Privacy Policy

Update as of June 1, 2024

1. Definitions

NEAR One Limited, a Limited company (LTD), having its principal place of business at 101 New Cavendish Street, 1st Floor South, London, W1W 6XH, registered in United Kingdom under the number 1514531, and its affiliate companies (together “Near One” or “we” or “us”) is the responsible party for the processing of personal data collected through your use of our website https:/nearone.org/ (the “Website”) as per the applicable data protection laws;

User (“you”, “your”) – an individual over 18 years old who can be identified, directly or indirectly, in particular by reference to – an identifier such as a name, an identification number, location information, or an online identifier, or any relevant factors of the individual;

Privacy Policy – means the terms which set out how we will collect, store, use, and manage the information received from you via the Website;

Personal Data – any content that can be linked or identified, directly or indirectly, with the User. Personal Data may include your name, LinkedIn handle, or email address;

Third-Party – a legal entity or a physical person, service provider, public body, agency, or authority other than the User or Near One legally entitled to operate with Personal Data;

2. Introduction

We, at Near One, may collect, use, share and store the Personal Data of: 1. Users in relation to their visit to our Website: https://nearone.org/; 2. Other persons (potential employees and contractors) during the application and recruitment process.

This Privacy Policy applies to the Personal Data collected and processed by Near One during any interactions with the Website, including, but not limited to job applications via the Website, or job applications on other third-party services (collectively, “Interactions” or “Services”). Additionally, we may collect and process your Personal Data from the following publicly available sources, provided the collection of the data is necessary and relevant to the performance of the job which you apply for and provided we are allowed to do so by national laws: LinkedIn, Facebook, Twitter and other social media platforms/Google.

This Policy describes the categories of Personal Data that we collect, how we use your Personal Data, how we secure your Personal Data, when we may disclose your Personal Data to Third-Parties, and when we may transfer your Personal Data outside of your home jurisdiction. This Policy also describes your rights regarding the Personal Data that we hold about you including how you can access, correct, and request the erasure of your Personal Data.

We will only process your Personal Data in accordance with this Policy unless otherwise required by the applicable law. We take steps to ensure that the Personal Data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

The Personal Data that we collect, use, share, and store is mandatory in connection with our recruiting activities. Failure to provide or allow us to process mandatory Personal Data may affect our ability to accomplish the purposes stated in this Policy.

3. Personal Data Collected

We, at Near One, may collect certain Personal Data directly from you as well as from other available sources to the extent relevant and permitted by applicable local law. The categories of Personal Data that are typically collected and processed in the recruitment context are:

Data that is collected automatically

When you use our Website, we may also use cookies or similar technologies to collect extra data, including, * 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. * Information on how you interact with our Website. * Details of your computer, mobile, TV, tablet or other devices, and browsers used to access our content.

Data that is given to us by you.

When you submit a job application form, Near One, as the data controller, 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 One;
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 One;
From Third-Parties (through recruitment agencies and background verification agencies), which may also include public sources such as professional networking platforms.

4. Legal Grounds for Collecting Personal Data

We are required to warn you about the legal basis on which we treat your Personal Data. We shall treat your personal data legitimately, fairly, and transparently. We only gather and process information about you when we have a legal basis to do so. These legal grounds depend on your use of the Website, meaning we collect and use your information only when:

Performance of an agreement. It is required for the performance of an agreement to which you are a party or to take steps at your request prior to entering into such an agreement.
Legitimate interest. It serves a legitimate interest (that is not outweighed by your data protection interests), such as research and development, marketing and promotion of our activities, and protection of our legal rights and interests.
Consent. You give us permission to collect and use your Personal Data for a specific reason.
Legal obligation. Near One needs to process your Personal Data to comply with a legal obligation.

5. Purpose of Collecting Personal Data

Near One uses and collects your Personal Data for the following purposes:

User Assistance. Near One uses and collects your Personal Data in order to communicate with you for providing customer service and, if necessary, provide our feedback on job applications.
Website Development. In order to optimize your user experience, we may use your Personal Data to operate, maintain, and improve our Website.
Encouraging Legitimate Interests. Generally, We process Personal Data for the purposes of our legitimate interest, for example, for legal compliance purposes, regulatory, or other corporate governance requirements, security purposes, submitting reports as required by applicable laws or regulations, to comply with our legal obligations, and resolve any disputes that we may have, or to maintain the ongoing confidentiality, integrity, availability, and resilience of the Website and Interactions.
Identifying and evaluating job applicants. Identifying and evaluating your job application, including assessing skills, qualifications, and interests for the purposes of determining suitability for the position for which you have applied.
Verifying your information. Verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.
Communicating. Communicating with you about the recruitment process and your application.
Keeping records. Keeping records related to our hiring processes, for only as long as appropriate under the circumstances. In addition to using your Personal Data for the position for which you have applied, we may retain and use such data to inform you about and consider you for other positions that may be appropriate for you with your consent.
Marketing purposes. Sending you emails and messages about Company progress and development, products and services, and other similar content.
Securities. By collecting your Personal Data, we safeguard the Interactions from being abused from any spam attacks, or fraud. To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.

We will only process your Personal Data for the purposes we collected it for or for compatible purposes. If we need to process your Personal Data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We may process your Personal Data without your knowledge or consent only where required by applicable law or regulation.

We consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of this information, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements when determining the appropriate retention period for personal information.

6. Data Retention

Retention of data that is collected automatically

We will only store your Personal Data on our systems for the period necessary to serve the outlined purposes or obligations by the applicable law (for example for bookkeeping or mandatory archiving purposes). The Personal Data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected and the storage period prescribed by the applicable law expires.

Retention of data that is given to us by you

All your Personal Data that is given to us by you directly will be deleted: 1. In two years or sooner if Near One will not need this information to pursue any legitimate purpose; or 2. If you request the deletion of your Personal Data.

Under some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

If you are offered and accept employment with Near One, the Personal Data we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal data policies. If you do not become an employee, or, once you are no longer an employee of Near One, we will retain and securely destroy your Personal Data in accordance with the applicable laws and regulations.

7. Disclosure of Personal Data to Third-Parties

We use certain Third-Parties to facilitate the usage of our Website and meet legal and regulatory requirements relevant to Near One. Such Third-Parties may use your Personal Data in delivering their services to us or comply with regulatory requirements. The Third-Parties may be the following:

Database services. Near One may share the information collected about you with database services providers in order to properly and securely retain your Personal Data.
Service providers. Your Personal Data can be shared with service providers to help us analyze how you and other users perform Interactions in order to improve the Website’s functionality. We may employ Third-Party companies and individuals to facilitate the Interactions and assist us in analyzing how our Website is used.
Auditors and lawyers. Near One may transfer your Personal Data to auditors, accountants, and lawyers in order to complete financial, technical, and legal audits, as well as for other legal requirements.
Affiliates. Any of our group companies or affiliates.
Supervisory authorities. Near One may be required to share your Personal Data with supervisory authorities, law enforcement agencies, or government officials. We will only do this if we are required to do so by law or a formal request, if it is necessary to prevent physical injury or financial loss, or if we are required to report illegal activity.
Other cases of sharing your data. We may also disclose your Personal Data for the following additional purposes where permitted or required by applicable law:
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your Personal Data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum Personal Data necessary for the specific purpose and circumstances.
- To protect the rights and property of Near One in any claims and courts.
- During emergency situations or where necessary to protect the safety of persons.
- Where the Personal Data is publicly available.
- If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary, and we will anonymize the data where possible.
- For additional purposes with your consent where such consent is required by law.

In addition, Near One may also engage Third-Party service providers, such as recruitment agencies/search firms and providers of recruiting software and applicant tracking system, with whom Near One contracts as part of its normal business operations to carry out recruitment-related functions. Near One diligently selects such service providers and enters into written agreements with them ensuring that such providers (i) have adopted adequate data protection and security measures to safeguard your Personal Data; (ii) only use your data as instructed by Near One and for no other purposes; and (iii) store your Personal Data only within the terms of the agreement.

8. Securing your Personal Data

Near One implements a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. Near One uses appropriate physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and modification of personal information. Near One provides security such as data encryption and physical access controls to its servers. Your Personal Data is also protected through confidentiality undertakings entered into by all persons processing your Personal Data.

Near One is committed to doing its best effort in protecting the information We receive from You.

However, Near One will not be liable for disclosures of your Personal Data due to errors in transmission or unauthorized acts of Third-Parties. We have undertaken commercially reasonable efforts to prevent unauthorized Internet access to visitor data retained in our servers. However, due to the inherently open nature of the Internet, Near One cannot ensure or warrant the security of any information you provide us, and you do so at your own risk. Users must accept all risks associated with any data transmission, including the risk that their Personal Data may be intercepted in transit.

9. Rights of the Users

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).

10. Cross-border Personal Data Processing

The Personal Data that Near One collects may be stored, processed and transferred between any of the countries in which Near One operates to enable the use of the information in accordance with this Policy. You agree to such cross-border transfers of Personal Data.

11. Minors

Our Website and Interactions are not intended to appeal to persons under 18 years old. We will take appropriate steps to delete any unauthorized private information of a child that has been collected if it is discovered that such has been inadvertently collected. You understand that you must be at least 18 years old to perform any Interactions.

12. Third-Party Intervention

You are aware of the links contained on the Website which belong to Third Parties and not to Near One. We are not responsible or liable for Third-Party policies and terms of processing your Personal Data.

The Website may, from time to time, provide links or references to other websites. We have no control over such websites and are not responsible for the content of these websites. This Policy does not extend to your use of such websites. You are advised to read the privacy policies or statements of other websites prior to using them.

13. General

Transfer rights. You may not transfer any of your rights under this Policy to any other person. We may transfer our rights under this Policy where we reasonably believe your rights will not be affected.
Unenforceable Provisions. If any court or competent authority finds that any provision of this Policy (or part of any provision) is invalid, illegal, or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Policy will not be affected.
Right of remedy. Unless otherwise agreed, no delay, act, or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
How to complain. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is Information Commissioner's Office (https://ico.org.uk/).

14. Read this Privacy Policy

Before using our Website and performing any Interactions, Near One recommends reading this Policy carefully and completely in addition to, our Terms and Conditions, available on the Website. If you do not agree with this Policy, then you should refrain from performing any Interactions.

15. Amendments to the Privacy Policy

We reserve the right to amend or update this Privacy Policy at any time by posting the amended version on the Website including the effective date of the amended version. The current version of the Privacy Policy, as published on the Website, is applicable.

16. Contact

Near One is the Controller of data for the purposes of GDPR. For any queries, please contact us at the following email address: info@nearone.org.