Privacy and Cookies Policy

This Privacy and Cookies Policy explains how personal data is processed in connection with the website and the AI recruitment platform operated by:

("Company", "we", "us")

This Policy applies to:

• visitors of the website,
• newsletter subscribers,
• people contacting us,
• users of our social media pages,
• and users of the SaaS recruitment platform.

It does not replace the Data Processing Agreement (DPA) between the Company and business customers using the recruitment platform.

1. Definitions

2. Who is the data controller

The Company acts as:

For candidate data, the Customer is the controller and the Company processes data only on their behalf under a Data Processing Agreement.

3. Data processed on the Website

When you visit the Website, we automatically process technical data such as:

• IP address
• browser and device type
• operating system
• date and time of visit
• visited pages

This data is processed based on our legitimate interest in operating and securing the Website and improving its performance (Article 6(1)(f) GDPR).

The Website is hosted on secure servers located in the EU.

4. Newsletter

When you subscribe to our newsletter, we process:

• your email address (required)
• optionally your name

The purpose is to send information about our products, services, and recruitment-related insights.

Legal basis:

• your consent to receive electronic communication
• our legitimate interest in maintaining business communication

You may unsubscribe at any time.

Newsletter delivery is handled by an external provider (e.g. Mailer Lite), which processes data under EU Standard Contractual Clauses.

5. Contact forms

If you contact us via a form or email, we process:

• name
• email address
• content of your message

Legal basis: Our legitimate interest in responding to inquiries and maintaining business correspondence.

Data is stored until the communication ends and claims are time-barred.

6. Social media

We operate company pages on platforms such as LinkedIn and Facebook.

We process personal data of people interacting with these pages (e.g., comments, messages) based on our legitimate interest in:

• communicating with users,
• sharing information about our services,
• marketing and brand awareness.

Each platform is a separate controller of its own user data.

7. SaaS platform – Candidates

Candidates do not have accounts in the Platform.

All candidate data is uploaded by Customers.
Customers are the data controllers.

The Company processes candidate data only:

• to provide AI-based matching, scoring, and recruitment support,
• under written instructions defined in the Terms of Service and DPA.

We do not determine the purposes of recruitment and do not make hiring decisions.

The Platform does not require or intentionally process sensitive personal data.

8. AI and third-party processing

The Platform uses:

• AWS (EU) for hosting and storage
• OpenRouter / LLM providers only on anonymized data

Before any data is sent to LLMs:

• names, emails, phone numbers and identifiers are removed
• the data cannot reasonably identify a person

This anonymized data is used only to generate insights and recommendations.

9. Data recipients

Data may be processed by:

• hosting providers,
• email and analytics providers,
• legal, accounting, and IT service providers.

All such providers act under contracts ensuring confidentiality and GDPR compliance.

10. User rights

Every data subject has the right to:

• access their data
• correct data
• delete data
• restrict processing
• object to processing
• data portability
• lodge a complaint with a supervisory authority

Requests can be sent to:
info@3of100.tech

If you are a candidate, your request should be addressed primarily to the employer who recruited you, as they are your data controller.

11. Cookies and tracking technologies

We use cookies and similar technologies for:

• Website functionality
• traffic analytics
• marketing and optimization

Cookies may collect:

• IP address
• device and browser type
• pages visited

We use:

• Google Analytics
• Meta (Facebook) Pixel
• Hotjar

These tools do not allow us to directly identify users.

You can control cookies through your browser settings.

12. Changes

We may update this Privacy Policy to reflect legal, technical, or business changes.
The current version is always published on our Website.