Defuse Labs

Privacy Policy

PRIVACY POLICY

DEFUSE LABS LTD

Update as of April 1st, 2025

I. Definitions

Defuse Labs Limited, a Limited company (LTD), having its principal place of business at PO Box 199, Madison Building, Midtown, Queensway, Gibraltar GX11 1AA, registered in Gibraltar, and ( “Defuse Labs” or “we” or “us”) is the responsible party for the processing of personal data collected through your use of our website www.defuselabs.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 Defuse Labs legally entitled to operate with Personal Data;

Unless otherwise specified in this Privacy Policy, the terms used here have the same definitions as outlined in the UK GDPR (as defined in section 3(10), as supplemented by section 205(4), of the UK’s Data Protection Act 2018) and the EU GDPR (General Data Protection Regulation (EU) 2016/679)) ("GDPR").

II. Introduction

We, at Defuse Labs, may collect, use, share and store the Personal Data of:

  • Users in relation to their visit to our Website: www.defuselabs.org;

  • Other persons (potential employees and contractors) during the application and recruitment process.

This Privacy Policy applies to the Personal Data collected and processed by Defuse Labs 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.

III. Personal Data Collected

We, at Defuse Labs, 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:

  1. 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.

  1. Data that is given to us by you.

If you are a candidate for any role in Defuse Labs, please check our Candidate Privacy Policy.

IV. 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. Defuse needs to process your Personal Data to comply with a legal obligation.

V. Purpose of Collecting Personal Data

Defuse Labs uses and collects your Personal Data for the following purposes:

  • User Assistance. Defuse Labs 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.

VI. 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.

  1. 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:

  • In two years or sooner if Defuse Labs will not need this information to pursue any legitimate purpose; or

  • 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 Defuse Labs, 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 Defuse Labs, we will retain and securely destroy your Personal Data in accordance with the applicable laws and regulations.

VII. 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 Defuse Labs. 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. Defuse Labs 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. Defuse Labs 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, if applicable.

  • Supervisory authorities. Defuse Labs 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 Defuse Labs 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, Defuse Labs may also engage Third-Party service providers, such as recruitment agencies/search firms and providers of recruiting software and applicant tracking system, with whom Defuse Labs contracts as part of its normal business operations to carry out recruitment-related functions. Defuse Labs 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 Defuse Labs and for no other purposes; and

(iii) store your Personal Data only within the terms of the agreement.

VIII. Securing your Personal Data

Defuse Labs implements a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. Defuse Labs uses appropriate physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and modification of personal information. Defuse Labs 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.

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

However, Defuse Labs 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, Defuse Labs 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.

IX. 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).

X. Cross-border Personal Data Processing

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

Please note that we process personal data and hire service providers located in countries outside the EU/EEA. These third countries may not offer a level of data protection equivalent to that of the EU/EEA.

To ensure the security of your personal data during these transfers, we fulfill applicable legal obligations by adopting appropriate safeguards. These safeguards include:

  • Transfer of data to countries that have received an adequacy decision from the European Commission.

  • Implementation of standard contractual clauses provided by the European Commission, in accordance with Commission Implementing Decision (EU) 2021/914 of 4 June 2021, as well as supplementary measures for the transfer, where we consider that such measures are necessary to guarantee a level of protection essentially equivalent to that of the EU.

In the event of a transfer to a third country where adequacy decisions or appropriate safeguards are absent, it is conceivable that authorities in the third country, such as intelligence services, could access the transferred data. Consequently, the enforceability of your data subject rights may not be guaranteed.

We and/or our service providers transfer your personal data to and process it in countries outside the EU/EEA. These countries include:

  • United States of America;

  • United Kingdom.

In cases where the transfer to a third country is based on the use of standard contractual clauses provided by the European Commission, you have the right to request a copy of the clauses under which your personal data is transferred to a third country. However, the contract may be redacted in those parts that must remain confidential (i.e. other people's personal data).

XI. 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.

XII. Third-Party Intervention

You are aware of the links contained on the Website which belong to Third Parties and not to Defuse Labs. 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.

XIII. Candidate Privacy Policy Disclaimer

If you are accessing this Privacy Policy in the context of a recruitment process, please note the following:

All personal data submitted by you as part of a job application, whether through our website, will be processed exclusively for recruitment and selection purposes. By submitting such data, you acknowledge and consent to its use for assessing your qualifications, contacting you regarding relevant opportunities, and maintaining a candidate profile for potential future openings.

For more detailed information about how your data is processed in the context of recruitment, including your rights under applicable data protection laws, please refer to our Recruitment Privacy Notice, or contact us at operations@nearprime.com or [email protected].

You can check our Candidate Privacy Policy.

XIV. 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 [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.

XV. General

1. 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.

2. 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.

3. 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.

4. 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 the Information Commissioner's Office ([https://ico.org.uk/](https://ico.org.uk/)).

5. Right to File a Complaint with a Supervisory Authority: If you believe that the processing of your personal data violates data protection laws, you have the right to lodge a complaint with a data protection supervisory authority. In the EU and EEA, you can exercise this right by contacting a supervisory authority in your country of residence, workplace, or where you believe the infringement occurred. You can find a list of the relevant authorities here: [https://edpb.europa.eu/about-edpb/about-edpb/members](https://edpb.europa.eu/about-edpb/about-edpb/members).

XVI. Read this Privacy Policy

Before using our Website and performing any Interactions, Defuse Labs 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.

XVII. 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.

XVIII. Contact

Defuse Labs is the Controller of data for the purposes of GDPR. For any queries, please contact us at the following email address: XX

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