Privacy Policy

This Privacy Policy is provided by Universal Grammar Limited a company registered in England and Wales under company number: 10901058 with registered office 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX ('we', 'our' or 'us') for use of our recruitment technology platform and API services including our website www.recuity.ai (Services). The Services are designed for recruitment companies and recruiters ('you' or 'your') to maintain job data from their client companies and access it through various means.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

This privacy policy relates to your use of the Services only.

The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

We use cookies and similar technologies that are strictly necessary to operate the Services and, with your permission, analytics cookies that help us improve them. Specifically:

• Authentication cookies — our authentication provider, WorkOS, sets session cookies when you log in. These are required to keep you authenticated while using the Services and cannot be disabled without preventing access.
• Payment cookies — our payment processor, Stripe, may set cookies in connection with payment and subscription processing.
• Analytics cookies — our analytics provider, PostHog, helps us understand how the Services are used. Analytics cookies are only set if you accept them in the cookie banner. Until you answer, visits are counted anonymously without cookies, and if you switch analytics off we collect no analytics about your visits.

We do not use cookies for advertising. Strictly necessary cookies do not require your consent under UK GDPR. You can change your choice about analytics at any time using the Cookie settings link at the bottom of every page.

Our Cookie Policy lists each cookie we use, its purpose and how long it lasts.

The personal data we collect about you depends on the particular activities carried out through the Services. As a recruitment company or recruiter using our Services, we will collect and use the following personal data about you:

Category of data	In more detail
Account registration and identity data	First name and Last name Email address Company name and information Job title Contact details
Data about client companies you track	Information about the companies you choose to track in your private workspace, including company names, tracked job postings, and your workspace configuration preferences (this data is maintained separately for each recruiter and is not shared with other users)
Usage and activity data	Your activities on and use of the Services, including: Public IP address of the device you are using Browser information Time and date of access to the Services Pages visited and features used Search queries, filters, and API requests Company research activities Job data exports and downloads
Billing and subscription data	Payment information, subscription plan details, and billing history (payment card details are processed by our payment service provider and are not stored by us)
Data collected when you make an enquiry with us	Your name and email address and any other personal information you supply to us
Data collected when you interact with us on social media	Your social media profile information including but not limited to profile name and profile photo

If you do not provide personal data we ask for where it is required it may prevent us from providing services and/or the Services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.

If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.

We collect personal data from you directly when you:

• Register for an account and set up your recruitment workspace
• Sign in using a third-party authentication provider (such as Google) — in which case we receive certain profile information, such as your name and email address, from that provider in accordance with your settings on their platform
• Configure your workspace by selecting client companies to track
• Use our web interface, API, or export functionalities
• Subscribe to a pricing plan and process payments
• Contact us for support or inquiries
• Interact with us via email or social media

We also collect data indirectly through your use of the Services, such as usage patterns, API calls, and system interactions.

As part of providing the Services, we automatically crawl publicly available company career pages to collect job posting data. This process may incidentally capture personal data published on those pages (such as the name or contact details of a named recruiter). We process any such data solely to provide the Services and do not use it for any other purpose. We take reasonable steps to minimise the retention of incidentally collected personal data.

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

1. where you have given consent
2. to comply with our legal and regulatory obligations
3. for the performance of a contract with you or to take steps at your request before entering into a contract, or
4. for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
To provide access to your private recruitment workspace and maintain job data from your client companies	To perform our contract with you, namely to deliver the core functionality of our recruitment technology platform
To provide API access and data export functionalities for your recruitment operations	To perform our contract with you and enable you to integrate our Services with your recruitment workflows
To process subscriptions, billing, and manage your account	To perform our contract with you and comply with legal obligations related to financial transactions
To maintain workspace isolation and ensure your client company data remains private and confidential	To perform our contract with you and for our legitimate interests in protecting the confidentiality of your business relationships
Providing services and/or the functionalities of the Services to you	to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Website Terms of Use or any other terms which apply to the Services)
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Protect the security of systems and data	To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app
Updating and enhancing user records	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To comply with our legal and regulatory obligations	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) to comply with our legal and regulatory obligations
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

We do not intend to send you email marketing to inform you of our services such as promotions. If we ever do, we will only do so with your consent.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

We routinely share personal data with the following categories of trusted service providers who help us run our business and deliver the Services:

• Authentication provider (WorkOS) — manages user login, session management, and identity verification. WorkOS processes your name, email address, and authentication credentials on our behalf.
• Payment processor (Stripe) — handles subscription billing and payment processing. Stripe processes your payment information and billing details. We do not store payment card details ourselves.
• Analytics provider (PostHog) — helps us understand how the Services are used. PostHog processes information about the pages you visit and the features you use and, if you have accepted analytics cookies and are signed in, your account identifier and organisation name.
• Cloud hosting and infrastructure providers — provide the servers, databases, and infrastructure on which the Services run.
• Email service providers — used to send service-related communications such as account notifications.

We will not disclose your workspace configuration (which companies you choose to track) to other customers or third parties. Your workspace configuration and the fact that you are a customer remain confidential.

Job data aggregated from public company career pages may be accessed by multiple customers who independently choose to track the same companies. However, we do not disclose to any customer which other customers, if any, are tracking the same companies.

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you, and cannot use it for their own purposes.

We will never sell, rent, or share your personal data or disclose your client relationships with other recruitment firms, competitors, or for marketing purposes. Your business relationships remain completely confidential.

We or the third parties mentioned above may occasionally also need to share your personal data with:

• external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
• professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
• law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
• other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

We will keep your personal data and workspace information for as long as you maintain an active subscription with us. After account closure, we will retain your personal data for a period of up to 7 years to comply with accounting, tax, and legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will securely archive your personal data in a separate database with restricted access limited to key stakeholders in our business on a 'need-to-know' basis for legitimate business and legal purposes only.

Upon account closure, your workspace data (including tracked companies and job data) will be deleted within 90 days unless you request immediate deletion or we are required to retain it for legal reasons.

Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.

Some of the service providers we use are based outside the UK, which means your personal data may be transferred to and processed in countries outside the UK, including the United States. Specifically:

• WorkOS (authentication provider) — operates infrastructure in the United States.
• Stripe (payment processor) — operates infrastructure in the United States.
• PostHog (analytics provider) — stores our analytics data in the European Union.
• Cloud infrastructure providers — may process data in data centres located outside the UK.

Under UK data protection law, we can only transfer your personal data outside the UK where appropriate safeguards are in place. For transfers to the United States and other countries not covered by a UK adequacy regulation, we rely on one or more of the following mechanisms:

• Standard Contractual Clauses approved under the UK International Data Transfer Agreement (UK IDTA) or the UK Addendum to the EU Standard Contractual Clauses, incorporated into our contracts with those service providers; or
• Where the recipient is certified under a framework recognised under UK GDPR as providing adequate protection.

You can obtain further details of the safeguards in place for international transfers by contacting us using the details in ’How to contact us’ below.

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

Access to a copy of your personal data	The right to be provided with a copy of your personal data.
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine- readable format and/or transmit that data to a third party—in certain situations.
To object to use	The right to object: at any time to your personal data being used for direct marketing (including profiling) in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by the Services.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please send an email email or write to us—see below: ‘How to contact us’. When contacting us please:

• provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Address: 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX

email: [email protected]