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Candidate Privacy Notice

  1. Introduction

This Candidate Privacy Notice ("Notice" or "Privacy Notice") explains how Jasnah Inc DBA Near AI ("we," "our,", “Near AI”, “Company” or "us") describes the ways that the Company recruit you as a candidate, collects and uses your personal data as a candidate (“You” or “Candidate”). We 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”). The Company cooperates 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 CPRA

  • The Gibraltar General Data Protection Regulation, enforced under the Gibraltar Data Protection Act 2004.

  • Other U.S. state privacy laws, where applicable

Depending on the context, Near Prime Limited and Near AI may act as independent or joint data controllers of your personal data.

  1. Who We Are

Near Prime Limited
Email: operations@nearprime.com

Jasnah Inc

Email: legal@near.ai

Near Prime may function as a candidate pool for Near AI. In certain cases, your personal data may be shared between these entities for recruitment evaluation and hiring purposes.

  1. Types of Data We Collect

When you submit a job application form for Near AI or Near Prime, as the data controller, it collects certain information that identifies you or could reasonably be used to identify you, and that is recorded in any form. Depending on the content provided, we may obtain the following Personal Data:

  • Name, gender, address, personal and/or business telephone number, personal and/or business email address, date of birth, and other contact details; competencies, skills (including cognitive abilities and language speaking abilities as a result of any assessments carried out during the recruitment process), experience and education, e.g. your CV or resume, previous employments, educational details and qualifications, third-party references;

  • Languages spoken, citizenship, and nationality to enable us to check your suitability for a specific role and working location;

  • Preferences, e.g. preferred country of employment, areas of interest as well as your preferred ways to be contacted by Near AIs;

  • Your online user identity, e.g. usernames and other such information used in connection with authenticating you to our online recruitment management system;

  • Technical Information: when you access our services online, our web servers automatically create records of your visit;

  • Information collected during interviews. As part of our interview process, we may maintain audio/video records of the interview (in case of telephone interviews or video-enabled interviews) as well as comments noted by our interviewers;

  • Information collected from online assessments proctoring: as part of the recruitment process, we may ask you to take certain tests which are necessary for assessing your suitability for a certain position. In such cases, we may also collect snapshots and/or audio/video recordings of you to ensure that the integrity of the tests is maintained. No biometric data will be collected from you.

  • Other information, such as information found from public sources as well as information related to reference checks, depending on the position you are applying for, and where necessary for the recruitment activities;

  • Additionally, once you have been shortlisted, we may collect additional information such as a copy of your Government ID, the expectation of compensation and remuneration details, information relating to your family members (for benefits administration), passport, visa, and work permit (in case of expatriate), background check reports including educational, employment and criminal checks, etc. as permitted under applicable laws. Also, in certain cases, we may collect your bank account details, details of the expenses incurred, and relevant bills to reimburse any expenses incurred by you during the interview process.

  • We collect this information in order to better understand the qualification and requirements of each person who submits a job application.

This information may be collected by us in a number of ways through multiple channels during the recruitment process and over time during our relationship with you:

  • Directly from you (when you apply online or via email);

  • Through referrals from your friends, a family of professional connects who work at/with Near AI;

From Third-Parties (through recruitment agencies and background verification agencies), which may also include public sources such as professional networking platforms.We may collect the following categories of data:

  • Full name, contact information (email, phone, address)

  • CV/resume, cover letter, and job application details

  • Employment and education history

  • References and background check information (where applicable)

  • Assessments or evaluations (e.g., technical, personality)

  • Publicly available professional profiles (e.g., LinkedIn)

  • Any other data voluntarily submitted by the candidate

  • Your IP address - a numerical code to identify your device address on the Internet, This can be used to identify the country, region or city where you are based.

We do not request or require special category (sensitive) personal data unless required by law or voluntarily provided.

We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists. We may use third-party tracking services and usage logs, to track and analyze data from Users of the Sites and Social Media and for purposes of security and fraud prevention. We may also use cookies and other tracking technologies to gather information regarding your use of the Sites and the information for which you searched and accessed.

  1. How We Use Your Data

Your personal data is processed 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

  • Compliance with legal or regulatory obligations.

  1. 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.

  1. Legal Bases for Processing

    1. 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)

    1. Under the CCPA and U.S. state privacy laws, we may:

  • Collect and use your personal data for disclosed business purposes

  • Not sell or share your personal information as defined under California law

  1. 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.

  1. 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 THE SITES AND/OR SERVICES AND/OR SOCIAL MEDIA, YOU ACKNOWLEDGE, AND CONSENT, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.

  1. 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)

  1. Your Rights

Your rights may vary, depending on the applicable law. These rights may not be available in certain jurisdictions and/or may be subject to certain derogations or limitations. You may have the following rights:

  • Access and receive a copy of your data

  • Correct inaccuracies

  • Request deletion (with exceptions)

  • Object or restrict processing

  • Data portability (UK/EU GDPR)

  • Opt-out of the sale or sharing of data (California)

To exercise these rights, contact: operations@nearprime.com or legal@near.ai.

  1. 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

  1. 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.

  1. Automated Decision-Making

We do not use automated decision-making that produces legal or similarly significant effects on candidates.

  1. Additional Notice to California Residents (“CCPA Notice”)

The California Consumer Privacy Act of 2018 (“CCPA”) requires certain businesses to provide a CCPA Notice to California residents to explain how we collect, use, and share their personal information, and the rights and choices we offer California residents regarding our handling of their information.

  • Privacy Practices. We do not “sell” personal information as defined under the CCPA. Please review the sections above for further details about the categories of parties with whom we share information.

  • Privacy Rights. The CCPA gives individuals the right to request information about how we have collected, used, and shared your personal information. It also gives you the right to request a copy of any information we may maintain about you. You may also ask us to delete any personal information that we may have received about you. Please note that the CCPA limits these rights, for example, by prohibiting us from providing certain sensitive information in response to access requests and limiting the circumstances under which we must comply with a deletion request. We will respond to requests for information, access, and deletion only to the extent we are able to associate, with a reasonable effort, the information we maintain with the identifying details you provide in your request. If we deny the request, we will communicate the decision to you. You are entitled to exercise the rights described above free from discrimination.

  • Submitting a Request. You can submit a request for information, access, or deletion to operations@nearprime.com or legal@near.ai.;

  • 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.

  1. Updates to This Policy

We may modify this Policy periodically. Updates will be posted with the "Last Updated" date. Substantive changes will be communicated directly to affected candidates where required.

  1. Contact

For questions or concerns about this policy or your personal data:

Email: operations@nearprime.com and legal@near.ai

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