Your privacy is a priority for Moray, a company based in Brazil (CNPJ: 46.503.195/0001-93), headquartered at Rua Andrade Fernandes 303, Annex 311, Unit 09, São Paulo/SP, ZIP 05449-050 (hereafter “Company” or “We”).

For the purposes of this document, we act as the Data Controller of all personal information collected through our website — whether from visitors, job candidates, or users submitting forms.

We are committed to complying with Brazil’s General Data Protection Law (LGPD – Law No. 13.709/2018), ensuring transparency and security in how we handle your data.

Questions about this policy? Contact our Data Protection Officer (DPO): dpo@moray.ai

We collect and use your data for the following purposes:

• Website browsing: Legitimate interest (LGPD Art. 7, IX)

• Forms (contact, newsletter, registrations): Consent (Art. 7, I)

• Recruitment process: Pre-contractual steps (Art. 7, V)

• Marketing communications: Consent (Art. 7, I)

• Legal obligations (e.g., invoicing): Legal obligation (Art. 7, II)

Depending on your interaction with the site, we may process:

During Browsing:

• IP address, approximate location, browser type

• Cookie data (see Section 4)

• Pages visited and time spent

Via Forms:

• Full name, email, phone, company

• Message content

• Demographic data (role, field of work)

For Job Applications (in addition to the above):

• Résumé, academic background, professional experience

• Interview videos, photos, references

• Work authorizations (if required)

Your data may be shared with trusted third-party providers that support our operations — such as hosting services, email platforms, analytics tools, and recruitment partners.

All data transfers and sharing are covered by agreements that ensure appropriate safeguards, in accordance with applicable legislation.

Note: International transfers follow EU Standard Contractual Clauses (SCCs) or equivalent mechanisms.

We use cookies to:

• Improve your browsing experience

• Personalize content and ads

• Collect usage statistics

You can manage cookie preferences via the website’s consent banner or your browser settings.

• Recruitment: We may use automated pre-screening (e.g., education/experience filters), but final decisions are always human.

• Marketing: We may segment emails based on site behavior (e.g., visited pages), always offering an opt-out option.

We adopt robust technical and organizational measures:

• Data encryption (in transit and at rest)

• Restricted access to authorized personnel only

• Periodic security audits

• Incident response plans (we notify users within 72 hours when legally required)

Data Type | Retention Period

• Browsing data: Up to 12 months

• Form submissions: 2 years after last contact or as required by law

• Successful job applications: Duration of employment contract

• Unsuccessful applications: 5 years (with consent) or legal period

You may request, at any time:

• Access to your personal data

• Correction of inaccurate information

• Deletion (unless required by law)

• Data portability (in structured format)

• Consent withdrawal (e.g., unsubscribe from newsletter)

• Objection to processing based on legitimate interest

To exercise your rights:
Email us at dpo@moray.ai with the subject line: “LGPD Data Request”.
We will respond within 15 days.

If you believe your data has been misused, you may:

1. Contact our DPO at dpo@moray.ai

2. File a complaint with Brazil’s National Data Protection Authority (ANPD): www.gov.br/anpd

We may update this policy to reflect legal or operational changes. The latest version will always be available on our website, with the revision date clearly indicated.

Last updated: March 19, 2024