Privacy Policy (NXD)

Date of Last Revision: 13/12/2023

Introduction:

Thank you for using Nexaminds’ websites and services that link to this Privacy Policy, including nexaminds.net (the “Sites”). Nexaminds, LLC. (“Nexaminds,” “we,” “us,” and/or “our”) operates these Sites to provide our users (“you” and “your”) with tools and information about Nexaminds and our services.

Nexaminds, a digital recruitment platform, recruits and connects talented individuals (“Talents”), with companies on the lookout for exceptional skills (“Clients” and/or “Client Companies”).

Nexaminds also operates tools across our Sites that support Talents and Clients, such as our virtual video interviews, virtual technical testing tools, and internal messaging tools. Our tools, sourcing and matching service, and other offerings are referred as the “Services” for this policy.

Nexaminds screens Talents with skills in areas such as software development, design, finance, product management, and project management to curate a proprietary network of highly skilled Talents (the “Pool”). We divide Talents in the Pool into Nexaminds’ employees (“Nexa Talents,” “Employees” and/or “Internal Talents") and Nexaminds Consultants, who are independent individuals operating with Nexaminds’ clients on a consulting basis (“Consultants” and/or “External Talents”).

Nexaminds values your privacy rights, and we take our responsibilities and obligations about your privacy rights seriously. We want you to know that Nexaminds is not in the business of selling your information. This privacy policy (“Privacy Policy”) is designed to help you understand how we collect, use, disclose, and safeguard your personal information. By using our platform, you agree to the terms outlined in this Privacy Policy.

Nexaminds adheres to relevant laws, particularly the legal framework established by the Organic Act No. 2004-63 of 27 July 2004 on the Protection of Personal Data. Collected data is strictly used for its intended purpose and may not be employed for other purposes without consent.

Scope:

This Privacy Policy explains how we collect, retain, and use information, including personal data (“Personal Data”), about Talents, Clients, potential Clients, Site visitors, blog readers, and job applicants, and others in accordance with applicable data protection laws and regulations as described below.

Information We Collect and How We Use It:

  1. 1.

    For Talents (including Applicants, Nexa Talents and Consultants):

    1. 1.1. Information That You Provide to Us

      To support your professional endeavors, Nexaminds LLC., located at Street Lac Tibériade, Lac 1, Tunis, Tunisia, collects certain personal data. The legal basis for this processing includes consent, the company's legitimate interests, and contract execution.

      Nexaminds aims to present professional opportunities and to recruit you, either within the company or on behalf of our clients.

      The processing of personal data is conducted lawfully, fairly, and transparently.

      Nexaminds strives to minimize the data collected, to keep it accurate and up to date, and to facilitate the rights of the persons concerned.

      We collect information from applicants and during our screening process we need to evaluate your qualifications such as your language skills, personality, domain-specific knowledge, competence, professionalism, and technical skills. If we admit you as a Nexa Talent or as an External Talent, we may also collect this information throughout your time in the Pool. We may ask you to provide information about yourself, which could include your:

      • - Name
      • - Contact information
      • - Birth Date
      • - Address
      • - Location.
      • - Personal Photograph
      • - Curriculum Vitae
      • - Language Skills
      • - Work experience
      • - Education
      • - References
      • - Social Media and Networks Links
    2. 1.2. Profile Creation

      If we select you to be a Nexa Talent or an External Talent, we may use some of your Personal Data to enable you to create a profile for us to display within the Services, which may be viewed by Clients seeking Talent. We may also display some of your information on public sections of nexaminds.net, marketing materials, and presentations to showcase your skill sets or to demonstrate the value in the Pool.

      Additionally, the data collected during the account creation process will be communicated to the following recipients:

      • - Nexaminds’ internal recruiters.
      • - Any Nexaminds operational entity whose purpose is to meet the purpose of processing your personal data.
      • - Our subcontractors and potential partners.
      • - Clients to whom we offer your profile outside of the platform context.
    3. 1.3. Client Feedback

      If you become a Talent, Clients you engage with may provide us information about your performance.

    4. 1.4. Information Obtained from Third Parties

      We may collect information, such as your name, contact information, address, work experience, and education from publicly available sources, third-party data providers, or services. This includes sources such as professional job boards or social media websites, like LinkedIn. We use this information to supplement the information that you provide us or to assess if you may be a good fit for the Pool.

    5. 1.5. Automatically Collected Data

      When you interact with Nexaminds through the Site or services, we may automatically collect certain information. Please read the “Site Visitors” section below for more information.

    6. 1.6. How We Use Your Data

      We use your Personal Data to process your request to become a Talent and administer our contracts with you and your engagements if you become a member of the Pool.

      We may use your contact details to tell you about job opportunities and other updates that we believe you will be interested in. If we do so, each marketing communication we send you will contain instructions permitting you to “opt out” of receiving future marketing communications. You cannot opt out of some administrative communications that are reasonably necessary to the Services, such as hiring request notifications, as those are not considered marketing communications.

      We also may use your Personal Data for certain business interests deemed legitimate under applicable law, including:

      • - To send you administrative information, for example, information regarding the Site and changes to our terms, conditions, and policies.
      • - To conduct analytics on how you use the Site and our Service for our internal purposes and to better understand your needs and interests to personalize your experience with our Services.
      • - To maintain our Services, including our standards of integrity and excellence in our Pool.
      • - To market our Services and showcase Talent to actual and potential Clients.
      • - To help prevent fraud, criminal activity, and misuses of our products or Services and to ensure the security of our IT systems, architecture, and networks.
      • - For legal reasons, including to comply with legal obligations and legal processes, such as our compliance with sanctions about specific regions or specifically designated individuals, respond to requests from public and governmental authorities, enforce our agreements, protect our operations, protect our rights, privacy, safety or property, and/or that of you or others, and allow us to pursue available remedies or limit the damages that we may sustain.

      If you ask us to delete your data and we are required to fulfill your request, we will keep basic data to identify you to prevent fraud or further unwanted processing.

      We may also ask for your consent to use your Personal Data for a purpose that is not listed on this Privacy Policy, and we will use your Personal Data for that purpose to the extent that you freely provide your informed consent.

      We may monitor, record, and transcribe audio or video calls with you during the application process or your time as a Talent. Consenting is voluntary, and you may withdraw your consent at any time. These recordings allow Nexaminds team members to review applications to the Pool, to better review your suitability for a Client engagement, or for internal quality assurance and training purposes. Additionally, we may provide your interviews with Clients for specific engagements to Client stakeholders to review the call.

      We may collect your voice, image, in-meeting messages, and any other Personal Data you choose to share during such calls. In addition, other participants in a video conference may be able to view your display name, email address and profile picture. Any third-party software we use for these audio or video calls may also collect and use your Personal Data. Please review the terms of any third-party site for their specific privacy practices.

    7. 1.7. How long we keep your data

      As an applicant, we retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected within the limits of the applicable laws.

      For security reasons, we begin the process of deleting your personal information after three (3) months from the day you delete your Nexaminds account. During this period, your account will not be visible by Clients on our services, however, your information will be retained.

      After two (2) years of inactivity of your account, we delete or anonymize your information, unless we must keep it:

      • - for accounting and record-keeping purposes,
      • - to comply with applicable law,
      • - to evidence our compliance with applicable law, or
      • - in case of an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved.

      We also may have to keep your information after two (2) years of inactivity if we have a valid reason to retain such information: For instance, our services may use machine learning that needs a longer information retention period to work properly. Our services may also need to keep the information to prevent fraud and other wrongdoings and to reinforce users' safety and security. For example, we may retain information of a user who was banned for unsafe behavior from opening a new account.

      The deletion of your account does not mean that your information will not still be viewable and/or accessed, in particular if you have shared it with others, or if others copied or stored it. We are not liable for such a situation.

      Please note that certain technical constraints may occur preventing the deletion of your information according to the time frame set in this privacy policy.

      If you become a Nexa Talent, your personal data will be kept for as long as you are employed with the company. If you are no longer an employee of the Company, your account will not be visible by Clients on our services, however, your information will be retained for a limited period not exceeding (5) five years.

  2. 2.

    Clients (including Prospective Clients):

    1. 2.1.Information That You Provide to Us

      We collect Personal Data from Clients and Prospective Clients (collectively “Clients”) when a Client visits our Sites, begins to use our Services and creates a company profile as well as through the hiring requests initiated by the Client to engage our Talent. This information may include, among other kinds of data:

      - Names

      - Contact information

      - Job titles

      - Payment and Billing information

      - Address

      - Location

      - Company information, including the type of talent(s) the Client is looking to engage and other information related to the Client’s field of operation, needs and projects they are hiring for.

      Nexaminds provides Talent and our internal team members the use of a nexaminds.net email address. Nexaminds stores and processes information sent to and from all nexaminds.net email addresses.

    2. 2.2.Information Obtained from Third Parties

      We may collect additional information about you and your company from publicly available or from third-party databases or services that provide information about business contacts and companies (including individuals’ names, job titles, business contact information, and company information).

    3. 2.3.Automatically Collected Data

      When you interact with Nexaminds through the Site or services, we may automatically collect certain information. Please read the “Site Visitors” section below for more information.

    4. 2.4.How We Use Your Data

      Nexaminds uses the Personal Data you provide consistent with this Privacy Policy. If you provide Personal Data for a certain reason, if we use the Personal Data, we will do so in connection with the reason for which you provided it. If you provide Personal Data in order to obtain access to the Services, we will use your Personal Data through our performance of our contract with you to provide you with access to such Services, maintain your account, contact you regarding your use of the Services and/or the Sites or to notify you of important changes to the Services and/or the Sites, and to monitor your use of such Services.

      We may use your contact details to tell you about Services, upcoming events, and other promotions that we believe you will be interested in. If we do so, each marketing communication we send you will contain instructions permitting you to “opt out” of receiving future marketing communications. You cannot opt out of some administrative communications that are reasonably necessary to the Services, such as billing or Service notifications, as those are not considered marketing communications.

      We may use your Personal Data for the certain business interests deemed legitimate under applicable law, including:

      - To send you administrative information, for example, information regarding the Site and changes to our terms, conditions, and policies.

      - To respond to your inquiries and fulfill your requests, such as to send you requested materials, newsletters and information and materials regarding our products and Services.

      - To conduct analytics on how you use the Site and our Services for our internal purposes, for example, for maintaining, benchmarking, and improving our offerings, identifying usage trends, and determining the effectiveness of our promotional campaigns, and to inform our marketing strategy and personalize our communications with you.

      - To supplement the information that we collected from you with information obtained from third parties (described above) to update, expand, and analyze our records, identify new Clients, and provide products and services that may be of interest to you.

      - To prevent fraud, criminal activity, and misuses of our products or services and to ensure the security of our IT systems, architecture, and networks.

      - For legal reasons, including to comply with legal obligations and legal process, respond to requests from public and government authorities including public and government authorities outside your country of residence, enforce our agreements with you, protect our operations, protect our rights, privacy, safety or property, and/or that of you or others, and allow us to pursue available remedies or limit the damages that we may sustain.

      We may also ask for your consent to use your Personal Data for a purpose that is not listed on this Privacy Policy, and we will use your Personal Data for that purpose to the extent that you freely provide your informed consent.

      We may monitor, record, and transcribe audio or video calls with you during your time as a Client. Consenting is voluntary, and you may withdraw it at any time. These actions allow multiple Nexaminds team members to review your requirements for sourcing or matching Talent, specifics about a particular engagement, or for internal quality assurance and training purposes. Additionally, your interviews with Talent for specific engagements may be recorded for internal purposes and, upon request, provided to you to review the call.

    5. 2.5.How long we keep your data

      We retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected within the limits of the applicable laws.

      For security reasons, we begin the process of deleting your personal information after three (3) months from the day you delete your Nexaminds account. During this period, your account will not be visible by Talents on our services, however, your information will be retained.

      After two (2) years of inactivity of your account, we delete or anonymize your information, unless we must keep it:

      - for accounting and record-keeping purposes,

      - to comply with applicable law,

      - to evidence our compliance with applicable law, or

      - in case of an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved.

      We also may have to keep your information after two (2) years of inactivity if we have a valid reason to retain such information: For instance, our services may use machine learning that needs a longer information retention period to work properly. Our services may also need to keep the information to prevent fraud and other wrongdoings and to reinforce users' safety and security. For example, we may retain information of a user who was banned for unsafe behavior from opening a new account.

      The deletion of your account does not mean that your information will not still be viewable and/or accessed, in particular if you have shared it with others, or if others copied or stored it. We are not liable for such a situation.

      Please note that certain technical constraints may occur preventing the deletion of your information according to the time frame set in this privacy policy.

      If you have previously hired a Nexa Talent and/or an External Talent, your company name might still be visible on the Talent's CV and professional background information, even if you have deleted your company account from the platform.

  3. 3.

    Site Visitors:

    When you interact with Nexaminds through the Site or the Services, we and service providers acting on our behalf will automatically collect information about you through cookies and other technologies. Please review the nexaminds.net Cookie Policy to learn more about how we use cookies and other technologies.

    As a Site Visitor, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address from which we understand the country you are connecting from at the time you visit the Site, browser type and settings, and the date and time of your request.

    We use this automatically collected data for our legitimate interests in maintaining the safe operation of our Site, maintaining our legal obligations and our legitimate interest in learning how Site visitors interact with our Site to improve your use of the Site.

  4. 4.

    Event Attendees:

    We may collect Personal Data from you when you attend one of our events, for instance at business conferences, hackathons, job fairs, etc. The data we collect includes information that you voluntarily give to us directly or through granting access to your Personal Data through the event, such as contact details on a business card or a curriculum vitae document. We will use this information to develop a potential business relationship with you including marketing our Services to you consistent with the purpose for which you gave the information.

    Where required by applicable law, we will ask your consent before or when sending you marketing information by email. When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you.

Security of Your Data:

Information system protection measures are implemented, adapted to the nature of the data processed and the company's activities.

Appropriate physical, logical and organizational security measures are in place to ensure the confidentiality of your data, including preventing unauthorized access.

Nexaminds also requires any subcontractor to provide appropriate safeguards to ensure the security, protection and confidentiality of personal data.

This requirement is achieved through the establishment of contracts, which include the obligation for the subcontractor to respect the privacy of Personal Data provided. These contracts provide for controls and audits, if necessary.

By accepting our Privacy Policy, you grant consent for the transfer of your personal data to countries within or outside the borders of Tunisia, where our clients' companies are situated. We implement specific measures, including contractual clauses, to regulate and ensure the secure handling of these data transfers.

Exclusions:

This Privacy Policy exclusively governs the collection of Personal Data through the Sites, Services, events, or third-party sources, as expressly detailed herein. It does not extend to information gathered during your employment with Nexaminds as a NexaTalent or within the context of your contractual relationship as a Client of Nexaminds.

Additionally, this Privacy Policy shall not apply to any unsolicited information you provide to Nexaminds through this Site or through any other means (without prejudice to your rights under the applicable law). This includes, but is not limited to, information posted to any public areas of the Sites, such as forums (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Nexaminds shall be free to reproduce, use, disclose, distribute, and exploit such Unsolicited Information without limitation or attribution.

Links to Other Websites

The Sites may contain links to other websites not operated or controlled by Nexaminds (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third-Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or review the Third-Party Sites. We suggest contacting those sites directly for information on their privacy practices and policies.

Your Rights:

According to different applicable laws, you enjoy certain rights when using our Sites. This includes:

  • Right to be informed: It is the right you have to be informed about the collection and use of your personal information.
  • Right of access, rectification and delete: You have the right to obtain a copy of your personal information and that is associated with your account directly within our Sites, to correct it if you believe it’s not accurate anymore or that we are not entitled anymore to use it, and to delete it in certain circumstances.
  • Right to object: in certain circumstances, you may object to the processing of your information.
  • Right to restrict processing: in limited circumstances, you have the right to request that processing be stopped but the data retained.
  • Right to delete your account: You can delete your account by using the corresponding functionality directly on the Sites. It's important to note that this feature is accessible to Clients, Applicants and Consultants. However, for NexaTalents, your account is inherently tied to your employment. In the case of termination, your account will be automatically deactivated as part of the employment cessation process.
  • Right to data portability: You can request a copy of your information in a machine-readable form that can be transferred to another provider.

To present any of your requests, you can contact us on the contact details below. For your protection and the protection of all of our users, we may request specific information from you for us to be able to confirm your identity before we can answer your requests.

Please note that we may not be able to answer certain of your requests for different reasons such as when it’s about an unlawful request or a request that may infringe our intellectual property or the privacy of other users. If your request will prevent us from providing our services, we will also not be able to answer it.

If you feel we have not resolved your concern, you have the right, according to certain jurisdictions, to make a complaint at any time to the appropriate data protection authority.

Changes to The Privacy Policy:

Nexaminds reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice, unless otherwise required by the applicable law. Please review this policy periodically, and especially before you provide any Personal Data. Your continued use of the Site after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy, without prejudice to your rights under the applicable law.

Contact

If you have any questions or concerns about this Privacy Policy, or if you need to exercise your rights related to your personal data, please contact us using the details below:

Email: contact@nexaminds.net

Mailing Address: Nexaminds, Les Berges du Lac , La Marsa, Tunis, 1053, Tunisia Street Lac Tibériade

For any data protection concerns, you also have the right to lodge a complaint with the appropriate data protection authority in your jurisdiction.