Recruiter & Talent Bank Terms

1. Eligibility & Verification

1.1 Who May Use the Talent Bank

The Talent Bank is available exclusively to:

• Employers – Companies hiring for their own positions
• Recruitment Agencies – Licensed staffing and recruitment firms
• Executive Search Firms – Retained search consultancies
• HR Departments – In-house talent acquisition teams

1.2 Verification Requirements

Before accessing candidate profiles, you must complete our verification process:

Requirement	Documentation
Business Registration	Valid business registration number (KvK, Companies House, etc.)
Legal Entity	Proof of legal entity status in EU/EEA or equivalent jurisdiction
Contact Verification	Business email domain, phone verification
Identity Confirmation	Authorized representative identification

1.3 Ongoing Verification

We may periodically re-verify your business status. Failure to respond to verification requests within 14 days may result in account suspension.

2. Talent Bank Access

2.1 What You Can Access

Verified recruiters can view candidate profiles that users have explicitly opted into the Talent Bank. You will see:

• Professional summary and skills
• Work experience (as configured by the candidate)
• Location preferences and availability
• Industry and role interests
• Language proficiencies

2.2 What You Cannot Access

The following information is never available to recruiters:

• Salary information – Stored on-device only, never shared
• Private notes – Candidate's personal research and notes
• Browsing history – Cities or jobs they've viewed
• Comparison data – Their city comparison preferences
• CathAI conversations – Processed on-device, never stored

2.3 Candidate Control

Candidates maintain full control over their Talent Bank participation:

• They can leave the Talent Bank at any time
• They can hide their profile from specific recruiters
• They choose what information to share
• They can block or report recruiters

3. Candidate Data Usage

3.1 Permitted Uses

You may use candidate data only for:

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

3.2 Legal Basis

Your processing of candidate data relies on:

• Candidate consent – They opted into the Talent Bank
• Legitimate interest – Recruitment for positions they expressed interest in

You must document your legal basis and be prepared to demonstrate compliance.

3.3 Data Retention

You must delete candidate data when:

• The candidate requests deletion
• The candidate leaves the Talent Bank
• The recruitment process for that candidate concludes
• 12 months have passed without active engagement (maximum retention)

4. Privacy Obligations

4.1 GDPR Compliance

You warrant and represent that you:

• Have a valid legal basis for processing candidate data
• Have appointed a Data Protection Officer where required
• Maintain appropriate technical and organizational security measures
• Will report data breaches to authorities within 72 hours
• Will honor data subject rights requests within 30 days

4.2 Data Security Requirements

You must implement:

• Access controls limiting who can view candidate data
• Encryption for stored and transmitted data
• Audit logging of data access
• Secure deletion procedures
• Staff training on data protection

4.3 Sub-Processing

If you share candidate data with third parties (e.g., clients, ATS providers):

• You must have a valid legal basis
• You must have appropriate data processing agreements
• You remain responsible for their compliance
• You must inform candidates where required

4.4 International Transfers

Transfers of candidate data outside the EU/EEA require:

• Adequacy decision, or
• Standard Contractual Clauses, or
• Other valid transfer mechanism under GDPR Chapter V

5. Prohibited Practices

5.1 Strictly Prohibited

The following practices are strictly prohibited and will result in immediate termination:

Violation	Consequence
Selling or sharing candidate data with unauthorized parties	Immediate ban, legal action
Scraping or bulk downloading candidate profiles	Immediate ban, legal action
Contacting candidates for non-recruitment purposes	Immediate ban
Misrepresenting job opportunities or employer identity	Immediate ban
Discriminatory screening based on protected characteristics	Immediate ban, regulatory referral
Charging candidates fees for job applications	Immediate ban
Creating fake job listings to harvest candidate data	Immediate ban, legal action

5.2 Other Prohibited Activities

• Using candidate data for marketing unrelated services
• Retaining data beyond permitted periods
• Failing to honor 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

Initial contact with candidates must occur through the mEUvy platform. This ensures:

• Candidates can track all recruiter interactions
• Candidates can block unwanted contact
• We can monitor for policy violations
• A record exists for dispute resolution

6.2 Off-Platform Communication

You may communicate outside the platform only when:

• The candidate explicitly consents (documented in-platform)
• The communication is for a specific job opportunity
• You have provided your identity and company information

6.3 Communication Standards

All communications must:

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

7. Fees & Billing

7.1 Talent Bank Access

Talent Bank access is available through:

• Free tier: Limited profile views per month
• Professional: Enhanced access with additional features
• Enterprise: Custom solutions for large organizations

7.2 Payment Terms

• Subscriptions are billed in advance
• Fees are non-refundable except as required by law
• EU consumers have 14-day withdrawal rights before service use begins
• We provide 30 days notice for price changes

7.3 No Placement Fees

mEUvy does not charge placement fees or success fees. Talent Bank access is subscription-based only. Any employment relationships formed are between you and the candidate directly.

8. Enforcement & Termination

8.1 Monitoring

We actively monitor for policy violations through:

• Automated pattern detection
• Candidate reports and feedback
• Periodic audits of recruiter activity
• Data access logging

8.2 Violation Response

Severity	Examples	Action
Minor	Excessive messaging, incomplete profile	Warning, temporary restriction
Moderate	Off-platform contact without consent, data retention violation	Suspension (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

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
• We may retain records of your account for legal purposes
• Bans apply to affiliated companies and individuals

8.4 Appeals

You may appeal enforcement decisions within 14 days by contacting 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 job listings and company information
• Your communications with candidates
• Employment decisions and practices
• Data security for candidate information you access

9.2 Indemnification

You agree to indemnify and hold harmless vaicat, 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 regulatory authorities
• Your employment practices and decisions

9.3 Platform Limitations

vaicat is not:

• A party to employment contracts
• Responsible for candidate qualifications or claims
• Liable for hiring decisions or outcomes
• 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, except for liability arising from our gross negligence or willful misconduct.