Privacy Policy
DPO: Renata Miziés de Barros (email: dpo@skyone.solutions)
We at Skyone are committed to respecting the privacy, protection, and security of our users' Personal Data, and we treat the information collected in accordance with Brazilian laws relating to privacy and the protection of Personal Data, such as the General Data Protection Law (LGPD).
Therefore, any information you provide to us will be treated in accordance with the limits established here and under the terms of applicable law. The same applies to companies acquired by the Skyone Group, which adhere to a rigorous program of compliance with best practices and alignment with our corporate processes.
With this Privacy Notice, we want to communicate the following aspects to you in an objective and transparent manner:
- What is Skyone's role in handling your Personal Data?
- For the sake of understanding. How about we clarify some of the technical terms in this Notice for you?
- To whom does this Notice apply?
- Children and Adolescents;
- What personal data of yours do we process?
- How and for what purpose do we use your information?
- What are cookies and how do we use them?
- How long is your Personal Data kept?
- Who has access to and with whom do we share your Personal Data?
- International Data Transfer
- What are your rights?
- Your choices and how to exercise your rights;
- How do we keep your data secure?
- Links to other websites;
- Changes to this Notice;
1. What is Skyone's role in handling your Personal Data?
In the course of its activities, Skyone performs various Personal Data Processing operations, and may be characterized as a Personal Data Operator or Controller, always committed to seeking the best interests of the respective data subjects and respecting their rights based on current legislation, especially the LGPD (Brazilian General Data Protection Law).
Select one of the options below to view practical examples of Skyone's role as a Data Processor or Controller, depending on the context of the processing:
For example, in its relationship with its clients, Skyone acts as a Personal Data Processor when it processes Personal Data in accordance with the lawful instructions of its clients.
On the other hand, when acting with decision-making power regarding the main elements of the Processing activity, such as the Processing of Personal Data hosted in its environments, or regarding the Personal Data of its employees or collected in marketing actions and website navigation, Skyone will act as a Personal Data Controller.
2. For the right to understand. How about we clarify some of the technical terms in this Notice for you?
| Term/Expression | Meaning |
| National Data Protection Authority (or ANPD) | The public administration body responsible for overseeing compliance with the provisions of the LGPD (Brazilian General Data Protection Law) throughout Brazil. |
| Personal Data | Any information capable of identifying a natural person, directly or indirectly. |
| Sensitive Personal Data | Any Personal Data relating to racial or ethnic origin, religious beliefs, political opinions, membership of a trade union or religious, philosophical or political organization, as well as data concerning health or sex life, genetic or biometric data. |
| DPO (or Data Protection Officer) | This professional is responsible for acting as a communication channel between Skyone, data subjects, and the ANPD (Brazilian National Data Protection Authority). Their main objective is to ensure that Skyone complies with laws and regulations relating to privacy and data protection. |
| LGPD | General Law on the Protection of Personal Data (Federal Law No. 13.709/2018) |
| Privacy by Design | Privacy by design is the principle of the LGPD (Brazilian General Data Protection Law) that requires the protection of personal data to be considered from the very beginning of any company project, system, or process—and not just after it is already in operation. This means planning and adopting preventive measures to ensure the security and correct use of data from the very first moment. |
| Third parties | Any and all individuals or legal entities with whom Skyone interacts or may interact. This includes, but is not limited to, service providers, suppliers, consultants, partners, contracted or subcontracted third parties, regardless of whether a formal contract exists or not, including those who use the Company's name, provide materials, interact with public officials, the government, or other third parties on behalf of Skyone |
| Holder | The individual to whom the Personal Data refers. |
| Treatment | Any activity performed with Personal Data, such as collection, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, updating, communication, transfer, sharing, dissemination or extraction, according to Article 5, X, of the LGPD (Brazilian General Data Protection Law). |
3. To whom does this Notice apply?
This Notice applies to (i) Skyone's individual and corporate clients; (ii) all third parties, whether individuals or legal entities, acting for or on behalf of Skyone in operations involving the Processing of Personal Data; and (iii) visitors to our Sites and users of our platforms.
This Privacy Notice also applies to the websites http://www.skyone.solutions
or https://www.skyone.cloud
or https://support.skyone.cloud/
or https://latamsuporte.skyone.cloud/
or https://suporte.skyone.cloud/
4. Children and Adolescents
Our services are not designed for, nor intended for, use by individuals under 18 years of age. For this reason, we do not collect or voluntarily solicit information from individuals under 18 years of age through the forms available on our services. Therefore, if we happen to receive information, we will delete it and not retain it in our databases. If you suspect that an individual under 18 years of age is using Skyone's services, you may send an email to: dpo@skyone.solutions.
5. What Personal Data of yours do we process?
In order to respect your privacy, we understand that any and all processing of personal data must be limited to the minimum necessary, in a relevant and proportionate manner, to allow the intended purpose to be achieved.
Therefore, the Personal Data we collect about you will vary depending on your relationship with us, whether you are a client, consumer, visitor, partner, or other.
Below, grouped into categories, we present the main Personal Data that may be processed by us:
- Registration data: may include first and last name, date of birth, gender, ID number, and CPF (Brazilian tax identification number);
- Qualifying data: may include residential/business address, area/department, nationality, parentage;
- Contact information: may include landline or mobile phone numbers and personal and/or professional email addresses, information related to any user support services;
- Professional information: may include profession, workplace, job title, and work history;
- Financial information: checking account, bank branch, or other payment method used when contracting our services;
- Social media data: social media profiles that you use to interact with us, primarily LinkedIn, Instagram, Threads, TikTok, YouTube, and Facebook;
- Attributes associated with your electronic devices: IP address, user, access provider, operating system, browser (type, version, enabled options and installed plug-ins), video settings (size/resolution and number of colors), date and time of access, and pages viewed through cookies.
- How and for what purpose do we use your information?
6. How and for what purpose do we use your information?
The information we process about you may have been provided directly by you to Skyone, by third parties, or even collected automatically through our platform and other channels.
Let's understand each of these data collection situations better?
a. Information provided directly by you
From the very beginning of your interaction with us, you voluntarily provide us with information about yourself. For example, when you contact us through social media or publicly tag us in a photo at an event. Or even when you use one of our customer service and support channels, or want to speak with one of our specialists. Furthermore, when you interact with the content on our Platform, register to participate in a selection process on our website, or subscribe to receive our newsletters .
b. Information obtained from third parties
In specific cases, we may also receive some of your Personal Data from Third Parties. For example, information provided by Skyone's contractors, such as employers, consultants, service providers, or suppliers who help us offer increasingly better products and services for you.
c. Information obtained automatically
In some situations, we may also automatically collect Personal Data through the devices you use to access our Platform. This information helps us generate access statistics and thus better understand our audience. This is important so that we can improve our Platforms and services and adapt them to the most diverse audiences. Some of this data may be collected through cookies or similar technologies, as we will explain in a specific section.
d. Publicly available information
There is also the possibility of collecting information about you that is publicly available and on social media (such as LinkedIn, Instagram, Threads, TikTok, YouTube, and Facebook).
Therefore, from the collection of your information, we can use it for several different purposes. Below, we list our main purposes, as well as the main groups of data used:
| Personal data category | Purposes | Legal basis |
| Registration data; Qualification data; Contact information; Financial data. | To enable a service/product requested by you, we will process your data in order to provide the service/product you purchased. | Contract execution |
| Registration data; Contact information; Financial data. | To execute a contract you have entered into with us or to carry out pre-contractual due diligence: If you are a party to a contract with Skyone, or represent a company in a contract, we will process your Data for the conclusion and execution of the contract, to ensure the completion of the work and the respective payment. | Contract execution |
| Registration data; Qualification data; Contact data | Communication • We may process your Personal Data to respond to your requests or other interactions with us, such as via email, chat, or other tools on our websites. • To send relevant notices about our activities, such as changes of address and corporate structure. • To send updates that impact your relationship with us in the interest of transparency, for example, updates to this Privacy Notice. | Legitimate interest or Contract Execution |
| Registration data; Qualification data; Contact data | To comply with our legal or regulatory obligations, your Personal Data may be used to fulfill our obligations under the law and/or regulations of government agencies and orders or requests from tax authorities, the Judiciary, and/or other competent authorities. For example, we may process Personal Data for the issuance of invoices. | Compliance with a legal or regulatory obligation |
| Registration data; Contact information | To allow the regular exercise of our rights: Even after the termination of your relationship with us, we may process some of your Personal Data to exercise our rights guaranteed by law, including as evidence in judicial, administrative or arbitration proceedings. | Regular exercise of rights |
| Registration data; Contact information; Social media data; Attributes associated with your electronic devices. | To enable activities necessary for Skyone, we may also process your Personal Data in activities such as: improvements to our products and services, research and questionnaires, event promotion, sending gifts, relationship management with our clients and partners, company performance analysis and reports, and internal consultations. In activities supporting Skyone's interests, we will always observe the limits of your expectations, and the processing of Personal Data will not prejudice your interests, rights, or fundamental freedoms. | Legitimate interest |
| Registration information; Contact information; Professional information. | Recruitment and selection: We may process your Personal Data to receive your application (including through specialized websites), analyze your resume, verify your skills and curriculum information, and determine whether or not you meet the specific requirements of the position you applied for, as well as to proceed with the selection process, when applicable, in situations such as contacting you by phone or email and scheduling interviews. | Legitimate interest |
| Registration data; Contact information; Social media data; Attributes associated with your electronic devices. | Creating Interest Profiles: We may analyze your Personal Data to create a profile of your interests and preferences so that we can tailor and target our communications in a timely and relevant manner for you. We may use additional information about you when it is available from external sources to help us do this effectively. This allows us to be more focused, efficient, and economical with our resources and reduces the risk of you receiving information that is considered inappropriate or irrelevant. | Legitimate interest |
| Registration data; Contact information; Social media data; Attributes associated with your electronic devices. | Marketing Communications: We will only send marketing communications via email, text, and phone if you have explicitly given your prior consent. You can opt out of our marketing communications at any time by clicking the unsubscribe link at the bottom of our marketing emails or, in the case of text and phone calls. | Consent |
7. What are cookies and how do we use them?
Cookies are text files that may be stored on your electronic devices when you visit our Sites. We use this tool for different purposes, such as generating access statistics and improving your experience on our Sites.
Below is a list of the types of cookies used and their purposes:
| Cookie Type | What do they do? |
| Necessary/Essential | To ensure the proper functioning of our Sites, as well as to allow you to make use of all available features. |
| Performance/Analysis | They help us understand how visitors interact with our Sites by providing information about the areas visited, the time spent on the Platform, and any problems encountered. |
| Functional | They allow us to remember your previous choices, such as your browsing language. They are responsible for providing a personalized experience. |
| Marketing/Advertising | Used to provide more relevant and specific content tailored to your interests. They can also be used to deliver more targeted advertising or limit the number of times it is shown. Additionally, they allow for measuring the effectiveness of a launched campaign. |
We would like to emphasize that necessary cookies are essential for the normal functioning of our Sites. This means that if you object to the use of this tool, it may compromise your experience or result in the suspension of your access.
You can manage your preferences at any time through our cookie banner or through our tool available at: https://skyone.solutions/pb/cookies/ ;
8. How long is your Personal Data kept?
Skyone retains Personal Data only for the period necessary to fulfill the purposes for which it was collected, including compliance with applicable legal, contractual, or regulatory obligations.
When Personal Data is no longer necessary for such purposes or when there is no legal basis for its retention, it will be deleted or anonymized, as applicable, in accordance with current legislation, especially article 15 of the LGPD (Brazilian General Data Protection Law), and in accordance with Skyone's internal data processing records.
9. Who has access to and with whom do we share your Personal Data?
We do not share your Personal Data with third parties for marketing purposes.
However, we may disclose your Personal Data to Third Parties in order to achieve the other purposes set out in this Notice. These Third Parties may include:
- companies within the Skyone economic group, so that we can provide our services and evaluate the efficiency of our service;
- Business partners and service providers, to enable the operation of communication channels, as well as providing the necessary infrastructure for the viability of our services;
- hypothetical scenarios of corporate transactions, such as mergers, acquisitions, spin-offs, and incorporations;
- administrative and judicial authorities when necessary to fulfill a legal obligation or to assist in the investigation of suspicious or illegal activities; and
- law firms, legal advisors, and other legal representatives when necessary to defend Skyone's interests in administrative, arbitration, or judicial proceedings
When we share your Personal Data in the situations described above, we use contractual instruments to ensure that any Third Party that receives it guarantees adequate protection for it.
10. International Data Transfer
Skyone adopts, whenever applicable, governance measures that include conducting Data Protection Impact Assessments (DPIAs), reinforcing our commitment to the principle of privacy by design and to the adoption of technical and organizational controls proportionate to the risks involved, identifying, assessing and mitigating risks before initiating processing.
Skyone may also review and update these assessments periodically, in accordance with technological advancements and changes in the operational context.
All Personal Data is stored in systems located in Brazil, the United States, Germany, and other regions such as Asia (including India and Saudi Arabia), when applicable, observing the appropriate levels of data protection required by applicable legislation. We may also relocate and store these systems in any other country that offers an adequate level of personal data protection or that observes the safeguards provided for in the LGPD (Brazilian General Data Protection Law) and, when applicable, in the GDPR (General Data Protection Regulation), always keeping them under our supervision and in a secure manner. All transfers will observe the principles of purpose, necessity, security, and transparency, ensuring the rights of data subjects.
In situations where it is necessary to share Personal Data with a third party located outside of Brazil, including Skyone group companies, in addition to guaranteeing the security and protection of Personal Data through a contract, Skyone will use one of the legal grounds for international data transfer authorized by applicable legislation, in particular those provided for in articles 33 et seq. of the General Data Protection Law (Law No. 13.709/2018) and in the ANPD's Regulation on International Data Transfer (Resolution CD/ANPD No. 15/2024).
Where applicable, Skyone will also observe the obligations set forth by the European Union's General Data Protection Regulation (GDPR), including the application of approved standard contractual clauses, additional contractual guarantees, and respect for the rights of data subjects residing in the European Union.
11. What are your rights?
Whatever relationship you choose to establish with Skyone, you are guaranteed all rights relating to your Personal Data as provided by law, including:
- Confirmation and Access Rights. You have the right to confirm what data about you is processed and to request access to what we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide this to you unless legal exceptions apply. To access your information, please send a description of what you wish to see and proof of your identity so that we can validate and return your information.
- Right to correct incomplete, inaccurate, or outdated data. You have the right to have your Personal Data corrected if it is incomplete, inaccurate, or outdated. The accuracy of your information is important to us, so we are working on ways to make it easier for you to review and correct the information we hold about you.
- Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data . You have the right to request that we anonymize, block, or delete unnecessary, excessive, or unlawfully processed data.
- Right to erasure and/or revocation of consent. You can ask us to delete your Personal Data processed with your consent. In some cases, it will be necessary to retain this information, such as to comply with a legal or regulatory obligation or to maintain anonymized data.
- Right to data portability. You can ask us to send your Personal Data to another service provider.
- Right to object . You have the right to object to the Processing where we use your personal information (1) based on legitimate interests, (2) for direct marketing or (3) for statistical/research purposes.
- Right to information from public and private entities. You have the right to obtain information about public and private entities with which we have shared your Data.
We may be required to request further information and/or proof of identity. We will strive to fully respond to all requests within the timeframe stipulated by applicable law. However, if we are unable to do so, we will contact you explaining any reasons for the delay.
Requests involving Personal Data and/or documents of other Data Subjects will not be fulfilled, except by means of a power of attorney, parental authority, or other circumstance that authorizes you to exercise the rights of another Data Subject.
It is important to note that, under specific circumstances, your request may not be fulfilled. In these cases, we will explain the reasons for the non-fulfillment.
12. Your choices and how to exercise your rights
If you do not wish to receive direct marketing communications and have any questions regarding the processing of your data, or wish to exercise your rights as a data subject, you can submit your request using the form available at: https://skyone.solutions/juridico-e-grc/requisicao-de-dados-lgpd-skyone/
We are committed to putting you in control of your Data at any time, as follows:
The form mentioned above;
Email: dpo@skyone.solutions ;
Our DPO: Renata Miziés de Barros – email: dpo@skyone.solutions
To do this, we ask that you identify yourself and indicate which right you wish to exercise. If you have any questions, please do not hesitate to contact us.
13. How do we keep your Personal Data secure?
- We have internal policies and procedures that determine how Personal Data should be handled by Skyone. These guidelines aim to ensure the proper and lawful processing of the Personal Data we hold.
- When you provide us with Personal Data, we take steps to ensure that appropriate technical and organizational controls are in place to protect it.
- Any sensitive personal data that is processed is protected with 128-bit SSL encryption software and stored using cybersecurity systems.
- Once we receive your information, we make every effort to ensure its security on our systems. It's important to note that where we have given (or where you have chosen) a password that allows access to certain parts of our Platform or Website, you are responsible for keeping that password confidential. We ask that you do not share your password with anyone.
In addition to these organizational and governance measures, we have adopted several other technical measures that ensure even greater security for your Personal Data, such as:
- We maintain processes for detecting, resolving, preventing, and reducing the occurrence of privacy, data protection, and cybersecurity incidents, providing increasingly reliable, available, and secure computing environments
- We adopt processes that include, but are not limited to: scanning for external and internal vulnerabilities; scanning the dark web; applying software patches; updating operating system versions; updating database versions; and scanning and mapping open ports
- Analysis and management routines associated with monitoring and alerting of security events using XDR ( Extended Detection and Response ) technology.
- Strict control of the processing of personal data, including access restriction and password-protected access;
- The existence of an information security program;
- Implementing segregation of access to Personal Data;
- Guidelines for password protection; and
- Access to services exclusively through secure networks.
In line with our commitment to privacy by , before implementing any high-risk data processing systems or processes, we conduct Data Protection Impact Assessments (DPIAs) to identify potential risks and define proportionate security and governance controls, as provided for in applicable legislation and ANPD guidelines.
14. How do we keep your Personal Data secure?
Our website may contain links to other websites operated by other organizations. This Notice applies only to Skyone Sites and the Personal Data we process, so we encourage you to read the privacy statements on other websites you visit. We cannot guarantee the accuracy and content of the privacy policies and practices of other websites, even if you access them using links from our Site.
Furthermore, if you are linked to our Site from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website; therefore, we recommend that you check their privacy policy.
15. Changes to this Notice
This Privacy Notice may be updated periodically. The current version is always the one published on this page.
Any changes will be posted on this Site, so we recommend that you check this page periodically to stay informed. If any significant changes are made, we will make that clear on this Site.
This Privacy Notice was last updated on January 15, 2026.
Society
- Associação Criança Brasil
supports projects focused on the comprehensive development of children in vulnerable situations, investing in initiatives that promote education, health, and well-being to ensure a future with more opportunities. - Friends of the Child Project (PAC):
We collaborate with PAC in actions aimed at strengthening family and community ties, offering support so that young people and children have access to a safe and welcoming environment for their growth. - Young
Apprentice Program at the company preferentially offers apprenticeship positions to young people enrolled in the Young Apprentice Program, prioritizing their inclusion in the job market. - Winter Clothing Drive:
We annually promote the collection of clothes and blankets to help vulnerable people during periods of low temperatures. Our solidarity network mobilizes employees and partners to keep those who need it most warm. - Builders Community:
An open learning and experience-sharing community focused on the practical use of AI and automation with Skyone Studio, bringing together professionals who share knowledge, real-world examples, and best practices in building intelligent agents.
ESG
- Reforestation and Biodiversity:
We believe that planting today guarantees a better future for the next generations. In 2022, we partnered with the Arvoredo Institute to promote the planting of native and fruit-bearing trees in strategic biomes, such as the Cerrado, directly contributing to the preservation of local fauna and flora and the recovery of degraded areas.
Sustainability and Technology:
We seek to integrate innovation and respect for the environment through sustainable technological solutions. We focus on the use of cloud computing and the optimization of data centers to reduce the carbon footprint and increase energy efficiency, combining digital advancement with the preservation of natural resources.
Skyone Code of Conduct.
Hello! This is our Code of Conduct. Use the side menu to navigate through the document.
Message from the Board of Directors
Skyone understands that the longevity of our business and the success of our results depend on how Skyowners guide their actions and attitudes, and on everyone who interacts with us, based on the values and ethical principles adopted by the company.
In this regard, Skyone expects and believes that all its employees, business partners, suppliers, and third parties will conduct themselves in accordance with the highest standards of personal and professional integrity.
This Code of Conduct has the primary objective of contributing to the building of a healthy, dignified and harmonious business environment, through a high level of trust, respect and transparency in interactions in any area of operation, promoting Skyone's unique vision that the ultimate success of our dealings with everything and everyone depends not only on what we do, but mainly on how we do it.
Field of Applications
This Code of Conduct is a guide for all Skyone employees (regardless of position), including business partners, franchisees, suppliers, and third parties who have a relationship with Skyone.
Since we deal with many different people and companies every day, it's difficult to predict every situation that might arise. Therefore, this document presents principles and best practices to promote a transparent, ethical, and mutually respectful environment.
Terms and Definitions
Public Official: Any person who performs a public function, whether temporary or permanent, paid or unpaid, by election, appointment, designation, or any other type of investiture or link with the public service.
Senior Management: These are the leaders of Skyone, including executives, shareholders, advisors, and directors.
Workplace harassment: These are abusive behaviors that can cause harm to a person's personality, dignity, or physical or psychological integrity, threaten their job, or damage the work environment. This can also occur in virtual environments, such as emails, video conferences, text messages, social networks, among others.
Sexual Harassment: Behaviors of a sexual nature, expressed physically, verbally, or through gestures, that are imposed on a person against their will, causing embarrassment and violating their sexual freedom.
Contributor(s): All Skyone employees, including those with permanent or temporary employment contracts, interns, and apprentices.
Corruption: Abuse of power to obtain personal benefits.
Family members: People who are part of the employee's family, including spouse (husband or wife), brothers or sisters, parents, relatives by marriage, children, partner or companion.
LGPD (General Data Protection Law): Law No. 13.709/2018 that establishes guidelines for the protection of personal data.
Anti-Corruption Law (Law 12.846/2013): Federal law that addresses the administrative and civil liability of companies for acts of corruption against the public administration.
Skyone's target audience: Customers, business partners, suppliers (service providers), and third parties.
Relatives: A person connected to another by the same blood tie, affinity, or adoption.
Purpose, Mission and Values
Our Purpose and Mission
Simplify reality. Impact tomorrow.
We work with what is invisible, yet essential to moving the world forward. And, if it depends on us, not even the sky is the limit for this movement, because we are already there. Skyone breathes innovation to deliver much more than just productivity.
With the integrating power of technology in our hands, we simplify today to impact tomorrow. In this way, we evolve businesses, solidify careers, and help build a more prosperous society.
We are tireless in perpetuating our competitive strength and leading a competent and ethical technological structure. And, of course, ensuring peace of mind for our clients and partners: that's how we earn their trust.
Our Vision
To positively impact the productivity of 1 million people by 2028.
The Skyone platform impacts the daily lives of thousands of people, anywhere in the world. This impact is reflected in hours of life saved for those who see time as their main ally in changing the world.
By increasing productivity, we eliminate growth barriers and deliver unlimited scale for any business.
Our Values
Trust
We build relationships of trust. We consider the impact of our words and actions. We care about the beginning, middle, and end of everything we do.
Expected Behaviors:
- We treat people the way they would like to be treated.
- Everyone can trust that we are doing our part for the safety of everyone, our business, and our customers.
- Everyone can trust that we are committed to the sustainability and long-term viability of the business.
Collaboration
We work to delight and simplify the daily lives of our customers. We contribute constructively to achieving shared goals.
Expected Behaviors:
- We understand the realities of each area of the company and contribute to ensuring that everyone achieves the best possible results.
- We show openness to doing things in different ways and we see multiple perspectives.
- We understand the other departments, including their services, results, and goals, and we involve them in decision-making that affects them.
- We clarify and align activities with peers and teams to ensure everyone's effectiveness.
- We use our resources to build a more just and equal society, beyond our own walls.
Sense of Prioritization
We are decisive and assess the impact of our priorities. We are agile in our decision-making.
Expected Behaviors:
- We balance the quality of our work with meeting deadlines.
- We respond positively to change, adopting and using new practices to achieve goals and solve problems.
- We are always striving to do our best to deliver with excellence and speed.
- The client's business is our business. We understand the reality of the business in order to prioritize actions.
Nonconformity
We are restless. We challenge ourselves to always do better.
Expected Behaviors:
- We practice "finishing," nothing stays unfinished in our hands. We deliver what we commit to with combined excellence. We adapt methods to achieve solutions and results in dynamic situations.
- We have identified areas for improvement in all situations.
- We are constantly developing ourselves to become better professionals.
- We share our learnings and best practices, contributing to everyone's development.
Tireless
We overcome the challenges to deliver what matters: impactful results.
Expected Behaviors:
- We are tireless in our pursuit of customer and partner satisfaction: we seek to improve and develop new ways to surprise them.
Guidelines
Legislation, Regulations and Internal Norms
Skyone values compliance with the laws and regulations of our country.
All employees need to know and respect our internal rules, and if they notice anything that violates these rules, it is important to report it to the Ethics Hotline.
Data and Information Protection
All employees have a responsibility to protect company information.
To help you with this task, we have internal rules on how to classify this information to ensure it is secure.
Each of us needs to take care of Skyone's important assets, such as computers, data, copyrights, and other information. To do this, we must follow the rules of the Information Security Policy and Standards, which are based on industry best practices.
It is very important to keep information confidential, ensure that it is not altered without authorization, and that it is always available when needed. Failure to do so constitutes a violation of the rules of this document and the Information Security Policy.
Personal Data Protection
Every employee is responsible not only for company information but also for the personal data they handle daily. Here are some important tips:
- Protect data against unauthorized access, alteration, destruction, or disclosure.
- Do not share personal data with unauthorized individuals.
- Use the resources that Skyone makes available to you only for operational purposes.
- Ensure that the systems, data, and information you manage are accessible and protected in accordance with security standards.
- Ensure the continuity of processing data essential to the business.
- Keep the resources provided to you in good working order, operating according to specifications.
- Follow Skyone's guidelines on where to store documents and information, especially in cloud storage services.
- Respect Skyone's guidelines and Code of Conduct to maintain information security while working remotely, avoiding the exposure of confidential information or personal data.
- Immediately report any questions or incidents to Skyone's Information Security and Governance, Risk and Compliance areas, in accordance with the Information Security Policy.
Assets and Property
At Skyone, each of us is responsible for taking care of the company's assets, client property, partner property, and other items we use at work. We should not use these things for our own benefit unless Skyone authorizes it.
Misappropriation/misuse
The misappropriation or misuse of these assets, including their copying, sale, or distribution to third parties, can lead to serious problems for the employee, such as labor or even criminal penalties.
Communication in case of loss, theft or misuse
If you notice or become aware of any loss, theft, or misuse of these items, you must immediately notify your manager and follow the established internal procedures for such cases. Upon termination of employment, you must return the cell phones, laptops, and other items provided by Skyone within the stipulated timeframe and in good condition.
Work Environment
At Skyone, we value a safe work environment that promotes freedom of expression, transparency, and respect for everyone's health and privacy.
We respect the personal lives of our employees, as we understand that it is a personal matter. However, it is important that the behavior of each individual does not harm the image or assets of Skyone.
Regardless of position, we expect everyone to be treated with courtesy and respect. We do not tolerate any type of discrimination, intimidation, or harassment, whether based on race, color, gender, sexual orientation, religion, origin, social class, age, physical or mental abilities, health conditions, marital status, or position.
Unacceptable Behaviors
- Discrimination for any reason whatsoever.
- Performing personal tasks during work hours.
- Unethical or illegal conduct.
- Violation of external laws and regulations.
- Hiring relatives without formal authorization from the Board of Directors and Human Resources department, or influencing their hiring without the knowledge of the person responsible for recruitment.
- Using company resources for personal purposes.
- Accepting corrupt practices (bribes, kickbacks, influence peddling for undue favors) and other illegal behaviors.
- Prioritization of personal interests or a specific area over those of Skyone.
- Consuming alcohol or illicit drugs on Skyone premises is prohibited. WARNING: Moderate alcohol consumption is permitted at Skyone social events, provided it does not affect behavior or violate the Code of Conduct during or outside of work hours.
- Carrying weapons inside Skyone is prohibited, except if required by your position.
- Share passwords and usernames for Skyone systems.
Expected Behaviors
- Acting with objectivity and clarity strengthens respect and trust in relationships.
- To encourage teamwork and focus on achieving the best results for Skyone.
- Respect the authorship and merit of all activities, ideas, and completed works.
- Being transparent in relationships and communicating any type of conflict of interest.
- Practice open dialogue and listen respectfully to other opinions.
Romantic Relationships
At Skyone, it's important that employees behave in a way that is compatible with the work environment, ensuring the smooth running of activities.
Therefore, we have established that no romantic relationship between employees should compromise their professional conduct.
Moral and Sexual Harassment
At Skyone, we do not tolerate any type of harassment, whether sexual, moral, or any other behavior that disrespects or intimidates colleagues, regardless of their position in the company.
In addition to Skyone's disciplinary measures, those who commit harassment may face legal action. The company complies with Law 14.457/2022, which combats sexual harassment and other forms of violence in the workplace.
Inclusive and diverse work environment
At Skyone, we value diversity and provide opportunities for all people, regardless of their cultural, ideological, or opinion differences, disabilities, gender, color, ethnicity, origin, political convictions, religious beliefs, generation, marital status, union membership, social class, sexual orientation, or level of education.
Our commitment is to create a welcoming and open-minded environment where everyone feels included.
Expected Behaviors:
- Respect the qualities, characteristics, and rights of all.
- Working together, accepting different ideas and having constructive conversations.
- To recruit, promote, and reward based on merit, providing equal opportunities for all.
- Promote diversity when building the team.
- Making decisions without prejudice or personal preferences.
- To create a work environment that reflects the appreciation of diversity.
- Report any discriminatory behavior you witness to the Ethics Hotline.
- Respect everyone's religious beliefs, as well as their right not to participate in religious demonstrations.
- Respect everyone's political opinions and refrain from engaging in political campaigning on Skyone premises.
Health and Safety
We believe that all employees have the right to a safe and healthy work environment. Therefore, we guarantee adequate working conditions, following hygiene and safety principles.
We constantly implement and evaluate actions to prevent and correct problems, including adjustments to the environment and ergonomics. Each of us must follow the rules and procedures to maintain our physical integrity and that of our colleagues, both inside and outside the company.
Unacceptable Behaviors:
- Working under the influence of alcohol, drugs, or other substances that impair the ability to perform tasks, putting one's own life and the lives of others at risk.
- To carry out activities or expose colleagues to situations that pose risks to their physical safety.
- Forcing colleagues to perform activities that jeopardize their health and safety due to the position they hold.
Expected Behaviors:
- Refuse to perform activities or participate in situations that pose risks to health and safety.
- Immediately report to the Human Resources department any situation that puts someone's safety at risk.
- Understand and follow legal requirements and internal health and safety standards.
- Perform activities only if you are qualified, authorized, have the appropriate tools, and are in good physical and mental condition.
- To contribute to a safe and healthy work environment, both physically and mentally.
- Comply with Skyone's rules regarding the completion of periodic occupational health examinations.
- Report any unsafe acts or conditions in the workplace, as well as work-related accidents and illnesses, to the Human Resources department.
Social and Environmental Commitment
At Skyone, we strive to minimize our impact on the environment.
We develop actions aimed at reducing the consumption of electricity, water, plastics, paper and other materials, in addition to encouraging recycling practices and respect for the environment.
Expected Behaviors:
- To develop and operate projects while minimizing impacts and avoiding environmental damage.
- To meet Skyone's goals for the sustainable consumption of resources such as water, electricity, and others.
Social media
Access
- Always maintain a stance aligned with our Values.
- Do not make any commitments on behalf of Skyone unless it is part of your responsibilities and you have the necessary approvals.
- Do not criticize colleagues or Skyone on social media or other channels that expose those involved. Direct criticisms or complaints to the company's official channels.
Improper disclosure
The employee may not speak on behalf of Skyone or promote causes on social media unless authorized by the Board of Directors or related to content disseminated by Skyone.
It is important to avoid sharing any posts that contain defamation, slander, libel, harassment, discrimination, or intolerant opinions of a political or religious nature, as this may harm your image and that of Skyone itself.
The misuse of the company's brand or name in embarrassing situations will subject offenders to disciplinary action or even dismissal.
On professional social networks, such as LinkedIn, by linking your profile to Skyone, you become a brand representative.
Therefore, when accepting connections that present themselves as Skyone collaborators, verify the authenticity of the information to avoid fraud.
Corporate Email
Corporate email is a work tool used primarily for exchanging professional messages.
You can use your work email for personal matters, but with moderation and common sense. Make sure the content does not include:
- Competitors.
- Promotions.
- Paid side activities.
- Anything inappropriate, such as erotic, pornographic, discriminatory, violent, political, or offensive content.
Mobile devices
It is important to avoid excessive or inappropriate use of personal mobile devices (such as cell phones or tablets) during work.
External Relationship
Customers
Our relationship with customers should be:
Unacceptable Behaviors:
- Disseminating and providing incorrect or inaccurate information.
- Neglecting to serve any customer, regardless of value or size.
- Using illicit means to acquire or retain clients, such as payments or any type of undue benefit, constitutes corruption, as it can be understood as bribery or kickbacks.
Expected Behaviors:
- We remain committed to ensuring customer satisfaction.
- Treat customers politely and efficiently, always providing accurate, clear, and transparent information.
- To fulfill the agreement with the client, preserving Skyone's credibility and image.
Suppliers and Business Partners
Our partners and suppliers must follow the same ethical principles as us, respecting Skyone's internal rules.
Suspicious actions, such as bribery or illegal favors that could harm Skyone, its employees, or society, are strictly prohibited by both Skyone and the Anti-Corruption Law, which regulates these practices.
Unacceptable Behaviors:
- Having relationships with suppliers that could create conflicts of interest.
- To offer, promise, induce, or give undue gifts or advantages to influence decisions in favor of Skyone or for one's own benefit.
Expected Behaviors:
- Treat our suppliers with respect and honesty.
- Hire partners who do not exploit child or slave labor.
- Do not accept services or materials that are not included in the purchase documents (contracts, for example), even if they seem advantageous to Skyone.
- To protect the information used in our partnerships with suppliers and clients (technical, commercial, strategic, financial, registration information, among others), whether it is ours or that of third parties.
- Do not do business with suppliers who do not follow the rules of our Code of Conduct.
Competitors
At Skyone, we value fair and honest competition, acting transparently and respecting all competition and antitrust laws. We follow the free enterprise system.
- Never speak incorrectly about our competitors' products or services.
- We should only use legal methods to obtain information about the competition.
- Respect the confidential information and intellectual property rights of our competitors and other companies.
- If you notice anything that could harm Skyone, report it impartially and based on concrete evidence to the Ethics Hotline.
Press and Corporate Information
At Skyone, we handle important information every day. Here are some key guidelines on how to handle press and corporate information:
- Only the Marketing team is authorized to speak to the press on behalf of Skyone, either in writing or verbally.
- Each employee is responsible for protecting the information they possess. If anything seems strange or inconsistent with Skyone's values, it is important to immediately inform your manager.
- Accounting records must be prepared and monitored by those directly responsible, following all laws, tax regulations, and company rules. The Controllership area is responsible for these tasks.
- If you have access to privileged information, it is essential to keep it confidential, even after leaving the company. Misuse of this information can result in serious labor and criminal consequences.
Trade unions
We recognize the category's union(s) and employers' unions as legitimate representatives of the parties involved in labor and union relations, respecting freedom of association and ongoing dialogue in building productive and harmonious labor relations.
Anti-corruption
Ethical principles: All Skyone business dealings must be conducted within the bounds of legality and corporate ethical principles. We do not tolerate any form of corruption, whether passive or active.
Transparency and Exemplary Conduct: Our relationship with external stakeholders, both from the public and private sectors, must be transparent and exemplary, preserving the reputation of Skyone and all those involved.
Offers and Payments: We do not authorize practices involving offering payments or benefits to government or private authorities to obtain commercial advantages. If you encounter such a situation, immediately inform the GRC or Legal department.
Legal Compliance: Although we follow Law 12.846/2013, which deals with acts of corruption within the public administration, we adopt practices to curb any corrupt behavior, regardless of the type of business.
Best Practices: We recommend that when holding meetings with public officials, you be accompanied by at least one other Skyone colleague, and that you do not accept or pay expenses during these meetings, communicating that this is in accordance with Skyone's Compliance rules.
Constant Updates: We are always up-to-date with the best market practices on this topic, including anti-corruption clauses in our contracts and dissemination of this Code, Policies and Standards through available internal channels.
Invitations, Giveaways, Gifts and Complimentary Items
At Skyone, we have clear guidelines regarding invitations, gifts, presents, and courtesies. If someone offers you a gift, you may only accept it if:
- The value of the gift must not exceed half the current minimum wage (small value).
- The gift must have the giver's mark (identification of the gift giver).
- It should not influence any business decision-making (anti-corruption).
- Respect a 12-month interval since the last gift/present given by the person (one gift per year).
Donations, sponsorship and charity
Any donation, sponsorship, or act of charity on behalf of Skyone must be approved by the relevant authorities.
This is done to assess the suitability, mission, and actions of the organizations that will receive the benefit, avoiding conflicts of interest and benefiting only entities that are in compliance with the law.
Clothing and Personal Presentation
The employees represent the image of Skyone.
Therefore, they must follow the guidelines of the Human Resources department regarding attire and personal presentation, maintaining an image consistent with the company's values.
Inventions, Discoveries and Improvements
Any invention, discovery, or improvement made by an employee during their employment will be the property of Skyone and may not be used for personal purposes or transferred to third parties.
Employees must classify information according to Skyone's Information Classification Standard.
The leak of information could cause reputational and financial damage to Skyone, as well as disciplinary and/or legal penalties.
Conflict of interest
A conflict of interest occurs when the personal interests of an employee or leader conflict with those of Skyone or its network of relationships.
These situations can affect the company's image, integrity, and reputation, as well as harm third parties and partners. Therefore, they must be reported quickly to the relevant departments and handled with transparency and efficiency.
Family members
If a family member of yours works for Skyone's suppliers, clients, or competitors, or holds significant financial stakes in those companies, be aware of a potential conflict of interest.
Before doing business with a company in which a family member is involved, it is necessary to inform the management of the situation for evaluation and approval, if required.
It is essential to document this approval, should it be granted.
Limitations
Any external activity must be completely separate from work at Skyone, whether it's a second job or freelance work. We should not use Skyone work time or involve other employees in external activities without specific and clear authorization from the manager.
As an employee, there are certain limitations you should observe to maintain a safe work environment and avoid problems for yourself and Skyone.
Prohibited situations, regardless of authorization:
- Filming or taking photos inside Skyone that could compromise its image in the market is prohibited.
- Entering Skyone with alcoholic beverages, a radio, entertainment material, and animals.
- Circulating raffles, lotteries, lists, petitions, distributing or selling invitations, tickets or similar items, or engaging in any type of commerce within Skyone is prohibited.
- Using the Skyone name for personal activities.
- Conducting political campaigns and/or posting notices about them within Skyone.
- Placing notices, invitations, posters of any kind inside Skyone.
- To share professional and confidential knowledge acquired at Skyone with other people.
- To promote external conferences, publish articles, or use other means of dissemination regarding matters related to Skyone.
Situations that must be authorized by the employee's supervisor:
- Bring visitors to Skyone.
- Using Skyone's tools, phones, materials, computers, and vehicles for personal purposes or for services unrelated to Skyone during working hours.
Duties and Responsibilities
Senior Management
Our senior management plays an important role in setting an example for all employees. They must promote, follow, and highlight the values and behaviors outlined in this Code of Conduct.
Leaders
Leaders have the responsibility to disseminate and ensure that everyone follows this Code of Conduct.
Collaborators
They must be familiar with and follow the rules of this Code of Conduct. To demonstrate this commitment, they must sign the Skyone Code of Conduct Commitment Agreement.
Handling Nonconformities and Penalties
Failure to comply with this Code of Conduct or other Skyone policies will have consequences. Depending on the severity of the situation and applicable laws, this may include:
Warnings
Suspensions
Layoffs
For Skyone employees, repeated non-compliance can result in dismissal for cause, based on insubordination.
It's important to know that Skyone can take immediate action, without waiting for repeat offenses to apply penalties, if the situation is serious enough.
Violations
Any violation of Skyone's Code of Conduct must be reported via the Ethics Channel, and the case will be reviewed by Skyone's Ethics Committee.
Validity
This Code of Conduct becomes effective from the day it is published in Skyone's media outlets and may be revised from time to time.
Final Considerations
If you have any questions, simply contact the Governance, Risk and Compliance Area by email:
Review Participants
Renata Miziés de Barros
Legal and Compliance Director – Finance
Approval and Change History
| Version | Date | Change | Responsible |
|---|---|---|---|
| 1.9 | 27/11/2018 | Finalization of the Initial Version | Lauro de Lauro |
| 2.0 | 13/12/2018 | Final Review for Release | Lauro de Lauro |
| 2.1 | 20/03/2019 | Final Version | Aila Braga |
| 3.0 | 23/05/2022 | Final Version | Lauro de Lauro |
| 3.1 | 22/03/2024 | Full review | Renata Miziés de Barros |
Complaints Portal
Confidential space for reporting misconduct. Access it via the link.
2nd Semester 2025
Law No. 14,611/2023 ( "Equal Pay Law ") aims to guarantee equal pay and remuneration criteria between women and men who perform work of equal value or carry out the same function.
The regulation of the Equal Pay Law (Decree No. 11,795/2023 and MTE Ordinance No. 3,714/2023) defines that the Salary Transparency and Remuneration Criteria Report – created by the Equal Pay Law and which must be published by private legal entities with 100 or more employees – will be prepared by the Ministry of Labor and Employment (MTE) itself, based on information sent by companies through eSocial and the Emprega Brasil Portal.
Based on this, on September 20, 2025, the MTE (Ministry of Labor and Employment) made available the reports for each company, based on a methodology developed by the MTE.
The analysis was conducted considering the overall picture of women and men in each company, without attention to particularities arising from hierarchical position, activity performed, effective position, performance, time in the company or in the function. Thus, the parameters used by the MTE (Brazilian Ministry of Labor and Employment) to prepare our report end up comparing Skyone employees from different positions who do not perform the same activities, such as, for example, [Director of Mergers and Acquisitions and Investor Relations, Product Manager, Technical Writer, QA Technical Lead].
The report also presents the ratio of Median Contractual Salary to Average Remuneration Effectively Paid for women and men, segregated by Major Occupation Group of the Brazilian Classification of Occupations (CBO), replicating the methodology used in the general comparison.
The division of Skyone employees by CBO's Major Occupational Groups also results in a comparison between employees in different hierarchical positions who perform distinct activities, such as, for example, [Sales Director and Systems Architecture Manager (both in the Executives and Managers Group), Technical Writer and Technical Development Lead (both in the Mid-Level Technicians Group), Financial Analyst and Audit and Process Analyst (both in the Administrative Services Workers Group), and Information Security Analyst and Implementation Specialist (both in the Operational Activities Workers Group)].
The methodology used by the Ministry of Labor and Employment (MTE), therefore, does not take into account the requirements of the Equal Pay Law and the Consolidation of Labor Laws (CLT), since it does not compare women and men who perform work of equal value or carry out the same function, nor does it observe the requirements set forth in article 461 of the CLT for equal pay.
Having made these considerations, and in compliance with the obligations established by the Equal Pay Law, we are making available, at the link below, the report from SKY.ONE TECNOLOGIA EM SOFTWARE SA, prepared by the Ministry of Labor and Employment (MTE).
Click to view the report.