PRIVACY POLICY

BeeXpro HR Recruitment Portal & Talent Pool <https://hr.beexpro.com>

Last updated: 23 January 2026

1. Introduction

This Privacy Policy explains how Beexpro Consulting Ltd (“BeeXpro”, “we”, “us”, “our”) collects, uses, and protects personal data when operating the BeeXpro HR recruitment platform (“Platform”). This Policy is issued in accordance with: - Regulation (EU) 2016/679 (GDPR) - UK GDPR - Swiss Federal Act on Data Protection (FADP)

It applies to: - Recruiter companies and their authorized users, and - Individual applicants accessing the Platform via application links or QR codes.

2. Data Controller & Contact Details

Legal entity: Beexpro Consulting Ltd Registered country: Cyprus (European Union) Contact & GDPR requests: info@beexpro.com You have the right to lodge a complaint with your local data protection authority.

3. Roles Under Data Protection Law

Depending on the context of processing: - Recruiter companies act as Data Controllers for applicant data - BeeXpro acts as a Data Processor on behalf of recruiter companies - For its own operational, security, and billing data, BeeXpro acts as Data Controller

4. Categories of Personal Data Processed

4.1 Applicant Data

• Name and contact details
• CVs, résumés, and cover letters
• Employment and education history
• Skills, qualifications, and languages
• Logic test and skill test results
• AI-generated scores, summaries, and recommendations
• AI avatar interview recordings, transcripts, or summaries (if enabled)
• Consent records
• Communication records

4.2 Recruiter / Company User Data

• Name, business email, role
• Company details
• Login and authentication data (including 2FA logs)
• Usage logs and audit trails
• Subscription and billing information (excluding payment credentials)

4.3 Technical & Security Data

• IP address
• Device and browser information
• Log files and security events

5. Purposes and Legal Bases of Processing

BeeXpro does not perform automated decision-making within the meaning of Article 22 GDPR.

6. AI Processing and Third-Party AI Providers

6.1 Use of Artificial Intelligence

BeeXpro HR uses artificial intelligence–based tools (“BXP Engine”) to support recruitment-related activities, including: - CV parsing and structured data extraction - Generation of position-specific questionnaires, logic tests, and skill tests - Candidate scoring, explanations, and matching insights - Optional AI-assisted avatar interviews

AI tools are used solely to support recruiters and do not replace human judgment.

6.2 Use of Third-Party AI APIs

To deliver certain AI-supported functionalities, BeeXpro uses third-party AI service providers, including large language models accessed via secure API connections (such as OpenAI API). Where such providers are used: - They act strictly as data processors - Personal data is processed only on BeeXpro’s documented instructions - Personal data is used exclusively to provide AI-supported recruitment services - Personal data is not used to train, retrain, or improve public or general-purpose AI models - BeeXpro does not use consumer-facing AI services (e.g. public ChatGPT interfaces)

6.3 Human Oversight and No Automated Decisions

• AI outputs are probabilistic and advisory
• Outputs must be reviewed by human recruiters
• Final hiring decisions are always made by humans

6.4 LinkedIn Integration

Our app integrates with LinkedIn to allow users to publish content to their LinkedIn profiles. When you connect your LinkedIn account, we may receive basic profile information and authorization to post content on your behalf, as explicitly initiated by you within the app.

We do not publish content without your action or consent. Any content shared to LinkedIn is created or approved by you prior to posting. We use this access solely to provide the posting functionality and do not use it for any other purpose.

LinkedIn’s use of your information is governed by its Privacy Policy: https://www.linkedin.com/legal/privacy-policy

7. Applicant Consents

Applicants must provide explicit consent for: - Processing personal data for recruitment purposes - Use of AI-supported recruitment tools

Optional consents include: - Inclusion in a talent pool / CV promotion - Training and upskilling communication - Marketing communication (always separate and optional)

Applicants may withdraw consent at any time.

8. Talent Pool & CV Promotion

Where applicants opt in: - Their profiles may be retained for future recruitment opportunities - Processing is limited to talent matching and recruitment purposes - Withdrawal of consent results in deletion without affecting prior applications

9. Training & Upskilling Communication (Current State)

At present: - BeeXpro does not operate an automated training platform - With explicit consent, BeeXpro may contact applicants manually by email to provide: - Skill gap insights - Market feedback - Training or upskilling recommendations

Any future training platform will require updated notice and consent where required by law.

10. Data Retention

BeeXpro applies strict retention limits: - Recruitment applicants: - Up to 12 months after the recruitment process ends - Talent pool / CV promotion: - Up to 24 months (explicit consent required) - Training communication data: - Within the same 24-month consent period - Recruiter / company data: - Contract duration plus 24 months

Encrypted backups may retain data temporarily under strict access controls.

11. IT Infrastructure, Hosting & Security

Hosting & Operations

• Platform hosted on VPS infrastructure located in Cyprus (EU)
• Application configuration and operations managed by Beexpro Consulting Ltd (Cyprus)

Backend & Databases

• Backend services provided by Supabase
• Primary databases hosted in Ireland (EU)

Payments

• Subscription agreements and payments handled through Stripe
• BeeXpro does not store payment credentials

Network Security

• Cloudflare used for DDoS protection, traffic filtering, and content delivery
• Limited technical data processed for security purposes only

Authentication

• Two-factor authentication (2FA) mandatory for recruiter accounts
• Role-based access controls enforced

12. Sub-Processors

All sub-processors are bound by GDPR-compliant Data Processing Agreements.

13. International Data Transfers

Where data is transferred outside the EU, UK, or Switzerland, BeeXpro ensures appropriate safeguards, including: - EU Standard Contractual Clauses (SCCs) - Adequacy decisions where applicable

14. Security Measures

BeeXpro implements appropriate technical and organizational measures, including: - Encryption in transit and at rest where appropriate - Two-factor authentication - Access control and audit logging - Incident response and breach notification procedures

15. Data Subject Rights

You have the right to: - Access your personal data - Rectify inaccurate data - Request erasure - Restrict or object to processing - Data portability - Withdraw consent at any time

Requests can be sent to info@beexpro.com.

16. Children and Age Limits

The Platform is not intended for individuals under 16 years of age. Applicants must confirm they are at least 16 years old.

17. Cookies

The Platform uses essential cookies required for functionality and security. Additional cookie information may be provided separately if applicable.

18. Changes to This Policy

BeeXpro may update this Privacy Policy from time to time. Updates will be published with a revised “Last updated” date.

19. Talent Pool Data

If you choose to join the Talent Pool as a job seeker, we process the profile data you provide (desired roles, salary expectations, location, CV, skills, languages), your questionnaire and skill-test responses, and — if you complete it — your AI interview transcript and the resulting AI-generated evaluation.

• Purpose & legal basis: to build your talent-pool profile and match you with hiring companies, based on your explicit consent (Art. 6(1)(a) GDPR). Automated assessment is used to help companies evaluate fit; the final decision is always taken by a human at the hiring company.
• Recipients: while your profile is set to discoverable, it is visible to third-party companies holding an active Talent Pool subscription, who may contact you. We log which companies view or contact you and show this to you.
• Your control: you can hide, pause, edit, or permanently delete your profile and all associated assessment data at any time from your dashboard, and withdraw consent with future effect.
• Retention: talent-pool profiles are retained for up to two years after your last activity, then deleted, unless you remove them sooner.

20. Contact

For privacy, GDPR, or data protection inquiries: info@beexpro.com