Terms & Conditions

Last updated on 22nd August 2026

1. Acceptance of Terms

By using ReCo, you accept these Terms and Conditions. If you do not agree with any part of these terms, you may not use the service.

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2. Description of Service

ReCo is a workspace application that supports recruiters through the interview-to-recommendation workflow. It enables the creation of interview transcripts, processing of CV and candidate data, and generation of candidate reports using AI.
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ReCo uses the OpenAI API to generate AI-assisted outputs. Data transmitted to OpenAI is not used to train OpenAI models or improve their services. See openai.com/security for details.
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Final reports are stored locally on the user's device. Recruiter Companion Labs PSA does not retain access to locally stored files.

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3. Scope of Services

ReCo is available to users worldwide, subject to applicable legal restrictions. Recruiter Companion Labs PSA reserves the right to limit access in certain jurisdictions if required by law.

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3.1 Fair use for in-person meetings and phone calls

Transcribing these conversations is enabled for an account following prior contact with us, and is subject to fair use agreed with the user at that point.

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Fair use is set to cover the needs of most recruiters and exists to prevent sustained automated or disproportionate consumption. Where usage goes materially beyond it, Recruiter Companion Labs PSA will contact the user to agree how continued use is to be handled, which may include an adjustment to the plan or an additional charge. Transcription is not interrupted without prior contact, except where use breaches Section 4 or applicable law.

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4. User Responsibilities

  • You must ensure you have the appropriate equipment and software to use ReCo.
  • You are responsible for the security and privacy of data stored on your device.
  • You agree to use ReCo in compliance with applicable laws, including data protection regulations.
  • You must not use ReCo for illegal activities or in violation of third-party rights.
  • You are responsible for ensuring a lawful basis for processing candidate personal data and for fulfilling your obligations as a data controller under applicable law.
  • You confirm that you are at least 18 years of age. ReCo is not intended for use by persons under the age of 18. Recruiter Companion Labs PSA does not knowingly collect personal data from persons under 18.

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5. Data Processing Addendum (DPA)

This section constitutes a Data Processing Addendum between the recruiter ("Controller") and Recruiter Companion Labs PSA ("Processor") pursuant to Article 28 of Regulation (EU) 2016/679 (GDPR). By accepting these Terms, the Controller instructs the Processor to process personal data of candidates on the Controller's behalf as described below.
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5.1 Subject matter and nature of processing

Recruiter Companion Labs PSA processes candidate personal data solely to provide the ReCo AI-assisted features, including generating reports from interview transcripts, CV content, job descriptions, notes, and chat messages. Processing consists of transmitting data to OpenAI's API and returning the generated output to the recruiter. For online meetings, ReCo does not record, capture, or transmit audio or video: transcription is based solely on closed captions generated by the video conferencing platform (Google Meet or Microsoft Teams). Where microphone transcription has been enabled for an account and a recruiter, acting as Controller, deliberately starts it to transcribe a conversation held in a room — an in-person interview, or a phone call the recruiter places from their own telephone and puts on speakerphone — ReCo captures audio through the microphone of the recruiter's computer and streams it, directly from the recruiter's browser, to Cantab Research Limited (trading as "Speechmatics") as a sub-processor for conversion into text. That audio is processed transiently: no audio recording is created or stored by Recruiter Companion Labs PSA, and the audio does not pass through its servers. ReCo does not place telephone calls and does not process telephone numbers.
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5.2 Categories of data and data subjects

Personal data of job candidates, including: names, contact details, professional experience, skills, and any other information contained in transcripts, CVs, job descriptions, notes, or chat messages submitted by the recruiter.

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Where a recruiter transcribes an in-person meeting or a phone call (Section 5.1), the data processed also includes the audio of the conversation while it is being transcribed, and the data subjects may include persons other than the candidate whose voices are audible in the room. Choosing a space where other people are not captured — or informing them that they may be — is the recruiter's responsibility (Section 5.5).

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ReCo includes a mandatory CV anonymization (blinding) step designed to minimize the amount of personal data transmitted to OpenAI's API. The recruiter controls the scope of anonymization applied and remains responsible for determining what data is ultimately submitted for processing.
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5.3 Duration

Processing occurs for the duration of the recruiter's use of ReCo's AI features. Data is not retained by Recruiter Companion Labs PSA beyond what is technically necessary for the processing operation.
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5.4 Processor obligations

Recruiter Companion Labs PSA shall:

  • Process candidate data only on documented instructions from the Controller (i.e. the recruiter's use of ReCo features).
  • Ensure that persons authorized to process the data are bound by confidentiality.
  • Implement appropriate technical and organizational security measures (Article 32 GDPR), including: encrypted data transmission (TLS), local processing of interview sessions without server-side retention of transcript or CV content, access controls using JWT-based authentication, mandatory CV anonymization prior to AI processing, and no retention of candidate data beyond what is technically necessary for the processing operation.
  • Not engage sub-processors without informing the Controller. Current sub-processors are listed in the Privacy Policy.
  • Assist the Controller in responding to data subject requests, where technically feasible.
  • Delete or return personal data upon termination of the service.
  • Make available to the Controller all information necessary to demonstrate compliance with Article 28 GDPR.
  • Allow for and contribute to audits and inspections conducted by the Controller or an auditor mandated by the Controller, subject to reasonable advance notice and confidentiality obligations.
  • Notify the Controller without undue delay — and in any event within 72 hours of becoming aware — of any personal data breach affecting candidate data processed through ReCo, providing sufficient information to enable the Controller to meet its own notification obligations under Article 33 GDPR.
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5.5 Controller obligations

The Controller (recruiter) confirms that:

  • It has a lawful basis under GDPR to process candidate data and to transmit it through ReCo.
  • It has provided candidates with appropriate information about data processing.
  • It will not submit special categories of data (Article 9 GDPR) unless a valid legal basis applies.
  • Where it transcribes an in-person meeting or a phone call (Section 5.1), it will either hold the conversation in a space where other people are not captured, or inform those present that their voices may be captured, and will obtain the consent of all parties wherever the applicable law requires it.
  • It keeps the conversation within what applicable recruitment and employment law permits, and does not ask questions that solicit special categories of data (Article 9 GDPR). Microphone transcription captures speech as spoken and cannot filter or redact what is said, so where such information is volunteered even so, it decides whether to continue, and may stop transcription and delete the transcript or the passage concerned.
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5.6 Sub-processors

The Controller (the recruiter) authorizes Recruiter Companion Labs PSA to engage the sub-processors listed in the Privacy Policy (currently: OpenAI Ireland Ltd., Cantab Research Limited trading as "Speechmatics" , Auth0 by Okta, and Stripe, Inc.). Each sub-processor operates under a DPA compliant with Article 28 GDPR. OpenAI does not use API data to train its models. Speechmatics is engaged only for the real-time conversion into text of audio captured through the microphone, as described in Section 5.1, and receives no other candidate or recruiter data. Speechmatics does not store audio, transcripts, or configuration data for its real-time service, and does not use real-time audio to improve its models. Speechmatics may involve its own group companies in providing and supporting the service, under the same contractual protections. Recruiter Companion Labs PSA will inform the Controller in advance of any intended addition or replacement of a sub-processor, thereby giving the Controller the opportunity to object to the change. If the Controller objects and the objection cannot be resolved within a reasonable period, either party may terminate the affected services in accordance with Section 12.

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Recruiters using ReCo are responsible for informing candidates about AI-assisted data processing before or at the start of any interview. The following clause is provided as a ready-to-use template that recruiters may copy and share with candidates (e.g. in a calendar invite, email footer, or at the start of a call).

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Important Notice for Candidates

Before we get started — this interview will be supported by AI tools. Here's what that means in practice:

  • Your conversation will be transcribed.
  • If we are meeting in person, or speaking by phone on speakerphone, this is done by capturing the sound in the room through my computer's microphone. The audio is converted into text by a specialist speech-to-text provider; no recording of it is created or kept.
  • The transcript and any materials you've shared (like your CV) may be processed by AI to help the recruiter prepare a structured summary of your interview.
  • AI may also be used, including but not limited to, assessing how your profile matches the role's requirements.

A human recruiter reviews all AI outputs before drawing any conclusions. No decisions are made by AI alone.

By proceeding with the interview, you consent to the processing described above.

You can withdraw your consent at any time by contacting the recruiter directly.

For more details, see our [Privacy Policy — insert link to your company's privacy policy].

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Use of this template does not constitute legal advice. Recruiters remain responsible for ensuring that their data processing practices comply with applicable law, including the GDPR.

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7. EU AI Act — Deployer Obligations

In the context of the EU AI Act (Regulation (EU) 2024/1689), recruiters who use ReCo to conduct interviews and generate candidate assessments act as deployers of an AI-assisted tool. By using ReCo in a recruitment context, the recruiter acknowledges this role and agrees to fulfil applicable deployer obligations, including:

  • Informing candidates that AI is used in the recruitment process.
  • Disclosing to candidates, where required under Article 50 of the EU AI Act, that AI-generated content (such as evaluation summaries or candidate reports) has been produced with the assistance of an AI system.
  • Ensuring human oversight of AI-generated outputs before any decisions are made.
  • Not using AI-generated outputs as the sole basis for decisions that significantly affect candidates.

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ReCo supports deployers in meeting these obligations by design: all AI outputs are intended to assist — not replace — human judgment, and recruiters retain full control over the assessment process.

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8. Consumer Rights

If you are a consumer within the meaning of EU law, you have the right to withdraw from the contract within 14 days of its conclusion without providing a reason. To exercise this right, contact us at: [email protected]. Any payments made will be refunded within 14 days using the original payment method.

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9. Intellectual Property

All intellectual property rights to ReCo belong to Recruiter Companion Labs PSA or are licensed to it. You receive a non-exclusive, non-transferable license to use ReCo in accordance with these Terms. This license does not grant ownership rights to the application.

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10. Limitation of Liability

To the maximum extent permitted by law, Recruiter Companion Labs PSA shall not be liable for any direct, indirect, incidental, special, consequential, or exemplary damages arising from the use or inability to use the service, including but not limited to lost profits, reputational harm, or data loss.

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11. Maintenance and Outages

Recruiter Companion Labs PSA will make reasonable efforts to ensure service continuity. Technical outages may occur due to maintenance or unforeseen failures. Recruiter Companion Labs PSA shall not be liable for damages arising from such interruptions.

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12. Termination

Recruiter Companion Labs PSA may suspend or terminate your access to the service without prior notice if you breach these Terms.

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12a. Termination by the User

You may cancel your subscription at any time from the account settings or by contacting us at [email protected]. You may also allow your subscription to lapse by not making payment for the next billing period, in which case your access to ReCo will cease at the end of the current paid period and your account will become inactive. No refunds are issued for the remaining portion of a paid billing period.

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Cancellation or lapse of your subscription does not relieve you of any obligations that arose prior to or survive termination, including your data protection responsibilities as set out below.

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If you are a consumer within the meaning of EU law, your right to withdraw from the contract within 14 days is set out in Section 8.

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All interview data — including transcripts, CVs, reports, and chat history — is stored locally in your browser. This data remains on your device after cancellation. As a data controller under GDPR, you remain responsible for managing and deleting candidate data stored locally in accordance with your data retention obligations.

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13. Governing Law

These Terms and Conditions are governed by the laws of Poland, without regard to its conflict of law principles.

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14. Final Provisions

These Terms constitute the entire agreement between you and Recruiter Companion Labs PSA regarding the use of ReCo. If any provision is found invalid or unenforceable, the remaining provisions remain in full force and effect.

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15. Promotional Programs

From time to time, ReCo may offer referral programs, promotional offers, or similar incentives. These programs may be subject to additional terms published separately, including the ReCo Referral Program Terms.

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16. Contact

Recruiter Companion Labs PSA

ul. Pilotów 2a/13, 31-462 Kraków, Poland (EU)

Email: [email protected]

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