Privacy Policy

1. Data Controller

The data controller responsible for the processing of personal data collected through the Website is Howdy, Inc., a company incorporated under the laws of the State of Texas, United States.

This Privacy Policy applies exclusively to information collected through the Website and does not apply to information obtained offline or through other channels not controlled by Howdy.

2. Information We Collect

We collect personal data when the user applies for professional opportunities, completes forms, registers for activities, participates in events, or contacts us through the Website.

Personal data may include, among others:

2.1 Identification and contact data

• First and last name
• Email address
• Phone number
• Country and city of residence

2.2 Professional information

• Resume/CV
• Work experience
• Technologies and skills
• Languages
• Education and certifications
• Links to professional profiles (e.g., LinkedIn, GitHub, personal portfolio)

2.3 Communication information

• Messages, inquiries, or requests sent through the Website or related channels.

2.4 Technical and browsing data

• IP address
• Browser and device type
• Cookie information
• Pages visited and browsing behavior
• Website analytics and performance data

Howdy does not request banking information, financial data, or unnecessary sensitive information.

3. Voluntarily Provided Information and Third-Party Data

Users may voluntarily provide additional information through the Website.

If a user shares personal data of third parties (for example, professional references), the user represents that they have the appropriate authorization to share such information.

Howdy is not responsible for third-party information submitted by a user without authorization.

4. Use of Information and Legal Basis

Howdy uses personal data for the following purposes:

4.1 Managing applications and recruitment processes

• Evaluate professional profiles and manage applications.
• Coordinate interviews and internal evaluation processes.
• Contact the user regarding current or future job opportunities.

Legal basis: taking pre-contractual steps and/or legitimate interests.

4.2 Institutional communications and marketing (optional)

• Send informational communications, news, event invitations, or content related to Howdy LATAM, only where consent has been provided or where permitted by applicable law.

Legal basis: consent and/or legitimate interests.

4.3 Website improvement and internal analytics

• Analyze Website usage.
• Improve user experience, features, and internal processes.
• Optimize content and Website performance.

Legal basis: legitimate interests.

4.4 Legal compliance and fraud prevention

• Comply with applicable legal obligations.
• Prevent misuse, unauthorized access, fraud, and impersonation.
• Respond to requests from competent authorities.

Legal basis: legal obligation and legitimate interests.

5. Sharing of Information

Howdy does not sell or rent personal data.

Personal data may be shared only in the following cases:

5.1 Service providers

Howdy may share information with external providers that provide technological or operational services, such as CRM platforms, ATS platforms, hosting, analytics, automation, and communications services.

Such providers act as data processors and process data only under Howdy's instructions and subject to contractual confidentiality and security obligations.

5.2 Client companies

Howdy may share information with client companies only when necessary to assess the user's suitability within a recruitment or hiring process.

5.3 Legal requirements

Howdy may disclose information when required by law, court order, or competent authority, or when necessary to protect the rights, security, or integrity of Howdy, its users, or third parties.

6. International Data Transfers

Personal data collected may be transferred, stored, and processed in the United States or other countries where Howdy or its service providers operate.

Howdy takes reasonable measures to ensure that such transfers are carried out under appropriate data protection and security standards, including contractual agreements with providers and technical security measures.

7. Data Retention

Personal data will be retained as long as it remains relevant for current or future recruitment processes, or as otherwise necessary to fulfill the purposes described in this Privacy Policy.

Users may request deletion of their data at any time, unless there is a legal obligation or legitimate need to retain it.

In general, Howdy may retain application-related information for a reasonable period of time to consider users for future job opportunities.

8. Information Security

Howdy implements reasonable technical, administrative, and organizational measures to protect personal data against loss, unauthorized access, misuse, alteration, or disclosure.

However, the user acknowledges that no system is completely secure and that, despite reasonable efforts, absolute security of information transmitted over the Internet cannot be guaranteed.

9. Automated Decision-Making and Profiling

Howdy may use technological tools to organize, classify, or analyze professional information to improve internal recruitment processes.

Howdy does not make decisions based solely on automated processing that produce significant legal effects for the user without human involvement.

10. Cookies and Analytics

The Website uses first-party and third-party cookies to:

• Remember browsing preferences.
• Analyze Website usage.
• Improve user experience and Website performance.

The use of cookies is subject to the consent provided through the applicable banner and the user's browser settings.

Users may disable cookies through their browser settings, although this may affect the Website's functionality.

11. User Rights

Users may exercise the following rights in accordance with applicable law:

• Access their personal data.
• Request correction or updating.
• Request deletion.
• Object to or restrict processing.
• Request portability, where applicable.
• Withdraw consent at any time, where processing is based on consent.

To exercise these rights, users may send a request to info@howdy.com.

Howdy may request additional information to verify the requester's identity before processing the request.

12. Right to Lodge a Complaint with a Competent Authority

If the user believes that the processing of personal data infringes applicable law, the user may lodge a complaint with the competent data protection authority in their country of residence or the applicable jurisdiction.

13. Children's Privacy

The Website is not directed to individuals under 18 years of age. Howdy does not intentionally collect personal data from minors.

If it is detected that a minor has provided personal data without authorization, Howdy will delete it to the extent reasonably possible.

14. Changes to this Privacy Policy

Howdy may update this Privacy Policy at any time.

Any changes will become effective upon publication on the Website. Users are encouraged to periodically review this section to stay informed about updates.

15. Contact

For any questions related to this Privacy Policy or to exercise rights related to the processing of personal data, the user may contact us at: info@howdy.com