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TUGA Recruitment

Legal

Privacy Policy

Last updated: October 27, 2026

TUGA Recruitment connects candidates from the European Union with employers across Europe. To do that we need to process personal data — some of it sensitive, such as identity documents, your BSN, your bank details and voice recordings. This policy explains, in plain language, what we collect, why, who sees it, how long we keep it and what your rights are under the General Data Protection Regulation (GDPR).

1. Who is responsible for your data

The data controller is TUGA Recruitment, registered with the Netherlands Chamber of Commerce (KVK) under number 42059707, with its registered office at Eikenlaan 203b, 6024 AN Budel-Dorplein, the Netherlands.

We are not required to appoint a Data Protection Officer. For questions about privacy, contact us at info@tugarecruitment.com.

2. What data we collect

If you register as a candidate, depending on how far you complete your profile:

  • Account data — name, email address, password (stored encrypted, never readable by us).
  • Contact and personal details — phone and WhatsApp number, emergency contact, date of birth, gender, nationality, native language, address, postal code, city and country.
  • Professional profile — CV, work experience, education, certifications, references, driving licences, availability, English level, whether you have your own transport or housing, and a profile photo if you add one.
  • Documents for placement — only after a client has accepted you, and only when they are needed to prepare your start: a copy of your identity document, your BSN (Dutch citizen service number), your IBAN and, if the job requires it, your driving licence. We do not ask for your BSN or a copy of your identity document during your application. If you are hired, the employer processes the data it needs to meet its legal obligations (identification, payroll and tax administration).
  • Voice recording (optional) — if you choose to record the English exercise, the audio file, its duration and the exercise you were given. It is only used by a recruiter to confirm your English level. It is not used to identify you and is not biometric data.
  • Activity on the platform — applications, proposals, status history, notifications, recruiter notes and the compatibility scores calculated for you.
  • Consent records — when you accepted these documents, which version, your IP address and browser type.

If you use the chat assistant, the messages you write and the language you choose. Please do not share identity numbers, bank details or passwords in the chat.

If you are a client or a contact person at a client, your name, business email, phone number, role and the communications we exchange.

If you only visit the website, our hosting providers process technical data such as your IP address, browser type and the pages requested, in server logs. We do not use analytics or advertising tools — see our Cookie Policy.

We collect this data directly from you, from the CV you upload, and from the recruiters who work with you. We do not buy data from third parties.

3. Why we use it and on what legal basis

PurposeLegal basis (GDPR)
Creating and managing your accountPerformance of a contract — Art. 6(1)(b)
Matching your profile with job offers and presenting you to clientsPerformance of a contract / steps at your request — Art. 6(1)(b)
Preparing your start, after a client has accepted you: identity document, BSN and IBANLegal obligation — Art. 6(1)(c)
Assessing your English level from a voice recordingYour consent — Art. 6(1)(a). You can withdraw it at any time by deleting the recording
Using AI to read CVs, calculate compatibility and draft proposals (see section 5)Legitimate interest in running an efficient recruitment service — Art. 6(1)(f), with the safeguards described below
Keeping you informed about your applications by email and platform notificationsPerformance of a contract — Art. 6(1)(b)
Sending you WhatsApp messages (job invitations, status updates, document requests)Your consent — Art. 6(1)(a). You can withdraw it at any time
Answering questions through the chat assistantLegitimate interest — Art. 6(1)(f)
Managing our relationship with clientsPerformance of a contract / legitimate interest — Art. 6(1)(b) and (f)
Security, preventing fraud and misuse, keeping proof of consentLegitimate interest and legal obligation — Art. 6(1)(f) and (c)
WhatsApp. We only message you on WhatsApp if you have agreed to it — when you register, in your candidate area, or by writing to us first. We use it for your recruitment process (job invitations you can answer with YES or NO, status updates and document requests), never for marketing. You can stop it at any time: reply STOP in the WhatsApp conversation, switch it off in your candidate area, or email us. We stop immediately. Messages are delivered through the WhatsApp Business API, so WhatsApp Ireland Ltd. (Meta) processes them as described in section 4. Anything you send us there — including photos of documents — is stored with the rest of your file.

Where we rely on legitimate interest, you have the right to object (see section 8). We do not use your data for marketing and we never sell it.

4. Who we share your data with

What a client sees when we propose you. The client sees your full name, your age, your phone and WhatsApp numbers, your compatibility percentage and your CV. The CV is either the one we generate (with your first name, your photo if you added one, and your email address and phone/WhatsApp number, and without your surname, date of birth or city) or the CV you uploaded, exactly as you sent it. A client never receives your home address, date of birth, BSN, IBAN or voice recording. If the client declines the proposal, we stop showing them your name and contact details. After a client accepts you, they can open and download your identity document and your driving licence (front and back) from their client area as you upload them, and our team may also email them those documents together with your phone number and email address to prepare your interview and your start. Every time a client opens one of your documents, it is recorded. If you do not start the job, the client can no longer open your documents.

Documents you upload stay with TUGA Recruitment and are opened by authorised recruiters. The only exception is the client that has accepted you, which can open and download your identity document and driving licence for as long as the placement stands. We never send clients your BSN, IBAN or bank details.

We also use service providers that process data on our behalf (processors), under a data processing agreement:

ProviderServiceLocation
Vercel Inc.Hosting of the websiteUnited States / EU edge network
AncornetHosting of the platform, database and uploaded files; sending of emailsPortugal
OpenAI (API)AI processing (see section 5)United States
WhatsApp Ireland Ltd. (Meta)WhatsApp messages, when you contact us or we contact you thereEU / United States

We may also disclose data to public authorities when the law requires it.

5. How we use artificial intelligence

We use AI tools to help our recruiters work faster. We want you to know exactly where:

  • Reading your CV — to pre-fill your profile. Before your CV is sent to the AI provider, we automatically remove your name, email address, phone number, IBAN, identity numbers, postal code, address and links.
  • Calculating compatibility — a percentage that estimates how well your profile fits each job offer.
  • Clarifying your CV — the AI may suggest up to five questions about gaps or unclear points. A recruiter reviews your answers before anything changes on your profile.
  • Drafting proposals — the AI writes a first draft of the proposal sent to a client. A recruiter always reads, edits and approves it.
  • Internal notes — suggestions for the recruiter on how your CV could be improved.
  • Chat assistant — answers general questions about the platform and the application process.

Your English level is never assessed by AI. Only a recruiter, listening to your recording, can confirm or change it.

Your right to human intervention. The compatibility score decides whether the "Apply" button is available to you for an offer (a minimum of 80% is required). If you think a score is wrong or you want to be considered anyway, contact us at info@tugarecruitment.com at any time, including while the offer is still open: a recruiter will review your profile for that offer personally, you can explain your point of view, and you can contest the result (Article 22 GDPR). Decisions to propose you to a client are always taken by a person.

6. International transfers

Some of our providers are based in the United States (see section 4), so your data may be transferred outside the European Economic Area. We only do this when the transfer is protected by an adequacy decision of the European Commission (such as the EU-US Data Privacy Framework, for certified companies) or by the European Commission's Standard Contractual Clauses.

Before a CV is sent for AI processing, direct identifiers are removed (see section 5), so that the minimum amount of data leaves the EEA.

7. How long we keep your data

DataHow long
Candidate account and profile (including CV)While your account is active. You can ask us to delete your account and data at any time (see sections 8 and 9)
Voice recording for the English assessmentDeleted automatically 12 months after it was made if you are not in an active recruitment process. You can delete it yourself at any time from your profile
Identity documents, BSN and IBANOnly for as long as needed for your placement, and afterwards for the period required by Dutch law
Proof of consent (these documents)For as long as your account exists
Client and business contact dataFor the duration of the business relationship and afterwards for as long as the law requires us to keep business records

When a retention period ends, data is deleted or irreversibly anonymised.

8. Your rights

Under the GDPR you have the right to:

  • Access — get a copy of the personal data we hold about you.
  • Rectification — have incorrect or incomplete data corrected. You can also edit most of your profile yourself.
  • Erasure — have your data deleted, unless we are legally required to keep it.
  • Restriction — ask us to temporarily stop using your data, for example while we check its accuracy.
  • Data portability — receive the data you gave us in a structured, machine-readable format.
  • Object — to processing based on our legitimate interest, including AI-assisted processing.
  • Withdraw consent — at any time, for processing based on consent (such as the voice recording), without affecting what was done before.
  • Human intervention — not to be subject to a decision based solely on automated processing, and to have a person review it (see section 5).

You also have the right to lodge a complaint with the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens, or with the data protection authority of the EU country where you live or work. We would appreciate the chance to resolve your concern first.

9. How to exercise your rights

Send an email to info@tugarecruitment.com from the email address linked to your account, saying which right you want to exercise. If we cannot confirm that the request comes from you, we may ask for additional information — but never a full copy of your identity document for this purpose.

We reply within one month. For complex requests this may be extended by two more months; if so, we will tell you why within the first month. Exercising your rights is free of charge.

10. How we protect your data

All connections to the website and the platform are encrypted (HTTPS). Passwords are stored as one-way hashes. Documents and voice recordings are kept in private storage that is not publicly accessible and can only be opened by authorised recruiters (and, for your identity document and driving licence, by the client that has accepted you, as described in section 4). Access within our team is limited by role, and clients only ever see the limited information described in section 4.

If a data breach occurs that is likely to put your rights at risk, we will notify the Autoriteit Persoonsgegevens within 72 hours and inform you without undue delay when required by law.

11. Cookies

We only use cookies that are necessary for the website to work — to keep you signed in and to remember your language and display preferences. We do not use analytics, advertising or tracking cookies. Full details are in our Cookie Policy.

12. Changes to this policy

We may update this policy when our services or the law change. The date of the latest version is shown at the top of this page. If the changes are significant, we will inform registered users and, where required, ask you to accept the new version.

We only use cookies that this website needs to work — to keep you signed in and remember your preferences. No analytics, no advertising, no tracking.