Privacy policy for the Vinci Compass employer branding and recruitment
Date of publication: 01-07-2026
We at Vinci Compass manage our employer branding and recruitment process through our career site (the “Career Site”), and by using a related applicant tracking system.
Depending on the position you are applying for and your location, your personal data may be processed in accordance with the European Union General Data Protection Regulation, the Brazilian General Data Protection Law (LGPD), and other applicable data protection laws.
In this privacy policy, we explain how we process your personal data if:
You visit our Career Site (you being a “Visitor”)
You connect with us via our Career Site, to create a profile with us and receive information about current or future vacancies with us (you being a “Connecting Candidate”)
You apply for a position with us, via our Career Site or a third party service (you being an ”Applying Candidate”)
We collect information about you from other parties, sites and services, since we believe your profile is of interest for our current or future vacancies (you being a “Sourced Candidate”)
We receive information about you from our employees or partners, since they believe your profile is of interest for our current or future vacancies (you being a “Referred Candidate”)
We receive information about you from a Candidate, who lists you as their reference (you being a “Reference”).
This privacy policy also describes what rights you have when we process your personal data, and how you can exercise these rights.
When we use the term “Candidate” in this privacy policy, we are referring to each of Connecting Candidates; Applying Candidates; Sourced Candidates; and Referred Candidates, unless it’s stated otherwise.
1. About processing of personal data.
Personal data is all information that can be directly or indirectly linked to a living, physical person. Examples of personal data are: name, e-mail address, telephone number and IP address. Processing of personal data is any automated use of personal data - such as collecting, creating, analyzing, sharing, and deleting personal data.
There are laws and regulations on how companies may process personal data, so-called data protection laws. Different data protection laws apply to different types of use of personal data, and in different parts of the world. Examples of laws that may apply to the processing activities described in this privacy policy, include the EU Data Protection Regulation (2016/679, “GDPR”), the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais – “LGPD”) and other applicable data protection laws.
Most obligations under the applicable data protection laws apply to the entity acting as data controller. A data controller is the entity that decides for which purposes personal data will be processed, and how the processing will be executed. The data controller can use a so-called data processor. A data processor is an entity that is only allowed to process personal data as instructed by the data controller and may not use the personal data for its own purposes.
Unless stated otherwise, Vinci Compass acts as the controller of the personal data processed under this Privacy Policy.
2. What personal data do we process?
All individuals
Website and Device information - When you visit our Career Site, certain technical information may be collected automatically, including IP address, browser information, device characteristics and information regarding your interaction with the Caree Site. Such information may be collected through cookies and similar technologies. Additional information is available in our Cookie Policy.
Communications data - We will collect and store your communication with us, including the information you provided in the communication. This may include the content of emails, messages exchanged through social media, information you add to your account with us, surveys responses and, where applicable, recording of interviews conducted during the recruitment process.
Candidates
Data from interviews, assessments and other information from the recruitment process - Such as notes from interviews with you, assessments and tests made, salary requirements.
Information in your application - Such as your CV, cover letter, work samples, references, letters of recommendation and education.
Information in your public profile - Meaning the information we collect about you from public sources related to your professional experience, such as LinkedIn or the website of your current employer.
Information provided by references - Meaning the information we receive from our employees or partners who refer you to us, or by the persons you have listed as your references.
3. Where do we receive your personal data from?
All individuals
From the Career Site. If you visit our Career Site, we collect technical and statistical information about how you use the Career Site, and information from your device.
Directly from you. Most of the information we process about you, we receive directly from you, for example when you apply for a position with us or connect with us. You can always choose not to provide us with certain information. However, some personal data is necessary in order for us to process your application or provide you the information you request to get from us.
References
Candidates
From public sources. We may collect personal data that you have made publicly available via professional networking platforms, such as LinkedIn or via the website of your current employer.
From our references. We may receive information about you from our employees or partners (such as recruitment service providers), when they believe your profile is of interest for our current or future vacancies.
From your professional references. If you provide us with professional references, we may collect information about you from them.
Data we create ourselves or in cooperation with you. Information about your application and profile is usually created by us, or by us in cooperation with you, during the recruitment process. This may for example include notes from interviews with you, assessments and tests made.
4. For what purposes do we process your personal data?
Protect and enforce our rights, interests and the interests of others, for example in connection with legal claims.
Affected individuals: The individual(s) affected by the legal issue - this may include persons from all categories of individuals listed above.
Categories of personal data used: Relevant categories of personal data listed above depending on the specific recruitment activity being performed.
Collect information about your use of the Career Site, using cookies and other tracking technologies, as described in our Cookie Policy.
Affected individuals: Visitors.
Categories of personal data used: Device information.
Maintain, develop, test, and otherwise ensure the security of the Career Site.
Affected individuals: Visitors.
Categories of personal data used: Device information; Technical and statistical data.
Analyse how the Career Site and its content is being used and is performing, to get statistics and to improve operational performance.
Affected individuals: Visitors.
Categories of personal data used: Device information; Technical and statistical data.
Provide you with updates about vacancies with us.
Affected individuals: Connecting Candidates.
Categories of personal data used: Contact details; Communications data.
Review profiles and applications sent to us. This also includes communicating with you about your application and profile.
Affected individuals: Connecting Candidates; Applying Candidates.
Categories of personal data used: Relevant categories of personal data listed above depending on the specific recruitment activity being performed.
Collect and evaluate your professional profile on our own initiative. This also includes communicating with you regarding your profile.
Affected individuals: Sourced Candidates; Referred Candidates.
Categories of personal data used: Relevant categories of personal data listed above depending on the specific recruitment activity being performed.
Contact you regarding future employment opportunities, where permitted by applicable law.
Affected individuals: Candidates.
Categories of personal data used: Relevant categories of personal data listed above depending on the specific recruitment activity being performed.
Record interview(s) where appropriate and permitted by applicable law and where consent has been obtained.
Affected individuals: Candidates.
Categories of personal data used: Communications data.
Contact you to invite you to participate in surveys.
Affected individuals: Candidates.
Categories of personal data used: Relevant categories of personal data listed above depending on the specific recruitment activity being performed.
Contact you to ask you to provide information about a Candidate, and evaluate the information you provide.
Affected individuals: References.
Categories of personal data used: Contact details; Communications data.
5. Whom do we share your personal data with?
Our service providers. We share your personal data with our suppliers who provide services and functionality in our employer branding- and recruitment process. For example, this includes recruitment service providers and the supplier of our Career Site and related applicant tracking system.
Our group companies. We share your personal data with our group companies, when they provide us services and functionality to our employer branding- and recruitment process, such as access to particular systems and software.
Companies providing cookies on the Career Site. If you consent to it, cookies are set by other companies than us, who will use the data collected by these cookies in accordance with their own privacy policy. You can find information about which cookies this applies to in our Cookie Policy.
To authorities and other public actors - when we are ordered to do so. We will share your personal data with authorities and other public actors when we have a legal obligation to do so.
To parties involved in legal proceedings. Where necessary to establish, exercise or defend our legal rights, we may disclose your personal data with public authorities or with other parties involved in a potential or existing legal proceeding. This may occur in connection with actual or potencial legal, administrative, regulatory or judicial proceedings including case of discrimination claims.
Mergers and acquisitions etc. In connection with a potential merger, sale of company assets, financing, or acquisition of all or part of our business to another company, we may share your personal data to other parties involved in the process.
6. On what legal bases do we process your personal data?
To process your personal data, we must rely on one or more legal bases recognized under applicable data protection laws.
Depending on the purpose of the processing, your location and the applicable legal requirements, we may process your personal data based on:
Our legitimate interests in conducting and improving our recruitment activities;
The need to take steps prior to entering into an employment or internship relationship;
Compliance with legal or regulatory obligations;
The protection, establishment, exercise or defence of legal rights;
Your consent, where required by applicable law; or
Any other lawful basis permitted under applicable data protection laws.
Where we rely on legitimate interests, we assess whether such interests are balanced against your rights and freedoms and whether the processing is necessary for the relevant purpose.
Where we rely on your consent, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal.
If you would like additional information regarding the legal basis applicable to a specific processing activity, you may contact us using the contact details provided in this Privacy Policy.
7. International transfers of personal data.
We may transfer and process your personal data in countries other than the country in which you are located, including countries where Vinci Compass, its affiliates, service providers or business partners operate.
Whenever personal data is transferred internationally, we implement appropriate safeguards and security measures designed to ensure that your personal data remains protected in accordance with applicable data protection laws.
Such safeguards may include contractual arrangements, adequacy decisions, internal policies, technical and organizational security measures, and other mechanisms recognized under applicable data protection laws.
If you want more information regarding international transfers of personal data, you can contact us using the contact details in Section 9 and 10 below.
8. For how long do we keep your personal data?
All individuals
If we process your personal data for the purpose of being able to protect and enforce our rights, we will keep your personal data until the relevant legal issue has been fully and finally resolved.
Visitors
We keep your personal data for one (1) year for security purposes. The retention periods for cookies are set out in our Cookie Policy. We keep your personal data to analyse the performance of the Career Site for as long as we keep personal data about you for other purposes.
Candidates
If you are a Connecting Candidate (only), we keep your personal data for as long as you maintain an active profile or relationship with us through the Career Site.
For other types of Candidates, we keep your personal data to decide if you are a suitable candidate for the relevant vacancy(ies) with us.
If you don’t succeed in the initial recruitment process, we may tetain your personal data for future employment opportunities only for as long as necessary to fulfil the purposes described in this Privacy Policy and in accordance with applicable legal, regulatory and operational requirements.
If you are hired, we will keep your personal data during your employment, for other purposes than those stated above, which you will be informed of.
References
We keep your personal data for as long as we keep the personal data of the Candidate for whom you acted as a reference.
9. What rights do you have, and how can you exercise them?
Depending on your location and the applicable data protection laws, you may have certain rights regarding your personal data, including the right to access, correct, delete, restrict or object to the processing of your personal data, withdraw consent where applicable, request portability of your personal data, and lodge a complaint with the competent authority.
If you want to exercise any of the rights listed here, we suggest that you:
Visit the Data & Privacy page on our Career Site, where we offer features to let you exercise your rights;
Log in to your account with us, where you can use the settings in the account to exercise your rights; or
Contact our Data Protection Officer (DPO) through the applicable Privacy Channel.
· For individuals located in Brazil: Fale com o Encarregado (DPO)
· For individuals located in other jurisdictions: Contact the DPO
10. Where can you turn with comments or questions?
If you want to get in touch with us to exercise your rights, or if you have any questions, comments or concerns about how we handle your personal data, you may contact our Data Protection Officer (DPO) through the applicable Privacy Channel.
· For individuals located in Brazil: Fale com o Encarregado (DPO)
· For individuals located in other jurisdictions: Contact the DPO
11. Updates to this Privacy Policy.
We update this privacy policy when necessary to reflect chances in our processing activities, applicable legal requirements, business operations or privacy practices.
We encourage you to regularly check this page for any changes. You can always check the top of this page to see when this privacy policy was last updated.
