Legal

recuut Privacy Policy

Effective date: Aug 13, 2026

This Privacy Policy describes recuut’s processing activities as of its effective date. It explains how recuut processes personal data when you visit our website, use our platform, APIs or dashboard, take part in a recuut-enabled transaction, or contact us.

Who is recuut?

recuut is a trading name of HighStakes Ventures Studio B.V., a Dutch private limited company registered with the Dutch Chamber of Commerce under number 42125698. Our registered address is Lucellestraat 19 3, 1055 HT Amsterdam, the Netherlands.

recuut provides software infrastructure that helps businesses configure access to paid digital resources and coordinate related transaction records. recuut is a technology provider, not a bank, licensed payment institution, financial institution, custodian or wallet provider.

What is recuut responsible for?

recuut is the controller for personal data we use for accounts, organization administration, security, service operation, transaction integrity, support, billing and our own legal obligations.

A business customer may also submit personal data for its own purposes. When we process that data only on the customer’s documented instructions, the customer is the controller and recuut is its processor. The customer’s privacy notice and our data processing agreement govern that processing.

Third-party websites, wallets, payment services, blockchains and applications have their own privacy practices. This Policy does not govern them, even when they connect to recuut.

What personal data does recuut process?

Depending on how you use recuut, we may process:

  • Account data, such as your name, email address, profile, sign-in method, verification status, sessions, invitations and account-recovery information. If you use Google sign-in, we receive the account information Google makes available for authentication; we do not receive your Google password.
  • Organization and service data, such as your organization, membership and role, administrator activity, resource and pricing configuration, API-key metadata, environment, usage and operational events.
  • Transaction data, such as payer or wallet identifiers, full payment-card numbers and other payment-card details where applicable, payment requirements, amount, currency or asset, network, authorization and transaction status, timestamps, provider responses, transaction hashes, settlement evidence, receipts, refunds, disputes and reconciliation records.
  • Technical data, such as IP address, device and browser information, pages and features used, request and response metadata, security events, essential cookies, preference storage, analytics events and error reports.
  • Business and communication data, such as company, registration, tax, representative, billing or payout details where needed, and support requests, feedback, correspondence, invoice and email-delivery records.

recuut is not designed to receive full payment-card numbers, private wallet keys, seed phrases or unrelated sensitive personal data. Please do not send them through general fields, resource metadata or support messages.

Depending on the services you use, recuut may process full payment-card numbers and manage private wallet keys where required to provide payment or wallet functionality. Please do not send seed phrases or unrelated special-category personal data through general fields, resource metadata or support messages.

Where does recuut obtain personal data?

We obtain personal data directly from you; from your organization, its administrators or a customer integration; from your use of recuut; from identity, hosting, email, analytics, monitoring and transaction providers; and, where relevant, from public blockchain networks and explorers.

Where identity or KYC verification is required, we may use an independent verification provider. Depending on the integration, the provider may collect identity documents directly, while recuut receives only verification status or results.

Why does recuut use personal data?

We process personal data only when we have a legal basis. Depending on the activity, we use it:

  • to provide and administer recuut, authenticate users, manage roles and API access, support transactions and deliver support, where necessary to perform a contract or take requested pre-contract steps;
  • to secure recuut, prevent misuse and fraud, investigate incidents, reconcile records, improve reliability and defend legal claims, based on our legitimate interests and those of customers and users;
  • to bill customers, maintain business records and meet tax, accounting, sanctions, court-order and other legal duties, where required by law or necessary to perform a contract;
  • to analyze service performance and usage and develop recuut, based on our legitimate interests, using aggregated or de-identified data where practical; and
  • to send service messages and, where permitted, marketing or analytics communications, based on contract, legitimate interests or consent as applicable. You can withdraw consent at any time without affecting earlier lawful processing.

We do not use private customer data to train general-purpose AI models unless we first disclose that use and establish an appropriate legal and contractual basis.

Does recuut share or transfer personal data?

We share personal data only where needed for the purposes above. Recipients may include the relevant customer organization and its administrators; cloud, database, content-delivery and backup providers such as Amazon Web Services; Google for sign-in and website analytics; Amazon Simple Email Service for email delivery; Sentry for error monitoring; payment facilitators, wallet infrastructure and blockchain networks involved in a supported transaction; professional advisers, auditors or insurers; a buyer or investor in a corporate transaction; and authorities where required by law or necessary to protect rights, security or safety.

We do not sell personal data or share it for cross-context behavioural advertising.

Some providers may process personal data outside the European Economic Area. Where required, we use an adequacy decision, the EU Standard Contractual Clauses, supplementary measures or another lawful transfer mechanism. Contact us if you want more information about safeguards relevant to your data.

How long does recuut keep personal data?

We keep personal data only for as long as needed to provide recuut, maintain security and transaction integrity, comply with law and resolve disputes. The period depends on the type of data, whether an account or customer relationship remains active, legal recordkeeping duties, applicable limitation periods and whether records are needed for fraud, security, support or claims.

When data is no longer needed, we delete or anonymize it. Backups may retain deleted data for a limited recovery cycle. We may retain data longer when required by law, litigation, a security incident or fraud investigation, and may keep irreversibly de-identified or aggregated information.

Does recuut use cookies or automated decisions?

The recuut application uses essential cookies or similar storage to sign you in, protect sessions and remember requested preferences. Our public website uses Google Analytics to understand page views and selected interactions; Google Signals and advertising personalization are disabled in our current configuration. We rely on consent for non-essential analytics where consent is required, and on legitimate interests only where the law permits this without consent. The public website does not currently use non-essential analytics cookies or similar tracking technologies. Browser settings can block or delete cookies, but blocking essential cookies may prevent parts of recuut from working.

We use automated technical rules for authentication, authorization, rate limiting, payment-evidence validation and fraud or security signals. We do not currently use solely automated processing to make decisions about individuals that produce legal or similarly significant effects under the GDPR.

What should you know about public blockchains?

Public blockchains are operated by distributed networks, not by recuut. Wallet addresses, transaction hashes, amounts and related data written to a public blockchain may be visible globally and may be impossible for recuut to erase or correct. We can update our own off-chain records where appropriate, but we cannot alter a public blockchain.

How does recuut protect personal data?

We use technical and organizational measures designed to protect personal data, including access controls, organization and environment scoping, secure transport, protected credential storage, audit records and data-minimizing monitoring. No system can eliminate every security risk. If you believe your account or data is at risk, contact [email protected] promptly.

What rights do you have?

Subject to the conditions in applicable law, you may have the right to:

  • access your personal data and information about how it is used;
  • correct inaccurate or incomplete personal data;
  • request deletion or restriction of processing;
  • object to processing based on legitimate interests or for direct marketing;
  • receive data you provided in a portable format where the portability right applies; and
  • withdraw consent and lodge a complaint with a supervisory authority.

Email [email protected] to exercise a right. We may verify your identity and ask you to clarify the request. Rights are not absolute; we may keep or continue using data where the law permits or requires it, including for transaction records, fraud prevention and legal claims.

If we process your data only on behalf of a customer, please contact that customer first. In the Netherlands, you may complain to the Autoriteit Persoonsgegevens. You may also contact the supervisory authority where you live or work, or where you believe an infringement occurred.

Does recuut process children’s data?

recuut is designed for business users and is not directed to children. Please do not provide children’s personal data through recuut. If you believe this has happened, contact [email protected].

How can you contact recuut?

Privacy and security enquiries: [email protected]

Controller: HighStakes Ventures Studio B.V., trading as recuut

Postal address: Lucellestraat 19 3, 1055 HT Amsterdam, the Netherlands

KVK number: 42125698

How will recuut update this Policy?

Our services will evolve, and we may update this Policy when our products, data practices, service providers or legal obligations change.

We will publish the updated Policy with a new effective date. If a change materially affects how we use personal data or your rights, we will provide additional notice where appropriate or required by law, for example by email or through the service, before the change takes effect.

Where a new processing activity requires consent, we will request that consent separately. Earlier versions are available by contacting [email protected].