Privacy Policy

1. Introduction

NextIn Limited ("we," "our," or "us") is committed to protecting your privacy. We are a company registered in the United Kingdom with company number 12345678 and registered address at 123 Tech Lane, London, EC1A 1AA.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our platform, including any related services, features, content, or applications (collectively referred to as the "Services").

As a UK-registered company working with candidates and companies in both the UK and US, we comply with applicable data protection laws including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and where applicable, the California Consumer Privacy Act (CCPA) and other US privacy regulations.

By accessing or using our Services, you consent to the collection, use, and storage of your information as described in this Privacy Policy. If you do not agree with our policies and practices, please do not use our Services.

2. Information We Collect

We collect information that you provide directly to us, information we obtain automatically when you use our Services, and information from third-party sources.

2.1 Information You Provide to Us

We collect information you provide when you register for an account, update your profile, apply for opportunities, communicate with us, or otherwise use our Services. This may include:

• Identity information (name, date of birth, gender, photograph)
• Contact information (email address, phone number, postal address)
• Professional information (resume/CV, work history, skills, education, certifications, LinkedIn profile)
• Career preferences (desired roles, location preferences, salary expectations, willingness to relocate)
• Communication data (messages with employers or our staff, feedback, survey responses)
• Account credentials (username, password)
• Financial information (for processing payments, such as bank account or payment card details)
• For employers: company information, job descriptions, hiring criteria, and organizational details

2.2 Information We Collect Automatically

When you access or use our Services, we may automatically collect certain information about your device and usage of our Services, including:

• Device information (IP address, browser type, operating system, device identifier)
• Usage data (pages visited, time spent on pages, links clicked, referring/exit pages)
• Log information (error reports, activity logs, timestamps)
• Location information (general location based on IP address)
• Cookies and similar tracking technologies (as described in our Cookie Policy)

2.3 Information from Third-Party Sources

We may receive information about you from third-party sources, such as:

• Professional networking platforms (with your permission)
• Employers or recruiters who use our platform
• Reference providers (when you apply for specific opportunities)
• Background check providers (with your consent and where permitted by law)
• Partners with whom we offer co-branded services or conduct joint marketing activities
• Publicly available sources (such as public social media profiles or professional websites)

3. How We Use Your Information

We use the information we collect for various purposes, including to:

• Provide, maintain, and improve our Services
• Create and manage your account
• Process your subscriptions and payments
• Match candidates with appropriate employment opportunities
• Enable communication between candidates and potential employers
• Provide agent representation services (for those who select this service)
• Communicate with you about our Services, updates, and responses to your requests
• Personalize and enhance your experience with our Services
• Send you marketing communications (with your consent where required by law)
• Monitor and analyze trends, usage, and activities in connection with our Services
• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Comply with legal obligations and enforce our terms, agreements, and policies
• Resolve disputes and troubleshoot problems

3.1 Legal Basis for Processing (UK and EU Users)

For users in the UK and EU, we process your personal information based on one or more of the following legal grounds:

• Contract: Processing is necessary to perform the contract we have with you (such as our Terms of Service) or to take steps at your request before entering into a contract.
• Consent: You have given us consent to process your personal information for specific purposes.
• Legitimate Interests: Processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms.
• Legal Obligation: Processing is necessary to comply with our legal obligations.

3.2 Automated Decision Making

We may use automated systems to help us match candidates with job opportunities. These systems analyze your profile information, work history, skills, and preferences to identify potential matches. You can request human review of any automated decisions by contacting us as described in the "Contact Us" section below.

4. Information Sharing and Disclosure

We may share your personal information in the following situations:

4.1 With Your Consent

We share your information with potential employers when you express interest in a specific opportunity or when an agent represents you as part of our services. We will never share your profile with employers without your explicit consent.

4.2 Service Providers

We may share your information with third-party vendors, consultants, and other service providers who perform services on our behalf, such as:

• Cloud storage and hosting providers
• Payment processors
• Email and communication service providers
• Customer support services
• Analytics providers
• Background check services (with your consent)

These service providers are contractually bound to use your personal information only as directed by us and in accordance with this Privacy Policy.

4.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency), to protect our rights or property, or in emergency situations.

4.4 Business Transfers

If we are involved in a merger, acquisition, financing, or sale of business assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your personal information.

4.5 Protection of Rights

We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, or as evidence in litigation.

5. International Transfers

NextIn is based in the United Kingdom but serves customers in both the UK and US. As a result, your information may be transferred to, stored, or processed in countries outside of your country of residence, including the United States.

When we transfer personal data from the UK or EU to countries that have not received an adequacy decision from the UK or European Commission, we implement appropriate safeguards to ensure your information remains protected according to this Privacy Policy and applicable law. These safeguards include:

• Standard Contractual Clauses approved by the UK or European Commission
• Binding corporate rules for transfers within our corporate group
• Appropriate data transfer agreements with our service providers
• Obtaining your explicit consent to the proposed transfer (where appropriate)

6. Data Security

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. These measures include:

• Encryption of sensitive data in transit and at rest
• Regular security assessments and penetration testing
• Access controls and authentication requirements
• Regular monitoring for suspicious activities
• Employee training on security and privacy practices
• Secure data backup procedures
• Incident response plans

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. We regularly review and update our security measures to ensure they remain appropriate to protect your data.

7. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information. These may include:

7.1 UK and EU Residents

If you are a resident of the UK or EU, under the UK GDPR or EU GDPR, you have the right to:

• Access: Request information about whether we process your personal data, receive copies of such data, and learn about the processing.
• Rectification: Request that we correct inaccurate or incomplete personal data about you.
• Erasure: Request the deletion of your personal data in certain circumstances.
• Restriction: Request that we restrict the processing of your personal data in certain circumstances.
• Data Portability: Request to receive your personal data in a structured, commonly used, and machine-readable format.
• Objection: Object to our processing of your personal data on grounds related to your particular situation, and object to the processing of your data for direct marketing purposes.
• Withdraw Consent: Withdraw your consent at any time if we process your personal data based on consent.
• Lodge a Complaint: Lodge a complaint with a supervisory authority, such as the UK Information Commissioner's Office (ICO).

7.2 California Residents

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

• Right to Know: You have the right to request that we disclose what personal information we collect, use, disclose, and sell.
• Right to Delete: You have the right to request deletion of personal information we collect and maintain about you, subject to certain exceptions.
• Right to Correct: You have the right to request correction of inaccurate personal information.
• Right to Opt-Out: You have the right to opt-out of the sale or sharing of your personal information.
• Right to Limit Use: You have the right to limit the use and disclosure of sensitive personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

7.3 How to Exercise Your Rights

To exercise any of these rights, please contact us using the details provided in the "Contact Us" section. We will respond to your request within the timeframe required by applicable law. We may ask you to verify your identity before fulfilling your request.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and use personal information about you. Cookies are small data files that are placed on your device when you visit a website. They are widely used to make websites work or work more efficiently, as well as to provide information to the website's owners.

8.1 Types of Cookies We Use

• Essential Cookies: These are necessary for the website to function properly and cannot be switched off in our systems. They are usually set in response to actions made by you, such as setting your privacy preferences, logging in, or filling in forms.
• Analytical/Performance Cookies: These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.
• Functionality Cookies: These enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages.
• Targeting Cookies: These may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.

8.2 Your Cookie Choices

Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may impact your overall user experience. For more information about how to manage cookies, please visit:

• www.aboutcookies.org
• www.allaboutcookies.org

You can learn more about how we use cookies and similar technologies in our Cookie Policy.

9. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide Services to you
• Whether there is a legal obligation to which we are subject
• Whether retention is advisable in light of our legal position (such as for statutes of limitations, litigation, or regulatory investigations)

For candidates, we typically retain your profile information for:

• Active accounts: For as long as your account remains active
• Inactive accounts: For 24 months after your last activity
• Job applications: For 6 months after the position is filled

For employers, we typically retain your information for the duration of our contractual relationship and for a reasonable period thereafter.

When we no longer need to use your personal information, we will either delete it or anonymize it in a secure manner that ensures the data cannot be reconstructed or read.

10. Children's Privacy

Our Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to delete that information as soon as possible.

If you believe that we might have any information from or about a child under 18, please contact us using the details provided in the "Contact Us" section.

11. Policy Changes

We may update this Privacy Policy from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons. The revised policy will be effective immediately upon posting to our website.

We will notify you of any material changes by:

• Posting a notice on our website
• Sending an email to the email address associated with your account
• Displaying a prominent announcement when you log into our Services

We encourage you to review this Privacy Policy periodically to stay informed about our data practices. Your continued use of our Services after any changes to this Privacy Policy constitutes your acceptance of the revised policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

For UK residents: You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

For California residents: To exercise your rights under the CCPA/CPRA, you can contact us at privacy@nextin.com or call our toll-free number at 1-800-XXX-XXXX.