which means that the countries/regions to which we transfer your data are considered, at the time of the update, not to have the appropriate level of protection for your personal information. 
However, to ensure that your personal information receives an adequate level of protection, we have established agreements between companies, including standard contractual clauses with these entities outside Brazil, which is a mechanism set out in the LGPD to provide adequate protection. If you would like more information about this, please contact [email protected]. 

DATA SECURITY 
We have implemented appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, contractors, and other third parties who need to know a business. They only process your personal information in accordance with our instructions and are subject to a duty of confidentiality. 

DATA RETENTION 
How long will you use my information? 
We will retain your information in accordance with applicable law and our Retention Policy. We keep your information during this period so that we can comply with legal requirements. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations. 

If we wish to keep your personal information on the basis that a new opportunity arises and we want to consider you for this, we will contact you separately, seeking your explicit consent to retain your information for a specified period on that basis. 

ACCESS RIGHTS, ANONYMIZATION. CORRECTION, ERASURE, RESTRICTION AND PORTABILITY  
Your responsibility to inform us of changes 
It is important that the personal information we hold about you is accurate. Please keep us informed if your personal information changes during your recruitment process with us. 

Your Rights in Connection with Personal Information 
You may, in accordance with applicable law, have the right to: 

• Request confirmation of the processing of your personal information. This will allow you to confirm that we have processed your personal data. 

• Request access to your personal information. This enables us 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 data we hold about you. This enables you to correct any incomplete, inaccurate, or outdated information we hold about you. 

• Request anonymization or erasure of your personal information. This enables you to ask us to anonymizse, delete or remove personal information where there is no good reason for us continuing to process it or where we process your personal data based on your consent. You also have the right to request that we anonymize, 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 rely on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground.  

• Request restriction of processing of your personal information. This enables you to request that we suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for the processing. 

• Request information about public and private entities with which we share your personal data. This enables you to receive contact information from the entities to which we may have transferred your personal data. 

• Request information about the possibility of not giving consent and the related consequences, if you have any questions after reading this notice. 

• Request the transfer of your personal information to yourself or to a third party (the right to portability). 

• Revoke your consent as set forth in this notice. 

If you wish to exercise any of the above rights, please contact [email protected]. 

No Fee Required 
You will not have to pay a fee to access your personal information (or to exercise any other right).  

What we may need from you 
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 other rights). This is another appropriate security measure to ensure that personal information is not disclosed to anyone who does not have a right to receive it. 

CONTACT DETAILS AND YOUR RIGHTS TO COMPLAIN 
If you have any questions about this privacy notice or how we handle your personal information, please contact  

Roberto Paes 
Head of Data Processing for Brazil 
Pegasystems Serviços de Software do Brasil Ltda.
[email protected] 
 
You have the right to lodge a complaint at any time with the relevant supervisory authority for data protection issues in the country in which you are located. 

Status and changes to this notice 
This notice does not form part of any employment contract or other contract for the provision of services. We may update this notice at any time and the changes will appear on this page.