P2B Annex (Business Users)

1. Scope & Services

1.1 What This Annex Covers

This P2B Annex applies to business users who use CUEBES to publish professional or organisational profiles, discover business opportunities, communicate with other users for commercial purposes, or access analytics about their content and engagement. It is the controlling document for issues governed by Regulation (EU) 2019/1150 (Platform-to-Business).

1.2 Platform Role

vaicat B.V. provides an online intermediation service. We are not an employer or recruiter, an agent or representative, a guarantor of any transaction, or a party to contracts between users.

2. Data Access

2.1 Your Data

As a business user you have access to data you have submitted to the platform, content you have published, analytics about your profile and content performance, and engagement metrics for your published material.

2.2 Other Users' Data

You do not have access to personal data of other users unless they have explicitly consented to share it with you, they have made it publicly available on their profile, or it is necessary for a specific permitted interaction (e.g. a candidate has opted into Talent Bank visibility for verified recruiters).

2.3 Platform Data Access

vaicat accesses business-user data solely for platform operations and service delivery, legal compliance and security, service improvement and analytics, and enforcement of terms and policies.

3. Ranking Parameters

3.1 Main Parameters

Search, recommendation, and ranking systems on CUEBES consider, in order of relative importance:

• Relevance — how well content matches the user's query, stated preferences, and engagement context
• Completeness — how complete and detailed the profile, listing, or content is
• Recency — how recently the content was published or substantively updated
• Engagement — interactions from real users (views, clicks, responses, save rate), with anti-manipulation filters
• Quality signals — moderation history of the publishing account, accuracy of disclosed information, salary transparency where applicable

A more detailed description of the main parameters and their relative importance is published in the AI Use & Transparency Policy §9 and on the Transparency Centre.

3.2 No Undisclosed Paid Ranking

We do not offer paid ranking advantages other than clearly-labelled "Sponsored" or "Promoted" placements, which are separated from organic results, subject to the same content policies, and disclosed under DSA Art. 26 (see Job Advertising Terms §4).

4. Changes & Notice

4.1 Advance Notice

Material changes to terms applicable to business users require at least 30 days advance notice before taking effect. This includes changes to:

• These terms or any incorporated annex
• Significant changes to ranking algorithms or visibility policies
• Data-access provisions for business users
• Fee structures (where any fees apply or are introduced)

4.2 How We Give Notice

We notify business users by email to the address on file and through an in-platform notification. Continued use after the effective date constitutes acceptance; you may close your business account before the effective date if you do not agree.

4.3 Exceptions

Shorter notice may apply where:

• Required by a legal or regulatory obligation
• Necessary to address an urgent security or integrity risk
• Necessary to prevent imminent harm to users or third parties

5. Account Restrictions

5.1 Statement of Reasons

If we restrict, suspend, or terminate your business account, we provide a written statement of reasons containing:

• The action taken and its effective date
• The factual circumstances leading to the decision
• The applicable rule(s) or provision(s) of the terms breached
• Our reasoning for the decision (including the role of any automated tooling)
• Information about available remedies, including the appeals process and access to mediation

This commitment applies regardless of whether the underlying conduct also triggers content-moderation actions under DSA Art. 17 — see the Moderation Policy.

5.2 Advance Notification

Where feasible, we provide advance notification before a restriction takes effect, except when:

• Immediate action is necessary for legal compliance
• There is risk of harm to users or third parties
• Prior notice would compromise an investigation

5.3 Reinstatement

Where the basis for a restriction has been corrected and is suitable for reinstatement, we will lift the restriction without undue delay.

6. Complaints Handling

6.1 Internal Complaint System

Business users may submit complaints regarding alleged non-compliance with P2B Regulation obligations, technical issues affecting the account or content, decisions about content or account restrictions, or ranking and visibility concerns. The full process is set out in the Complaints Handling Policy.

6.2 Response Timelines

We aim to acknowledge complaints within 5 business days and provide a substantive response within 14 business days; complex matters may require additional time, which we will communicate.

6.3 How to Submit

• Email support@vaicat.com or legal@vaicat.com
• Use the in-product support tools or /help/complaint

7. Mediation

7.1 Voluntary Mediation

For disputes that cannot be resolved through our internal complaint system, business users may access voluntary mediation through independent mediators specialised in P2B disputes.

7.2 Designated Mediators

We designate the following mediators for P2B disputes:

• Centre for Effective Dispute Resolution (CEDR) — www.cedr.com
• ADR Center (Rome) — specialised in P2B disputes

Either mediator may be selected by the business user. We commit to engaging in good faith in any mediation proceedings initiated through a designated mediator.

8. EUnify Institutions

8.1 Data Provided to Institutions

Educational institutions using EUnify (and operators of institution cubes) receive aggregated metrics only — never individual student or visitor data. Available signals include interest trends and search patterns (anonymised) and comparative performance against similar institutions.

8.2 What Institutions Do Not Receive

• Individual user identities or contact information
• Personal data of prospective students
• Specific user bookmark, comparison, or search-query data

8.3 Ranking Transparency

• EUnify uses rule-based logic, not machine learning
• No paid preferences influence ranking
• Ranking factors are documented in the AI Policy §9

9. Recruiters & Employers

9.1 Talent Bank Access

Verified recruiters and employers can access the Talent Bank to discover candidates who have opted in. Full terms in the Recruiter Terms:

• Business verification required before access (rolling out)
• Candidates control what information is visible
• Salary information that the candidate has not chosen to publish is never shared
• Strict data-protection obligations apply

9.2 Job Advertising

Employers can post job listings and sponsored placements. Full terms in the Job Advertising Terms:

• All listings must represent genuine, currently-open opportunities
• Sponsored listings clearly marked per DSA Art. 26
• Candidates must never be charged to apply
• Discriminatory listings are prohibited

9.3 Zero-Tolerance Areas

CUEBES enforces strict policies to protect candidates:

• Privacy violations: immediate account suspension or termination
• Data misuse: permanent ban and legal action
• Fraudulent listings: immediate removal and ban
• Charging candidates fees: immediate ban and regulatory referral

10. Termination Rights

10.1 Your Right to Terminate

You may close your business account at any time. However, prior contractual obligations remain enforceable, outstanding payments remain due, and content already shared with third parties may persist beyond closure.

10.2 Our Right to Terminate

We may terminate business accounts with the 30-day notice required under §4 of this annex, except in cases of serious or repeated violations, legal requirements, or risk of harm to users or the platform — in which case the statement-of-reasons obligations under §5 still apply.

Operator

• vaicat B.V.
• Noordeinde 99B, 2514 GD The Hague, Netherlands
• KvK (Dutch Trade Register): 89360672
• Email: legal@vaicat.com