Privacy Policy

1. General

Hudle B.V. (in formation), referred to below as “Hudle”, develops and operates Hudle, a software-as-a-service (SaaS) platform for staffing compliance, talent management, dynamic CV management, capacity planning and related services. Hudle is committed to processing personal data lawfully and carefully and protecting such data against unauthorised or unlawful use. This Privacy Notice explains which personal data Hudle processes, for what purposes, how data may be shared and safeguarded, and the rights available to individuals under the General Data Protection Regulation (GDPR).

Hudle B.V. (in formation). Correspondence address: Johan Huizingalaan 763A, 1066 VH Amsterdam (B. Amsterdam, B.1). Email: privacy@hudle.nl. Website: www.hudle.nl.

2. Roles and responsibilities

Hudle may act either as a data controller or a data processor, depending on the purpose and context of a particular processing activity.

2.1 Hudle as a controller

Hudle determines purposes and means for processing related to its own business relationships with customers, prospects and suppliers; administration and invoicing; certain account and access-management activities; information security and fraud prevention; support and communications; website operations; and compliance with legal obligations.

2.2 Hudle as a processor

Where a customer uses the platform to process personal data of its employees, professionals, candidates, clients or other individuals for that customer’s purposes, the customer is generally the controller and Hudle is the processor. Hudle acts on the customer’s documented instructions unless otherwise required by law. A separate Data Processing Agreement governs these respective obligations.

3. Segregated customer environments

Hudle’s architectural principle is a separate logical tenant for each customer. Customer-specific data is processed in the applicable customer environment, with role-based authorisation to restrict access to permitted users and functions. This may include candidate profiles and CVs, skills, education and work experience, availability and assignments, vacancies and matching, shortlists, client presentations, workforce planning, messages, certificates and VOG-related compliance information, and activity or audit data.

Hudle does not use one customer’s data to provide services to another customer unless an independent lawful basis exists or the customer expressly instructs Hudle to do so. Some underlying infrastructure and general platform components may be shared, provided appropriate safeguards maintain segregation.

4. Categories of personal data

Depending on the functions used and information provided by the customer, Hudle may process:

4.1 Identification and contact data

Names, email addresses, telephone numbers, employer or organisation, job titles, user accounts, authentication and authorisation information.

4.2 Professional information

CVs, work history, education, skills, certifications, language proficiency, projects, professional preferences and availability.

4.3 Staffing and planning data

Current and expected assignments, allocation, availability, capacity, client submissions, feedback, interviews and placements.

4.4 Compliance and certificate information

Where enabled, VOG (Dutch certificate of conduct) metadata, issue dates, validity and verification status, related documents, checks and audit information. OCR may be used to extract relevant information from documents. Hudle seeks to minimise personal data to what is reasonably necessary.

5. Purposes and legal grounds

Where Hudle acts as controller, its processing relies, as applicable, on performance of a contract, compliance with a legal obligation, legitimate interests, or consent where consent is the appropriate basis. Purposes include making the platform available, managing access, performing contracts and billing, customer support, security, preventing misuse, legal compliance and improving services.

Where Hudle acts as processor, the customer is responsible for determining the purpose and lawful basis and for providing relevant privacy information to individuals.

6. Hudle IQ and artificial intelligence

Hudle IQ may support vacancy analysis, matching and ranking of profiles, explanations of matches, identification of skills gaps, CV editing and translation, forecasting, workforce analytics and questions about information within a customer’s tenant. When tenant data is processed, AI functionality is intended to operate within that tenant’s authorisation context and not to expose one customer’s personal data to another.

AI outputs, scores and recommendations are decision-support tools only. They do not themselves constitute decisions to select, reject, hire, place or terminate the engagement of an individual. Human users or customers remain responsible for final decisions.

Whether personal data submitted to AI services is used to train general models depends on the actual technical arrangements and agreements with relevant providers; this point must be verified before an unconditional public claim is made.

7. Disclosures to clients via Hudle Link

Hudle Link enables customers to share selected candidate or professional information with their clients. The customer decides which information is shared, with whom and for how long. Depending on configuration, features may include time-limited access, access restrictions, SMS verification, anonymised profiles and activity logging. Such sharing is undertaken on the customer’s instructions and responsibility.

8. Recipients and subprocessors

Hudle does not sell personal data. To provide its services, Hudle may engage providers of cloud infrastructure, AI processing, OCR, email and notifications, SMS, monitoring and logging, security, support and technical management. Where a party is a subprocessor, appropriate contractual arrangements are required under the GDPR. An up-to-date list of relevant subprocessors can be requested from Hudle.

9. International transfers

Hudle aims to process personal data within the European Economic Area (EEA). Where personal data is transferred outside the EEA or accessed from outside it, Hudle assesses the lawfulness of that transfer and implements applicable safeguards, such as an adequacy decision or other recognised mechanism under the GDPR.

10. Retention and deletion

Personal data is not kept longer than necessary for the purposes for which it was collected, unless retention is legally required or otherwise justified. Customers generally determine retention periods for data processed on their behalf within the platform’s agreed capabilities. Following termination, customer data is made available for transfer and/or deleted in accordance with the SaaS and Data Processing Agreements. Backup copies are removed in line with backup and retention cycles. Some data may be retained as necessary for legal compliance, platform security or legal claims.

11. Security of personal data

Hudle applies appropriate technical and organisational security measures. Depending on the context these may include tenant segregation; identity and access management; role-based permissions and least privilege; authentication; encryption in transit and secure storage; logging and monitoring; API protection; patching and vulnerability management; secure development; backups and recovery; controls on administrative access; and periodic review.

Hudle staff or service providers may access customer data only insofar as authorised and necessary for operations, support, security or service management. Hudle does not publish sensitive technical details that could weaken its security.

12. Logs and audit data

Hudle may log activity for information security, investigation of incidents, administration and support, troubleshooting, fraud prevention and auditability. Logs are accessible only to authorised persons and are retained no longer than necessary for the relevant purpose.

13. Cookies and similar technologies

Hudle’s websites and application may use cookies and similar technologies. Strictly necessary technologies support authentication, sessions, security and core application functionality. Where the law requires consent for non-essential technologies, those technologies are used only after valid consent. See the separate Hudle Cookie Notice.

14. Data subject rights

Subject to applicable GDPR conditions, individuals may request access, rectification, erasure, restriction, portability and objection; withdraw consent; and exercise applicable rights concerning solely automated decisions. For processing where Hudle is controller, contact privacy@hudle.nl. For data Hudle processes on behalf of a customer, requests should generally be directed to that customer. Hudle supports its customers in fulfilling such requests in line with the Data Processing Agreement. Reasonable identity verification may be required.

15. Complaints

Privacy questions and complaints may be sent to privacy@hudle.nl. If Hudle processes the data only on a customer’s behalf, that customer is generally the first point of contact. Individuals also have the right to lodge a complaint with their competent supervisory authority; in the Netherlands this is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

16. Minors

Hudle is intended for professional and business use and is not specifically directed to minors. If a customer processes a minor’s personal data using Hudle, the customer is responsible for the lawful basis and any additional required safeguards.

17. Amendments

Hudle may amend this Privacy Notice following changes to its services, technical architecture, business operations or applicable law. The most recent version is made available through Hudle’s website. Material amendments may also be notified to customers or users.

18. Contact details

Hudle B.V. (in formation)
Correspondence address: Johan Huizingalaan 763A, 1066 VH Amsterdam (B. Amsterdam, B.1)
Email: privacy@hudle.nl
Website: www.hudle.nl

Recruitment workflow and data sharing

Hudle brings together recruitment, talent pools, professional availability, staffing status, CV management, vacancy matching, shortlist creation and candidate submissions within a connected workflow that can complement an existing applicant tracking system (ATS). Client feedback and submission history may be recorded in the customer’s tenant to support follow-up and transparency. The customer remains responsible for the lawfulness of collecting, sharing and retaining candidate information, including CVs and communications.

Website analytics

The current website configuration uses Google Tag Manager (GTM-TDDMFK45) and Google Analytics 4 (measurement ID G-TYD7SXZ0ZJ), with consent defaults set to denied. According to the configured page-view exclusions, the test environment test.hudle.nl and routes /dashboard and /internal are excluded from standard page-view measurements. These are configuration details, not a guarantee that no technical requests occur. Actual production operation, consent and data transfers should be verified.