This Privacy Policy is issued by Nefter LLC, a Delaware-based limited liability company, hereinafter referred to as “Nefter”, “we”, “us”, or “our”, in full compliance with the General Data Protection Regulation (EU Regulation 2016/679, “GDPR”), the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”), and all other applicable data protection laws. This document outlines the principles, procedures, and rights applicable to the collection, use, retention, disclosure, and safeguarding of personal data.

Scope and applicability. This policy applies to all individuals whose personal data is processed by Nefter, including website visitors, prospective clients, candidates, and users who engage with our services or platforms.

Definitions. For the purposes of this policy, “personal data” means any information relating to an identified or identifiable natural person. “Processing” refers to any operation performed on such data, whether automated or not, including collection, storage, use, or deletion. Nefter acts as a “controller,” determining the purposes and means of such processing.

Categories of data collected. Nefter collects personal information from clients and prospects such as full name, business email, phone number, company, title, location (city and country), and any message or project description voluntarily submitted. For candidates, we may collect the same as well as résumés, work experience, and skills. We also gather technical data automatically through tools like Google Analytics, including IP address, browser type, operating system, session duration, visited URLs, and referral sources.

Legal basis for processing. Under the GDPR, Nefter processes personal data based on: (a) consent, when a user voluntarily provides information via forms or communications; (b) legitimate interest, such as providing requested services, candidate evaluations, and business development, where not overridden by user rights; and (c) legal obligation, where necessary to comply with applicable regulations. Under the CCPA, our processing constitutes valid business purposes.

Purpose of data collection. We process personal data for the following reasons: to respond to inquiries, conduct professional evaluations, facilitate communication with leads or partners, manage service delivery, analyze usage of our website, and fulfill legal or contractual obligations. We do not collect or use personal data for purposes incompatible with these, unless otherwise authorized by the individual.

Use of cookies and analytics tools. Nefter uses cookies and other digital tools to improve site performance and understand visitor behavior. Specifically, we rely on Google Analytics to track aggregated activity, including time spent, pages visited, and general device/browser data. Use of the website implies consent to this, though users may disable cookies in their browser settings.

Data storage and retention. All personal data is stored on encrypted servers in the United States with strict access controls. Nefter implements technical and organizational safeguards to prevent unauthorized access, including encryption, limited access permissions, and monitoring systems. We retain personal data for no more than five (5) years unless required otherwise by law or unless a valid deletion request is submitted by the data subject.

Data sharing and transfers. Nefter does not sell or license personal information to any third party. Data may be shared only with trusted internal entities (affiliates or service providers) under confidentiality agreements. Where applicable, international transfers are governed by Standard Contractual Clauses or equivalent legal mechanisms to ensure protection.

User rights under GDPR and CCPA. Data subjects have the right to access the personal information we hold, request corrections, demand deletion (“right to be forgotten”), restrict or object to processing, request data portability, and withdraw consent where applicable. These rights may be exercised by contacting us at privacy@nefter.com. We commit to responding within the legally established time frames.

California-specific rights. Residents of California are entitled to specific disclosures under the CCPA, including the right to know which categories of data we collect and for what purposes, the right to request data deletion, and the assurance of non-discrimination for exercising privacy rights. Nefter does not sell personal data as defined by California law.

Minors. Nefter does not knowingly collect information from individuals under the age of 18. Our services are not directed to minors, and any data inadvertently collected from such individuals will be promptly deleted upon identification.

Policy updates. This Privacy Policy may be amended from time to time to reflect changes in our practices or in the applicable legal framework. Any such updates will be published on this page with a revised effective date. Continued use of our services following an update implies acceptance of the revised terms.

Contact information. For questions regarding this policy or to submit requests concerning your personal data, please write to us at: privacy@nefter.com.

Effective Date: June 12, 2025