Candidate Privacy Notice
Jasnah, INC.
1. Introduction
This Candidate Privacy Notice (“Notice” or “Privacy Notice”) explains how Jasnah Inc DBA Near AI (“we,” “our,”, “Near AI”, or “us”) collects, uses, and processes your personal data in connection with your application for employment or engagement as a contractor (“You” or “Candidate”). We may work with data processors to whom we have instructed to collect, store and process personal information on our behalf for the purposes of providing our services, for example, Greenhouse, as a recruiting and applicant tracking platform (“Platform”) in order to handle your personal data as a candidate. It also describes the rights and options available to you with respect to your personal data. We may have an additional privacy notice(s) explaining our own specific privacy practices related to your personal data (“Company Notice”). We cooperate with Near Prime Limited for recruitment coordination and HR services.
FOR A VOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US.
This Notice applies to all candidates applying to roles at Near AI, whether directly or through recruitment platforms or agencies, and applies under:
- The United Kingdom General Data Protection Regulation (UK GDPR)
- The European Union General Data Protection Regulation (EU GDPR)
- The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA)
- Other U.S. state privacy laws, where applicable
Depending on the specific context, Near Prime Limited and Near AI may act as independent or joint data controllers with respect to your personal data.
2. Who We Are
Near Prime Limited
Email: [email protected]
Jasnah Inc
Email: [email protected]
Near Prime may function as a candidate pool for Near AI. In certain cases, your personal data may be shared between Near Prime and Near AI for the purposes of evaluating your qualifications and facilitating hiring decisions.
3. Types of Data We Collect
When you apply for a role with Near AI or Near Prime, we may collect and process certain personal data about you, acting as the data controller. This information may be provided directly by you or collected through our recruitment partners, platforms, or internal processes, and may include:
- Contact and Identification Details: Your name, gender, date of birth, address, email address, and phone numbers
- Professional Background: Your resume or CV, employment history, education, certifications, skills (including cognitive and language assessments), and any professional references.
- Citizenship and Work Authorization: Nationality, languages spoken, and any information needed to assess your eligibility for employment in a specific region.
- Application Preferences: Preferred job location, areas of interest, and how you wish to be contacted.
- Technical and Online Identifiers: Usernames or login details used to access our recruitment platform, as well as technical data like your IP address, browser type, device ID, and interaction logs from our website or online recruitment systems. This data may be collected automatically through cookies or similar technologies for performance, security, and fraud prevention purposes.
- Interview Process Data: Notes from interviews, and where applicable, audio or video recordings from remote or phone interviews.
- Assessment and Proctoring Data: If required, you may be asked to complete online assessments. In such cases, we may collect still images or video/audio recordings solely to ensure test integrity. We do not collect biometric data.
- Background and Reference Checks: Publicly available professional information (e.g., LinkedIn), reference feedback, and background screening results, where permitted and relevant to the role.
- Post-Shortlist Information: If you are shortlisted, we may collect additional information such as government-issued identification, compensation expectations, passport and visa data, work permit status, family information (for benefits), and in some cases, banking details or receipts to reimburse recruitment-related expenses.
We do not seek or require special category (sensitive) personal data unless legally required or voluntarily provided by you.
We may cross-reference the personal data you provide with information from other sources or with existing records to maintain accuracy and completeness. All data is collected and used solely to evaluate your qualifications and candidacy and to support a fair and secure recruitment process.
4. How We Use Your Data
We process your personal data for the following purposes:
- Evaluating your qualifications, experience, and suitability for a role
- Contacting you regarding recruitment status and next steps
- Conducting interviews, assessments, and reference checks
- Creating and managing a candidate talent pool for future opportunities
- Sharing your application with Near Prime or Near AI when appropriate
- Complying with legal or regulatory obligations.
5. What are the purposes of the collection of Your Data
We will use your personal data in accordance with our Company Notice (if any available to you), including to evaluate and consider you as a candidate for positions, in accordance with its processes and policies for evaluating employment candidates, to contact you for your candidacy status and interviews, to schedule meetings and interviews, amongst others.
5.1 Legal Bases for Processing
Under UK/EU GDPR, our processing is based on:
- Legitimate interests (e.g., identifying qualified talent)
- Contractual necessity (taking steps prior to entering into a contract)
- Legal obligations (e.g., anti-discrimination requirements)
- Consent, where required (e.g., in specific international transfers)
6. Sharing of Data
We may share personal data:
- Between Near Prime and Near AI when candidate suitability overlaps
- With third-party service providers (e.g., Greenhouse, assessment platforms)
- With legal advisors and authorities when required
All vendors are subject to contractual obligations to protect your personal data, including Data Processing Agreements (DPAs).
We share information with members of our group of companies, including where they act as our service provider or for their own purposes.In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Notice, Privacy Policy, and/or the Terms of Use of both websites, including investigation of potential violations thereof, and to defend against any claims or demands asserted against us by you or on your behalf; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (e) to protect the rights, property, or personal safety of the Company, its Users or the general public; (f) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of the Company, so long as such acquirer maintains the same privacy terms hereunder; or (g) pursuant to your explicit approval prior to the disclosure.
7. International Transfers
Your personal data may be transferred outside the European Economic Area (EEA), including to the United States. Where such transfers occur, we rely on:
- Standard Contractual Clauses (SCCs)
- UK International Data Transfer Addendum
- Vendor-specific compliance mechanisms (e.g., Greenhouse’s DPA)
BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH OUR WEBSITE AND/OR SERVICES AND/OR SOCIAL MEDIA, YOU ACKNOWLEDGE, AND CONSENT, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.
8. Retention
We will retain your data for no longer than 24 months after the end of the recruitment process unless:
- You are hired (in which case, the data may become part of your employee record)
- A longer retention period is required by law
- You exercise your right to deletion (subject to exemptions)
9. Your Rights (For Users in the EEA, UK, and other applicable Jurisdictions)
If you are located in the European Economic Area (EEA), the United Kingdom (UK), or another jurisdiction that grants similar privacy rights, you may have certain additional rights under applicable data protection laws, including the General Data Protection Regulation (GDPR). These may include:You have the following rights under the applicable data protection laws:
- Right to withdraw permission. You have the right to withdraw your permission if you have consented to the processing of your Personal Data. Please keep in mind that even if you choose to withdraw your consent, we may be allowed to continue processing your Personal Data to the extent required or permitted by law.
- Right to object to the processing of your personal data. You have the right to object to the processing of your Personal Data if the processing is carried out on a legal basis other than consent. You may object to such processing by providing a ground related to your particular situation to justify the objection.
- Right to gain access to your personal data. You have the opportunity to learn whether your Personal Data is processed, to receive disclosure about specific aspects of the processing, and to seek a copy of the data being processed.
- Right to verify and seek rectification. You have the right to verify the accuracy of your Personal Data and ask for it to be updated or corrected.
- Right to have your personal data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your Personal Data, unless the processing is justified by our legitimate interests, necessary to fulfill a legal obligation, for reasons of public interest, or to assert, exercise, or defend legal claims.
- Right to make a formal complaint. Users have the right to file a complaint with their competent data protection authority (depending on their residence and the applicable data protection legislation).
To exercise these rights, contact: [email protected]
10. Security
We take appropriate technical and organizational measures to protect your personal data, including:
- Secure data hosting (EU-based AWS datacenter)
- Role-based access controls
- Encrypted communications and storage
- Ongoing staff training and compliance checks
11. Background Checks
Where permitted by applicable law, we may conduct background checks (including verification of education, employment history, and criminal records) as part of our recruitment process. These checks will be proportionate to the role and conducted in accordance with local legal requirements. Candidates will be notified in advance and may be asked to provide specific consent where required.
12. Automated Decision-Making
We do not use automated decision-making that produces legal or similarly significant effects on candidates.
13. Additional Notice to California Residents (“CCPA Notice”)
This section supplements the information contained in our Privacy Policy and applies solely to individuals who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and other California privacy law.
- Privacy Practices. We do not “sell” personal information as defined under the CCPA/CPRA. Please review the sections above for further details about the categories of parties with whom we share information.
- Submitting a Request. You can submit a request for information, access, or deletion to [email protected].
- Identity Verification. The CCPA requires us to collect and verify the identity of any individual submitting a request to access or delete personal information before providing a substantive response.
- Authorized Agents. California residents can designate an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming their authority.
14. Updates to This Policy
We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page with a revised effective date. Your continued use of the Website after any changes become effective constitutes your acceptance of the revised Privacy Policy.
15. Contact
For questions or concerns about this policy or your personal data:
Email: legal@near.ai