Privacy Policy

Last updated: 14 October 2026 · Version 2.0

This Privacy Policy explains how Scaleo LLC ("Scaleo OS", "we", "us") processes personal data when you visit scaleo-os.com, use the Scaleo OS platform at app.scaleo-os.com, or contact us. Scaleo OS connects international engineering talent with employers in Germany and the Netherlands and with mobility partners such as immigration law firms and relocation agencies.

1. Who is responsible

The controller is Scaleo LLC, 8 The Green, Dover, DE 19901, United States. For all privacy questions and requests, write to privacy@scaleo-os.com.

EU representative under Article 27 GDPR: [to be inserted before launch].

2. What data we process

Talents

  • Account data: name, email address, phone number, password or Google sign-in identifier, country of residence.

  • Profile data: professional history, education, skills, tools, languages, certifications, CV, profile photo, salary expectations, availability, job preferences, nationality, date of birth, visa-related information you provide.

  • Documents you choose to upload, for example degree or language certificates.

  • Application data: applications, interview participation, offers and hiring outcomes.

  • Answers to questions about your working style and preferences.

Companies

  • Account and contact data of your users, company name, size, industry, location and branding content (logo, images, videos).

  • Job postings and hiring requirements, billing contact data, communication with talents, partners and administrators.

  • Calendar data if you connect Google or Microsoft Calendar (see section 10).

Partners

  • Organisation and contact data, service descriptions and availability.

  • Data of assigned mobility cases and related communication.

  • Bank details needed to pay out partner fees.

All users

  • Technical data: IP address, device and browser information, log data (time stamps, actions, system events) and security signals.

  • Cookies and similar technologies as described in section 9.

3. Identity verification and sanctions checks

Identity verification. Where verification is offered, we use Stripe Identity. Stripe processes the image of your identity document and a selfie, including biometric comparison, on the basis of your explicit consent (Art. 9(2)(a) GDPR). We do not store these images or biometric data. We store the verification status, the issuing country of the document and related non-biometric metadata.

Sanctions compliance. We do not offer Scaleo OS to persons who are in, or resident in, Cuba, Iran, North Korea, Syria, or the Crimea, Luhansk and Donetsk regions. To enforce this we ask for your country of residence and a declaration regarding these regions at registration, check the issuing country of your identity document, and block network traffic from the named countries. Registrations that indicate a restricted jurisdiction can be rejected or reviewed manually. Legal basis: legal obligation and our legitimate interest in complying with sanctions and export control laws (Art. 6(1)(c) and (f) GDPR).

4. Why we process data and on which legal basis

  • Creating and managing accounts, operating the platform, matching, applications, interviews, hiring, mobility cases, communication between users: performance of a contract (Art. 6(1)(b) GDPR).

  • Payments, invoicing and subscriptions: performance of a contract and legal obligations (Art. 6(1)(b) and (c)).

  • Security, fraud prevention, abuse prevention, system logs, platform stability: legitimate interest (Art. 6(1)(f)).

  • Improving the platform from aggregated usage data: legitimate interest (Art. 6(1)(f)).

  • Sanctions and other legal compliance: legal obligation (Art. 6(1)(c)).

  • Biometric identity verification and optional features that require it: consent (Art. 9(2)(a) and Art. 6(1)(a)). You can withdraw consent at any time, which does not affect earlier processing.

  • Marketing emails: only with your consent or where the law allows it, with an unsubscribe link in each message.

5. Matching, scores and AI-assisted features

Matching. Scaleo OS calculates scores for each pair of talent and job from 12 weighted factors with fixed weights. The platform shows four values: Fit Score, Visa Eligibility, Mobility Readiness and Salary Alignment. The scores support decisions. They do not decide on hiring. Every hiring decision is made by a person at the company. You may ask for an explanation or a human review of a score at privacy@scaleo-os.com.

AI-assisted features. Some features use AI models, for example reading an uploaded CV to pre-fill your profile, summarising profile information and drafting job descriptions. These requests go through the Lovable AI Gateway to Google Gemini models. For CV reading, the text of the CV you upload is sent to the model. You review and confirm the results before they are saved to your profile. We do not use personal data to train AI models ourselves.

6. What companies and partners see

Companies first see talent profiles in reduced form. Identifying details are released step by step as the hiring process moves forward. Full contact details are released only at an advanced stage of the process, at the offer or contract stage. When a company receives your data in the course of its own recruitment process, it processes that data as an independent controller under its own privacy notice. Deleting your Scaleo OS account does not delete data a company already holds in its own systems.

Mobility partners receive the data they need to handle the case that is assigned to them, for example your visa-related information and contact details.

7. Recipients and service providers

We share personal data with the following service providers, who process it on our behalf under data processing agreements, or, where they act independently, under their own terms:

  • Supabase: database, authentication, file storage and server functions. Region: EU (Ireland).

  • Lovable: application platform and AI gateway; Google: Gemini models via the gateway.

  • Cloudflare: network, security, DDoS protection and country-based access rules.

  • Stripe: payments and identity verification.

  • Resend with Amazon SES (EU region): sending of emails.

  • SignWell: electronic signature of contracts.

  • Google and Microsoft: sign-in with Google and calendar connection, if you use them.

  • n8n: workflow automation.

  • Termly: cookie consent management.

  • Framer: hosting of our marketing website.

We may also disclose data to authorities where the law requires it, to advisers under confidentiality obligations, and in connection with a business transfer such as a merger or sale. We do not sell personal data and we do not share it for advertising.

8. International transfers

Scaleo LLC is established in the United States and some of our service providers are located outside the European Economic Area. Where personal data is transferred to countries without an adequacy decision, we rely on the European Commission's Standard Contractual Clauses or on the EU-US Data Privacy Framework where the recipient is certified. You can request a copy of the safeguards at privacy@scaleo-os.com.

9. Cookies and similar technologies

The platform uses strictly necessary cookies and local storage for sign-in sessions, language and interface settings. Our payment provider Stripe may set cookies for fraud prevention. We do not use advertising cookies and no analytics tools that profile you on the platform. Our consent banner is provided by Termly. Details are in our Cookie Policy.

10. Google user data

If you sign in with Google, we receive your name, email address and profile picture. If a company connects Google Calendar, we request the calendar.events permission. If a company connects Microsoft Calendar, we request Calendars.ReadWrite, offline_access and User.Read. We use this access only to create, update and delete the interview events you schedule through Scaleo OS. We do not use calendar data for advertising, and we do not sell it. Access tokens are stored encrypted at rest and only our systems can use them. You can disconnect the calendar at any time in your settings, and we delete the tokens when you do, and when you delete your account.

Scaleo OS's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

11. How long we keep data

We keep your account data until you delete your account. When you delete it, we remove your personal data from our active databases. Billing records are not deleted but pseudonymised and kept for as long as tax and commercial law require. Backups are overwritten in the regular backup cycle. Operational and security logs are kept for limited periods. Data we need to defend legal claims or to prevent repeated abuse may be kept longer within the limits of the law.

12. Your rights

Under the GDPR you have the right to access your data, to have it corrected or erased, to restrict or object to its processing, to receive it in a portable format, and to withdraw consent at any time. You can exercise most rights in your account settings or by writing to privacy@scaleo-os.com. We answer within one month. You also have the right to complain to a data protection authority, for example in your country of residence or in the Member State of your workplace. If you live elsewhere, local rights may apply in addition.

13. Security

We use technical and organisational measures to protect personal data, including encryption in transit and at rest, role-based access and row-level access rules in the database. No system is completely secure. Please protect your sign-in details.

14. Children

Scaleo OS is for people aged 18 and over. We do not knowingly collect data from minors. If you think a minor has registered, write to us and we will delete the account.

15. Changes

We update this policy when our processing changes. The date at the top shows the current version. For material changes we notify registered users by email or in the platform.

16. Contact

Scaleo LLC, 8 The Green, Dover, DE 19901, United States
Email: privacy@scaleo-os.com

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