Recruiter & Talent Bank Terms

These Recruiter Terms apply to anyone using the CUEBES Talent Bank or recruiter-only features as a representative of an employer, agency, or staffing firm. They sit alongside the Terms of Service and the Privacy Policy; in case of conflict on recruiter-specific matters, these terms control.

1. Eligibility & Verification

1.1 Who May Use Recruiter Features

CUEBES recruiter features are available exclusively to:

• Employers hiring for their own positions
• Recruitment agencies — licensed staffing and recruitment firms
• Executive search firms — retained-search consultancies
• HR / talent-acquisition departments within an organisation

1.2 Verification Requirements

During application you must provide:

• Business registration: a valid KvK, Companies House, or equivalent EU/EEA business registration number
• Legal-entity status: evidence that you represent a registered legal entity (or an in-house team within one)
• Contact verification: a business email domain and the identity of an authorised representative

Verification process: we are rolling out automated verification of business identifiers. Until that process is fully active, applications are reviewed against the information you provide on a self-attestation basis. Once automated verification is live, your application will not be approved until your identifier is verified against the relevant register. Submitting false or misleading information at any point is grounds for immediate termination.

1.3 Ongoing Verification

We may periodically re-verify your business status. Failure to respond to a verification request within 14 days may result in account suspension until the request is resolved.

2. Talent Bank Access

2.1 What You Can Access

Approved recruiters can view candidate profiles that users have explicitly opted into the Talent Bank. The fields available depend on the candidate's own privacy choices. CUEBES does not search for, ingest, or store profiles from external platforms.

2.2 What You Cannot Access

The following are never available to recruiters, regardless of subscription tier:

• Candidate salary or compensation expectations they have not chosen to publish
• Candidate browsing history, comparison preferences, or in-app search queries
• Private notes, drafts, or saved items
• End-to-end-encrypted message contents
• CathAI conversations (on-device or server-side)
• Special-category data under GDPR Art. 9 (we never store or expose this in the Talent Bank / recruitment context)

2.3 Candidate Control

Candidates retain full control over their Talent Bank participation. They may leave the Talent Bank at any time, hide their profile from specific recruiters, and block or report any recruiter.

3. Candidate Data Usage

3.1 Permitted Uses

You may use candidate data only for:

• Evaluating candidates for specific job opportunities
• Contacting candidates (through CUEBES) about relevant positions
• Maintaining records of recruitment interactions
• Complying with applicable legal obligations

3.2 Legal Basis & Controllership

Your processing relies on:

• Candidate consent for opted-in Talent Bank profiles — the only basis on which recruiters access candidate data

Every profile you can reach is one its owner has consented to place in the Talent Bank, so CUEBES is the controller for that data. When you contact a candidate, you become an independent controller for the purpose of that outreach and evaluation.

3.3 Retention

You must delete candidate data when:

• The candidate requests deletion (Art. 17 erasure or Art. 21 objection)
• The candidate leaves the Talent Bank or withdraws their consent
• The recruitment process for that candidate concludes
• 12 months have passed without active recruiter engagement

4. Privacy Obligations

4.1 GDPR Compliance

You warrant that you:

• Have a valid legal basis for processing candidate data
• Have appointed a Data Protection Officer where required
• Maintain appropriate technical and organisational security measures
• Will report data breaches to the relevant authority within 72 hours
• Will honour data-subject-rights requests within 30 days

4.2 Data Security Requirements

• Access controls limiting who can view candidate data
• Encryption for data at rest and in transit
• Audit logging of access
• Secure deletion procedures
• Staff training on data protection

4.3 Sub-Processing

If you share candidate data with third parties (clients, ATS providers, etc.) you must have a valid legal basis, an appropriate data-processing agreement, and you remain responsible for the third party's compliance. You must inform candidates where required.

4.4 International Transfers

Transfers of candidate data outside the EU/EEA require an adequacy decision, Standard Contractual Clauses, or another valid transfer mechanism under GDPR Chapter V.

5. Prohibited Practices

5.1 Strictly Prohibited

The following practices result in immediate termination and a permanent ban:

• Selling, sharing, or publishing candidate data to unauthorised parties
• Scraping or bulk-downloading candidate profiles
• Contacting candidates for non-recruitment purposes
• Misrepresenting job opportunities or employer identity
• Discriminatory screening based on protected characteristics
• Charging candidates fees of any kind
• Creating fake job listings to harvest candidate data
• Aggregating data to derive Art. 9 special-category attributes

5.2 Other Prohibited Activities

• Using candidate data for marketing unrelated services
• Retaining data beyond permitted periods
• Failing to honour candidate opt-out requests
• Circumventing platform communication systems
• Creating multiple accounts to evade restrictions
• Impersonating other recruiters or companies

6. Candidate Communication

6.1 Platform Communication First

Initial contact with candidates must occur through CUEBES. This ensures candidates can track all recruiter interactions, block unwanted contact, and we can monitor for policy violations.

6.2 Off-Platform Communication

You may communicate outside CUEBES only when the candidate has explicitly consented (with the consent documented in-platform), the communication is for a specific job opportunity, and you have provided your identity and company information.

6.3 Communication Standards

• Clearly identify yourself and your company
• Specify the job opportunity
• Provide opt-out instructions
• Be professional and respectful
• Do not be excessive in frequency

7. Fees & Billing

7.1 Current Pricing

Recruiter access on CUEBES is currently provided without subscription fees. We reserve the right to introduce paid tiers and other fees in the future; any new fees will be communicated with at least 30 days' notice and will not apply retroactively to existing engagements.

7.2 Payment Terms (when fees apply)

• Subscriptions, where introduced, will be billed in advance
• Fees will be non-refundable except as required by law (e.g. EU 14-day withdrawal rights for new consumers before service use begins)
• Material price changes will receive at least 30 days' notice

7.3 No Placement / Success Fees

CUEBES does not charge placement fees or success fees. Any employment relationships formed are between you and the candidate directly.

8. Enforcement & Termination

8.1 Monitoring

We monitor for policy violations through automated pattern detection, candidate reports, periodic audits, and access logging.

8.2 Violation Response

Actions are proportionate to severity:

• Minor (excessive messaging, incomplete profile): warning, temporary feature restriction
• Moderate (off-platform contact without consent, retention violation): suspension (typically 14–30 days), required remediation
• Severe (data selling, discrimination, fraud): immediate termination, permanent ban
• Critical (data breach, illegal activity): immediate ban, legal action, regulatory referral

Both temporary suspension and permanent termination are available; the system uses whichever is proportionate to the conduct, and may escalate from one to the other on repeat or aggravated violations.

8.3 Termination Effects

Upon termination Talent Bank access is immediately revoked, you must delete all candidate data obtained through the platform, outstanding fees remain due, and we may retain records of your account for legal purposes. Bans extend to affiliated companies and individuals where there is a clear factual basis.

8.4 Statement of Reasons & Appeals (P2B)

For business users, where we restrict, suspend, or terminate your account we will provide a written statement of reasons in line with our P2B Annex. You may appeal within 6 months by emailing legal@vaicat.com; appeals are reviewed by personnel not involved in the original decision.

9. Liability & Indemnification

9.1 Your Liability

You are solely responsible for your compliance with employment and data-protection laws, the accuracy of your job listings and company information, your communications with candidates, your employment decisions, and the security of any candidate data you access.

9.2 Indemnification

You agree to indemnify and hold harmless vaicat B.V., its officers, employees, and agents from any claims, damages, or expenses arising from your violation of these terms, your violation of applicable laws, your misuse of candidate data, disputes with candidates or regulators, or your employment practices and decisions.

9.3 Platform Limitations

vaicat B.V. is not a party to your employment contracts, not responsible for candidate qualifications or claims, not liable for hiring outcomes, and not a guarantor of candidate availability or interest.

9.4 Liability Cap

Our total liability to you is limited to the fees you paid in the 12 months preceding the claim (and thus may be zero where no fees apply), except for liability arising from our gross negligence or wilful misconduct, which cannot be excluded under applicable law.

10. Acceptance & Updates

You accept these terms when you submit a recruiter application. We log the acceptance with the version of these terms in effect at that time. If we materially change these terms after your approval, we will notify you in-platform and by email at least 30 days before the change takes effect (see also P2B Annex §3); your continued use after the effective date constitutes re-acceptance, and you may close your recruiter account before the effective date if you do not agree.

Recruiter Contact

• Verification: verification@vaicat.com
• Recruiter support: recruitment@vaicat.com
• Legal & compliance: legal@vaicat.com
• Report abuse / candidate concerns: abuse@vaicat.com

Operator

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