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Privacy Policy

Last updated: February 25, 2025

No FUD Games, Inc., DBA Aperturio ("NoFUD," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, and disclose Personal Information when you use our developer assessment and job-matching platform (the "Services") or otherwise interact with us. By accessing or using our Services, you confirm you've read and understand this Privacy Policy.

If you have any questions, please email us at privacy@nofudinc.com.

1. Scope and Applicability

This Privacy Policy applies to all individuals using our Services and websites, including:

  • Service Users ("Customers" or "Clients"): individuals or entities purchasing or evaluating our services.
  • Developer Job Applicants: candidates participating in NoFUD-led developer assessments seeking employment or contract opportunities through us or our customers.
  • Non-developer Job Applicants: applicants who participate in alternative recruitment processes (e.g., resume screening, traditional interviews) where developer assessment is not utilized.

Where you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, additional provisions in Section 7 (GDPR Notice for Service Users and Developer Job Applicants) and Section 8 (GDPR Notice for Non-developer Job Applicants) apply. We act as a data controller for non-developer job applicants and either a controller or processor (depending on the relationship) for developer job applicants and service users.

2. Personal Information We Collect

Personal Information is information that identifies, relates to, or can reasonably be linked with you. We collect Personal Information through:

  1. Information You Provide Directly:
    • Account registration data (e.g., name, email, password).
    • Profile information (e.g., work history, skills, certifications, location).
    • Resume / CV details, if uploaded.
    • Audio/visual data from interviews or coding assessments (e.g., webcam recordings).
    • Contact information when you correspond with us via email, phone, or contact forms.
  2. Information from Job Applications:
    • Resume content, references, links to professional profiles (LinkedIn, GitHub).
    • Demographic data (in some cases, if you voluntarily provide it).
  3. Information from Third-Party Providers:
    • Service customers (e.g., hiring companies) may share certain candidate-related data.
    • Single sign-on providers (e.g., Google, GitHub) that you use to authenticate.
  4. Information from Browsing the Services:
    • Device data (e.g., IP address, browser type, operating system).
    • Usage data (e.g., pages visited, time spent on pages).
    • Cookies and similar technologies (per our Cookies Policy).

3. How We Use Personal Information

We use Personal Information to:

  1. Provide the Services: e.g., facilitate developer assessments, match candidates with customer-employers, manage user accounts, schedule and conduct interviews, communicate with you, and otherwise operate our platform.
  2. Improve the Services: e.g., analyze usage patterns, troubleshoot issues, develop new features.
  3. Marketing & Promotional Activities: send updates, newsletters, and offers consistent with your preferences. You can opt out via the "unsubscribe" link or by emailing optout@NoFUD.com.
  4. Legal Obligations: comply with laws, court orders, or government requests; protect rights, safety, and security.
  5. Hiring Decisions (particularly relevant for non-developer applicants): review qualifications, schedule interviews, and consider applicants for available positions.

4. Disclosure of Personal Information

We may share Personal Information with:

  1. Service Providers: third-party vendors that perform services on our behalf (e.g., cloud hosting, analytics, payment processors). They are contractually bound to handle data securely and use it only for the specified purposes.
  2. Customers: when we facilitate a job match or developer assessment, we may share relevant candidate information with the customer/employer.
  3. Affiliates and Subsidiaries: within our corporate group, for consistent business operations.
  4. Business Transactions: if NoFUD is involved in a merger, acquisition, or sale of assets, your information may be transferred to the relevant parties (subject to confidentiality).
  5. Legal Compliance & Protection: to comply with applicable law, respond to lawful requests, or protect the rights, property, or safety of NoFUD, our users, or others.

We do not sell Personal Information for monetary consideration.

5. Data Retention

We retain Personal Information only as long as is necessary to:

  • Provide the Services you requested.
  • Comply with our legal obligations.
  • Resolve disputes and enforce our agreements.

Once these purposes no longer require your data, we either delete or anonymize it. For job applicants whose applications are not selected, we may retain certain data for an additional period in case future opportunities arise (in line with applicable law), or we may delete it upon request.

6. Security

We employ commercially reasonable physical, administrative, and technical safeguards to protect your Personal Information. However, no method of transmission or storage can be guaranteed 100% secure. If you suspect unauthorized access or misuse, please notify us immediately at privacy@nofudinc.com.

7. GDPR Notice for Service Users and Developer Job Applicants

If you reside in the EEA, UK, or Switzerland, the following applies in addition to the rest of this Privacy Policy:

7.1 Data Controller

For Service Users (e.g., customer-employers) and Developer Job Applicants who use our developer assessment platform, NoFUD typically acts as a joint controller alongside the customer for processing data related to candidate evaluations and job matching. However, for some processing activities (e.g., user-account creation), NoFUD acts as the sole controller. If you wish to exercise any data-subject right, you may contact us directly at privacy@nofudinc.com.

7.2 Legal Basis for Processing

We process Personal Information under one or more of the following legal bases:

  • Contractual Necessity: e.g., to provide or improve the Services you have requested.
  • Legitimate Interests: e.g., for business operations, fraud prevention, or to enhance user experience.
  • Compliance with Legal Obligations: e.g., to meet record-keeping or regulatory requirements.
  • Consent: e.g., for direct marketing, optional features, or specific data uses (where required).

7.3 Your Rights

Subject to certain conditions and exceptions, you have the following rights:

  1. Right to Access: Request a copy of the Personal Information we hold about you.
  2. Right to Rectification: Request correction of inaccurate or incomplete data.
  3. Right to Erasure ("right to be forgotten"): Request deletion of your Personal Information where there is no overriding legitimate ground for processing.
  4. Right to Restrict Processing: In certain situations, request that we limit our processing of your data.
  5. Right to Data Portability: Request your data in a structured, machine-readable format and have it transmitted to another controller, if applicable.
  6. Right to Object: Object to certain processing activities, including direct marketing or processing based on legitimate interests.
  7. Right to Withdraw Consent: Withdraw any previously granted consent at any time (this does not affect lawfulness of prior processing).
  8. Right to Lodge a Complaint: With the relevant supervisory authority in your country of residence, place of work, or where an alleged infringement occurred.

To exercise your rights, email privacy@nofudinc.com or use our Data Subject Access Request form, if provided.

7.4 Data Transfers Outside the EEA

We may transfer Personal Information to countries that do not provide an "adequate" level of protection, as recognized by the European Commission (or relevant authority). For these transfers, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the EU Commission, or other lawful transfer mechanisms.

7.5 Data Retention (EEA-Specific)

We will retain your Personal Information only for as long as necessary for the purposes outlined in this Privacy Policy or to comply with our legal obligations. Where data is no longer required, we ensure it is securely destroyed or anonymized.

8. GDPR Notice for Non-developer Job Applicants

If you are applying for a position via traditional means (e.g., resume submission, in-person interviews), and you reside in the EEA, UK, or Switzerland, the following supplemental notice applies:

8.1 Data Controller

NoFUD is the sole Data Controller for the Personal Information collected as part of your job application.

8.2 Categories of Data Collected

  • Identification Data (e.g., name, email, address, phone).
  • Professional Data (e.g., resume, references, work history).
  • Identification Documents (if relevant to the position or required by law).
  • Sensitive Data (e.g., diversity information, only if you voluntarily provide it).

8.3 Purposes and Legal Basis

We process your data for:

  • Recruitment and Hiring (legal basis: pre-contractual measures, your consent, and/or legitimate interests in hiring).
  • Compliance with Legal Obligations (e.g., labor regulations).
  • Internal Administration (e.g., evaluating candidate suitability, scheduling interviews).

8.4 Storage and Retention

We retain your data for the duration of the recruitment process. If you are not selected, we may keep your information for up to 24 months for future opportunities, unless you request earlier deletion or local law mandates a different retention period.

8.5 Data Subject Rights

Same data subject rights as outlined in Section 7.3 above, including the right to access, rectify, erase, restrict, object, port, withdraw consent, and lodge a complaint.

8.6 Data Sharing

We may share your application data with third-party service providers (e.g., background check vendors) under strict confidentiality, and only as necessary.

8.7 Security and International Transfers

We implement reasonable security measures and rely on SCCs or other lawful mechanisms for international transfers where applicable.

9. Children's Privacy

The Services are not directed to children under the age of 13 (or other minimum age in your jurisdiction). We do not knowingly collect Personal Information from children under that age. If we become aware that a child has provided us with Personal Information, we will delete it as soon as possible.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the revised version on our website and updating the "Last Updated" date. Your continued use of the Services after the changes take effect signifies acceptance of the revised Privacy Policy.

11. Contact Us

For questions, complaints, or to exercise your data protection rights, please contact us at:

No FUD Games, Inc., DBA Aperturio

If you reside in the EEA, UK, or Switzerland and are dissatisfied with our response, you may lodge a complaint with your local data protection authority.

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your Personal Information as described herein.