Privacy Policy

Leadl.recruit

Last updated: July 12, 2026.

1. Who we are

1.1. This Privacy Policy explains how AI LEADPLATFORM, S.L. (“Leadl”, “we”, “us”), a company incorporated in Spain, operator of the Leadl.recruit platform (the “Platform”), processes personal data.

1.2. Contact:

• Controller: AI LEADPLATFORM, S.L., CIF B75627067, registered office at Calle Consell de Cent, 38, 08014 Barcelona, Spain
• Data protection contact / DPO: hay@leadl.ai

1.3. This Policy is issued under Regulation (EU) 2016/679 (“GDPR”) and Spanish Organic Law 3/2018 (LOPDGDD). As a controller established in the EU (Spain), we are not required to appoint an Article 27 representative. Where we act as a processor on behalf of our business customers, the customer’s privacy notice — not this Policy — governs that processing; see Sections 4 and 8.

2. Our roles: controller and processor

Leadl processes personal data in more than one capacity, and the applicable rules differ:

When we make a sourced candidate profile available to a customer, the customer becomes an independent controller of their copy. We do not act as joint controllers with our customers.

3. Personal data we process and legal bases

3.1. Customers, users and website visitors (data collected from you — Art. 13)

3.2. Candidates (data NOT obtained from you — Art. 14)

See the dedicated Candidate Privacy Notice in Section 8, which is the primary notice for individuals whose professional data we source. In short:

• Categories of data (Art. 14(1)(d)): name; professional/vocational information — role, skills, experience, education; links to professional and public profiles and work outputs; city/region; and, where the individual has made them public, professional contact details.
• Legal basis: Art. 6(1)(f) legitimate interests — connecting qualified professionals with relevant opportunities and enabling our customers to recruit efficiently. We have carried out and documented a Legitimate Interest Assessment (balancing test); a summary is available on request.
• Source (Art. 14(2)(f)): publicly accessible sources such as professional networking sites, developer and portfolio platforms, public professional directories, and licensed third-party data vendors.

3.3. Special category data (Art. 9)

We do not intend to collect or infer special category data (racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health, sex life or sexual orientation, genetic or biometric data). We configure our sources and models to exclude and filter out such data at ingestion and to avoid producing inferences about protected characteristics. Any special category data received inadvertently is deleted.

4. How we use automated processing and AI (Art. 22)

4.1. The Platform uses automated processing, including profiling, to generate a suitability indication, possible red flags, and suggested interview questions for a role.

4.2. These outputs are decision-support tools for a human recruiter and do not constitute a decision based solely on automated processing that produces legal or similarly significant effects on the candidate. The final screening and hiring decisions are made by the customer’s personnel, who review the outputs and retain full authority to disregard them.

4.3. We provide meaningful information about the logic involved (the criteria influencing an output) without disclosing trade secrets. Where a candidate believes an automated output has significantly affected them, they may request human review, express their view, and contest the output via hay@leadl.ai.

4.4. AI systems used for recruitment may qualify as high-risk under the EU AI Act (Reg. (EU) 2024/1689). We implement transparency, human-oversight, logging and monitoring measures accordingly. Customers remain solely responsible for their hiring decisions and for compliance with anti-discrimination law.

5. Recipients and sub-processors

5.1. We share personal data with: our business customers (as described above); service providers acting as processors (cloud/hosting, analytics, payment, and AI/LLM providers); and authorities where legally required.

5.2. AI/LLM providers are contractually barred from using personal data to train their models. Our current sub-processors and the applicable transfer mechanism per vendor are listed at hay@leadl.ai (on request).

6. International transfers

6.1. Where personal data is transferred outside the EEA, we rely on: an adequacy decision (including the EU–US Data Privacy Framework for certified importers); the EU Standard Contractual Clauses; the UK IDTA/Addendum; and Swiss safeguards — supported by a transfer impact assessment where required. A copy of the safeguards is available at hay@leadl.ai.

7. Retention

7.1. We keep personal data no longer than necessary for the purposes described. Sourced candidate profiles with no engagement and no other legal basis are automatically deleted after 365 days. Customer-instructed processing follows the customer’s retention settings and our agreement with them. Suppression identifiers (see 9.4) are retained to honour opt-outs.

8. Candidate Privacy Notice (Article 14)

Who we are: AI LEADPLATFORM, S.L. (CIF B75627067, Calle Consell de Cent, 38, 08014 Barcelona, Spain); data protection contact hay@leadl.ai.

What data we hold about you: professional/vocational information — your name; role, skills, experience and education; links to your professional and public profiles and work outputs; your city/region; and professional contact details where you have made them public.

Where we got it: publicly accessible sources such as professional networking sites, developer/portfolio platforms, public professional directories, and licensed data vendors.

Why and on what basis: to connect qualified professionals with relevant job opportunities and to enable our customers to recruit efficiently — based on our legitimate interests (Art. 6(1)(f)). We limit our collection to role-relevant professional information.

Who sees it: our business customers (recruiters/employers) who use the Platform, and our service providers.

How long: until you object or ask us to erase it, or automatically after 365 days of no engagement.

Your rights: access, rectification, erasure, restriction, portability, and — importantly — the right to object to our processing (Art. 21). You can exercise all of these, including a one-click removal, at hay@leadl.ai (no account needed) or via hay@leadl.ai. You may also lodge a complaint with the Spanish supervisory authority, the Agencia Española de Protección de Datos (AEPD), www.aepd.es, or with your local supervisory authority.

9. Your rights and how to exercise them

9.1. Under the GDPR and the LOPDGDD you have the rights of access (Art. 15), rectification (16), erasure (17), restriction (18), portability (20), objection (21), the right not to be subject to solely automated decisions (22), and — where processing is based on consent — the right to withdraw consent at any time. You may also complain to the Agencia Española de Protección de Datos (AEPD), C/ Jorge Juan 6, 28001 Madrid, www.aepd.es.

9.2. Requests can be made to hay@leadl.ai. We respond within one month (extendable by two months for complex requests), free of charge in ordinary cases.

9.3. Where we act as a processor, we forward requests to the relevant customer-controller and assist them; the customer is responsible for the substantive response.

9.4. Opt-out and suppression. When you object or ask for erasure of sourced data, we delete the active record and retain only a minimal hashed identifier on a suppression list, solely to ensure we do not re-source or re-contact you. We recognise Global Privacy Control signals.

10. Security

10.1. We implement appropriate technical and organisational measures (Art. 32), including access control, encryption in transit, logging, backups, and an incident-response process, and we notify supervisory authorities and affected individuals of personal-data breaches where required (Arts. 33–34).

11. Changes and contact

11.1. We may update this Policy; the current version is published at recruit.leadl.ai. Material changes will be communicated.

11.2. Questions and requests: hay@leadl.ai.