Privacy Policy (Brazil)

Last Updated: July 23, 2025
Last Reviewed: July 23, 2025
Applies to: Brazilian Users of Jobbers.io
Entity: Varlorys (French Sole Proprietorship)
Governing Law: LGPD – Lei Geral de Proteção de Dados (Law No. 13.709/2018)
Platforms: Website (jobbers.io) and Mobile Apps (iOS/Android)

1. Introduction

This Privacy Policy explains how Jobbers.io (operated by Varlorys, a French sole proprietorship) collects, uses, discloses, and manages your personal data when you use our website at https://www.jobbers.io and our mobile applications for iOS and Android (collectively, the “Platform”).

Jobbers.io is an international freelance marketplace operated from France, serving users worldwide including Brazil. We facilitate connections between freelancers/professionals and clients by providing a platform for them to find each other, communicate, and arrange their own work agreements and payments.

As a Brazilian resident or visitor, you have specific rights under Brazilian data protection law, which are outlined in this policy. Please note that as a French-based company, our primary operations and data processing activities are conducted from France, subject to European data protection standards, while ensuring compliance with Brazilian privacy requirements for our Brazilian users.

LGPD Compliance Commitment

We are committed to protecting your privacy in accordance with the Lei Geral de Proteção de Dados (LGPD – Law No. 13.709/2018). Our data processing practices are guided by LGPD principles:

• Purpose: We clearly state the purposes for which we process personal data
• Adequacy: Processing is compatible with specified purposes
• Necessity: We limit collection to what is necessary for identified purposes
• Free Access: We guarantee easy and free consultation about data processing
• Data Quality: We ensure accuracy, clarity, and relevance of data
• Transparency: We provide clear information about data processing
• Security: We implement appropriate technical and administrative measures

Key Information for Brazilian Users:

• French Sole Proprietorship: We are based in France and subject to French and European privacy laws
• International Platform: Your data will be processed globally to connect freelancers and clients
• International Transfers: Your personal data may be transferred outside Brazil
• Your Rights: You have rights under LGPD as outlined in section 12
• Marketplace Role: We facilitate connections but users arrange their own payments and contracts

2. Data Controller Information

Data Controller: Varlorys
Business Type: French Sole Proprietorship (Entreprise Individuelle)
Registration Number: 894 375 625 R.C.S. Pontoise
Business Address: 145 Rue du général Leclerc, 95130 Franconville, France
Service: International Freelance Marketplace
Contact Person: Driss LJAM BENNIS
Data Protection Officer: [email protected]

3. Personal Data We Collect

We collect personal data necessary to operate our freelance marketplace and provide our services. Under LGPD, we limit our collection to data that is necessary for the identified purposes.

3.1 Account and Profile Information

• Registration Details: Name, email address, password, username
• Age Verification: Confirmation that user is at least 18 years old
• Verification Data: Email verification, phone number verification
• Profile Information: Professional skills, work experience, education, service descriptions
• Contact Information: Phone number, preferred communication methods
• Profile Media: Profile pictures, portfolio images, work samples, certifications
• Professional Documentation: Certificates, qualifications, professional credentials
• Contact Visibility Preferences: Settings for displaying contact details through premium packs
• Content Moderation Data: Information reviewed and modified by our administrators for compliance

3.2 Premium Services and Billing Information

• Premium Package Purchases: Connection Packs, Professional Packs, Service Packs, Contact Packs, Project Packs
• Payment Details: Payment card details for platform services (processed by payment providers)
• Billing Information: Billing addresses, payment preferences for platform services
• Package Usage: Visibility boost usage, contact detail displays, search ranking improvements

3.3 Platform Activity Data

• Job and Project Data: Job postings, project descriptions, service offerings, proposals
• Proposal Management: Proposal statuses (accepted, pending, rejected), proposal content
• Communication Records: Chat messages, file sharing through our messaging system
• Ratings and Reviews: Reviews and ratings between freelancers and clients
• Portfolio Content: Work samples, portfolios, certifications, professional qualifications
• Search and Browse History: Jobs viewed, searches performed, saved profiles
• Contact Interactions: When contact details are displayed or accessed through premium packs
• AI Translation Data: Content submitted for automatic translation services

3.4 Technical Information

• Device Information: Device type, operating system, browser type, unique device identifiers
• Usage Data: Pages visited, time spent, click patterns, feature usage
• Network Information: IP address (anonymized), internet service provider, connection type
• Cookies and Tracking: As described in our Cookie Policy

3.5 Mobile App Permissions and Data

Our mobile apps may request the following permissions to provide enhanced functionality:

• Camera: To take profile photos and capture documents for verification
• Photo Library: To upload images for profiles and portfolios
• Contacts: To help you connect with existing contacts on the platform (with your consent)
• Location Services: To show location-based job opportunities and verify your location
• Push Notifications: To send important updates about jobs, messages, and platform activities
• Microphone: For voice messages and video calls (if available)
• Storage Access: To store app data and enable offline functionality
• Network Access: To connect to our services and sync data

Note: You can manage these permissions through your device settings at any time.

4. How We Collect Personal Data

Under LGPD, we are transparent about how we collect your personal data:

4.1 Direct Collection

• Account Registration: When you create an account (must be 18+ years old)
• Profile Creation: When you set up your freelancer or client profile
• Verification Processes: Email and phone number verification
• Form Submissions: Contact forms, job applications, project postings
• Communications: When you contact us or communicate with other users
• Administrative Review: During our validation process for profiles, services, and projects
• Surveys and Feedback: Voluntary participation in platform surveys
• Rating and Review System: When you provide or receive evaluations

4.2 Automated Collection

• Website and App Usage: Through cookies, analytics, and tracking technologies
• Device Information: Automatically collected when you access our platform
• Location Data: Through IP address or GPS (with permission on mobile)
• Performance Monitoring: App crashes, error reports, usage statistics

4.3 Third-Party Sources

• Social Media: When you connect social media accounts (with your consent)
• Payment Providers: Transaction and verification data from PayPal, Stripe
• Verification Services: From email and SMS verification providers
• Public Sources: Publicly available professional information

5. Legal Bases and Purposes for Data Processing

Under LGPD, we process your personal data based on the following legal bases and for the following purposes:

6. Sharing and Disclosure of Personal Data

Under LGPD, we limit the use, disclosure, and retention of personal data to the purposes for which it was collected. We may share your personal data in the following circumstances:

6.1 With Other Platform Users

• Public Profile Information: Name, profile picture, skills, services, reviews, portfolio
• Contact Details: Phone number and email (through premium Contact Packs, when authorized)
• Communication: Direct messaging through our chat system for project discussions
• Project Information: Project details, proposals, and related communications
• Reviews and Ratings: Feedback provided by clients and freelancers
• Portfolio Content: Work samples, certifications, and professional credentials

6.2 With Service Providers (Data Processors)

• Payment Processors: PayPal, Stripe (for platform premium package purchases only)
• Cloud Hosting: AWS, Google Cloud (for data storage and processing)
• Analytics Services: Google Analytics (for platform analytics, with consent)
• Communication Tools: Email and messaging service providers
• AI Translation Services: Third-party providers for automatic content translation
• Verification Services: Email and SMS verification providers
• Customer Support: Help desk and support platforms

6.3 Legal and Compliance Sharing

• Law Enforcement: When required by law or court order
• Regulatory Authorities: For compliance with applicable laws
• Legal Proceedings: In connection with legal disputes or investigations
• Safety Protection: To protect the safety of users or the public

6.4 Business Transfers

If our business is sold, merged, or acquired, your personal data may be transferred to the new owners as part of the business assets, subject to the same privacy protections and your consent where required by LGPD.

7. International Transfer of Personal Data

As an international platform operated by a French company, your personal data will be transferred outside Brazil. Under LGPD, we are required to inform you about these transfers and obtain your consent.

7.1 Countries Where Your Data May Be Transferred

• Germany: Our primary operations and main servers
• European Union: Additional hosting and service providers
• United States: Cloud services (Google, AWS), payment processors (Stripe, PayPal)
• Other Countries: Where freelancers, clients, and service providers are located

7.2 Safeguards for International Transfers

Before transferring your personal data outside Brazil, we ensure that:

• Adequate Level of Protection: Recipients provide adequate data protection
• Contractual Protections: We have agreements requiring recipients to protect your data
• Your Consent: You consent to transfers when you use our international platform
• Legal Compliance: Transfers are necessary for our services or required by law
• GDPR Standards: Our French operations comply with strong European privacy standards

7.3 Platform-Specific Transfers

As a global freelance marketplace, transferring your data internationally is essential for:

• Connecting you with freelancers and clients worldwide
• Processing premium package purchases
• Providing AI translation services for multilingual communication
• Providing customer support across time zones
• Ensuring platform security and preventing abuse
• Facilitating direct communication and project arrangements between users

8. Data Retention

Under LGPD, we retain personal data only for the period necessary to fulfill the purposes for which it was collected:

9. Data Security and Protection

Under LGPD, we are committed to implementing appropriate technical and administrative security measures to protect your personal data:

9.1 Technical Safeguards

• Encryption: Data encrypted in transit and at rest using industry standards
• Access Controls: Multi-factor authentication and role-based access
• Network Security: Firewalls, intrusion detection, and monitoring
• Regular Updates: Security patches and system updates
• IP Address Anonymization: Full IP addresses are blocked from Google Analytics

9.2 Administrative Safeguards

• Staff Training: Regular privacy and security training for employees
• Background Checks: Screening of personnel with access to personal data
• Incident Response: Procedures for handling security breaches
• Third-Party Agreements: Data processing agreements with all service providers

9.3 Data Breach Response

In the event of a data breach affecting Brazilian users:

• We will notify the ANPD (National Data Protection Authority) when required
• We will notify affected individuals when the breach poses relevant risk or damage
• We will provide information about the breach and steps to protect yourself
• We will take immediate action to contain and remedy the breach

10. Cookies and Tracking Technologies

We use cookies and similar technologies as described in our Cookie Policy (Brazil). Key points include:

• Essential Cookies: Required for platform functionality
• Analytics Cookies: To understand platform usage (with consent)
• Marketing Cookies: For advertising and personalization (with consent)
• Third-Party Cookies: From our service providers and partners
• Google Analytics: We have a data processing agreement with Google and block full IP addresses

You can manage your cookie preferences through our consent management platform and your browser settings.

11. Marketing and Communications

11.1 Platform Communications

We will send you essential platform communications including:

• Account security notifications
• Transaction confirmations
• Important platform updates
• Legal and policy changes

11.2 Marketing Communications

With your explicit consent, we may send:

• Newsletter and platform updates
• Job recommendations and opportunities
• Feature announcements
• Educational content and tips

You can withdraw consent and opt-out of marketing communications at any time using the unsubscribe link or contacting us.

12. Your Rights Under LGPD

Under the Lei Geral de Proteção de Dados (LGPD), you have the following rights regarding your personal data:

12.1 Fundamental Rights

• Confirmation of Processing: Confirmation of the existence of processing of your personal data
• Access to Data: Access to your personal data that we process
• Correction: Correction of incomplete, inaccurate, or outdated data
• Anonymization, Blocking, or Deletion: Of unnecessary, excessive, or data processed in disagreement with LGPD provisions
• Data Portability: Portability of data to another service or product provider, upon express request, observing commercial and industrial secrets
• Deletion: Deletion of personal data processed with your consent, except in cases provided for in art. 16 of LGPD
• Information on Sharing: Information on public and private entities with which we have shared your data
• Information on Non-Consent: Information on the possibility of not providing consent and the consequences of denial

12.2 Additional Rights

• Consent Withdrawal: Withdraw consent at any time without affecting prior lawful processing
• Objection to Processing: Object to processing based on legitimate interests
• Automated Decision Review: Information about automated decision-making processes

12.3 How to Exercise Your Rights

To exercise your rights:

• Email: [email protected]
• Subject Line: “Brazilian Privacy Request – [Type of Request]”
• Include: Your account email, specific request details, identity verification
• Response Time: We will respond within 15 days as required by LGPD
• Fees: No charge for standard requests

12.4 Complaint Process

If you have a privacy complaint:

1. Contact Us First: Send your complaint to [email protected]
2. We Will Investigate: We’ll investigate and respond within 15 days
3. ANPD Complaint: If unsatisfied, you can complain to the National Data Protection Authority

12.5 Quick Data Request Form

For common requests, you can use our simplified request process:

Name: [Your Full Name]

Email: [Your Account Email]

Request Type:

• Submit a request for access to the data we process about you
• Submit a request for deletion of data if it is no longer relevant
• Submit a request to receive an export file of the data we process about you
• Submit a request for correction of inaccurate data
• Submit a request for information about data sharing

Send your completed request to: [email protected]

13. Age Restrictions and Children’s Privacy

Our platform is strictly intended for individuals who are 18 years of age or older. We do not knowingly collect personal data from anyone under 18 years of age.

Age Verification: During registration, users must confirm they are at least 18 years old. This is required for:

• Legal capacity to enter into work agreements
• Compliance with our terms of service
• Protection of minors from inappropriate content
• Meeting legal requirements for freelance marketplace participation

If we become aware that we have collected personal data from someone under 18, we will take immediate steps to delete such information and terminate the account.

If you believe we have collected information from someone under 18, please contact us immediately at [email protected].

14. Content Moderation and Administrative Review

To maintain platform quality and safety, we conduct administrative review and content moderation:

14.1 Administrative Validation Process

• Profile Review: All freelancer and professional profiles require admin approval before going online
• Service Validation: New or modified service listings are reviewed before publication
• Project Approval: Client project postings are validated before becoming visible
• Content Modification: We may edit content to remove contact details, correct categories, or remove inappropriate content

14.2 What We Review

• Professional qualifications and service descriptions
• Compliance with platform guidelines
• Removal of personal contact details from inappropriate fields
• Category accuracy and content relevance
• Age verification (18+ requirement)

14.3 Content Standards

We review content to ensure it is not:

• Abusive, defamatory, or discriminatory
• Misleading about qualifications or services
• Containing inappropriate contact information disclosure
• Violating intellectual property rights
• Against applicable laws and regulations

15. Our Role as a Marketplace Facilitator

Important: Jobbers.io acts as a marketplace facilitator that connects freelancers and clients. We provide the platform and tools for users to find each other and communicate, but we do not:

• Process payments between users: Users arrange their own payment methods and terms
• Mediate disputes: Users handle project disputes directly with each other
• Guarantee work quality: We provide a rating system but users are responsible for vetting each other
• Act as an employer: We facilitate connections but are not party to work agreements

We do provide:

• Platform hosting and maintenance
• Communication tools (chat, file sharing)
• Premium visibility and contact packages
• AI translation services
• User verification (email and phone)
• Rating and review systems

16. Third-Party Services and Links

Our platform may contain links to third-party websites, services, or integrations. This privacy policy does not apply to third-party services. We recommend reading the privacy policies of any third-party services you use.

16.1 Social Media Integration

If you connect social media accounts, we may access certain information from those platforms according to your privacy settings on those platforms.

16.2 Payment Processors

Payment processing is handled by third-party providers (PayPal, Stripe) who have their own privacy policies and are responsible for protecting your payment information.

17. Changes to This Privacy Policy

We may update this privacy policy to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

• Posting the updated policy on our platform
• Updating the “Last Updated” date
• Sending email notifications for significant changes
• Obtaining fresh consent where required by LGPD

We encourage you to review this policy periodically to stay informed about how we protect your privacy.

18. Contact Information

If you have questions about this Privacy Policy or our privacy practices, please contact us:

Data Controller Details:

Varlorys (French Sole Proprietorship)
Registration: 894 375 625 R.C.S. Pontoise
Business: International Freelance Platform (Jobbers.io)
Address: 145 Rue du général Leclerc, 95130 Franconville, France
Brazilian Service Area: All Brazilian states and territories

Contact Information:

Website: https://www.jobbers.io
General Email: [email protected]
Privacy Email: [email protected]
Phone: +33 6 88 95 37 10 (French timezone: CET/CEST)

Data Protection Officer:

Name: Driss LJAM BENNIS
Title: Privacy Contact / Data Protection Officer
Address: 145 Rue du général Leclerc, 95130 Franconville, France
Email: [email protected]

Brazilian Privacy Authority:

If you’re not satisfied with our response to your privacy concern, you can lodge a complaint with:

Autoridade Nacional de Proteção de Dados (ANPD)
Address: Esplanada dos Ministérios, Bloco C, 2º andar, CEP 70297-400 – Brasília – DF
Website: www.gov.br/anpd
Email: [email protected]

Response Times:

General Inquiries: 24-48 hours
LGPD Rights Requests: 15 days (as required by LGPD)
Urgent Privacy Matters: 72 hours
Data Breach Notifications: As required by law