At RecXchange, your trust is our priority. We're committed to protecting your personal data and operating in full compliance with UK GDPR, EU GDPR, and other applicable data protection laws globally. This Privacy Policy explains how we collect, use, share, and safeguard your personal data, and outlines your rights under relevant data protection laws.
1. Who We Are
RecXchange is a global recruiter-to-recruiter collaboration platform operated by RecXchange Portal LLC, a company registered in Dubai, United Arab Emirates (Trade Licence No. 1508955). Our platform enables independent recruitment professionals to connect, share vacancies and candidates, and enter into split-fee arrangements in a trusted network.
While headquartered in the UAE, our services are governed by the laws of England and Wales for consistency, as stated in our Terms & Conditions.
RecXchange Portal LLC is the data controller responsible for your personal data in connection with our services.
2. What Personal Data We Collect
We only collect the personal information necessary to provide and improve our services. This may include:
- •Identity and Contact Data: Your name, business or personal contact details (email address, telephone number, physical address).
- •Professional Information: Your company or agency name, job title, and LinkedIn profile URL (used to verify your role in the recruitment industry).
- •Financial and Transaction Data: Payment or billing information such as credit card details or bank account information (for subscription payments, commission disbursements or split-fee transactions).
- •Profile and Membership Data: Information you provide when registering or filling out your profile on RecXchange (e.g. business specialties, regions, and any content you upload).
- •Candidate/Client Data (Third-Party Personal Data): Details of candidates or client contacts that you choose to share on the platform. You must ensure you have the right and consent to share this data.
- •Communications: Records of our correspondence with you and any information you submit through forms or messages on the platform.
- •Usage Data: Technical and usage information when you use RecXchange, such as log-in times, pages viewed, search queries, IP address, browser type, and operating system.
- •Marketing Preferences: Your preferences for receiving marketing or updates from us (only collected if you opt-in).
We do not intentionally collect any sensitive personal data (also known as special category data, such as information about health, race, religion, or biometrics) unless it is absolutely necessary and you have explicitly consented. We also do not knowingly collect data from anyone under 18.
3. How We Collect Personal Data
We collect personal data through various channels, including:
- •Directly from You: When you fill out our online registration forms, update your profile, submit a candidate or vacancy, contact us via email/phone, or communicate through the platform.
- •Through Our Website: Via cookies and analytics tools that track your usage of our site.
- •Referrals or Partnerships: If you were invited to the platform by another Member or through a referral program, we may receive basic information about you from the referrer (with your consent).
- •Newsletters or Events: If you sign up for our newsletter or attend a RecXchange event/webinar, we may collect your name and contact details.
No Third-Party Data Purchasing
All personal data we process is obtained directly from you or your authorized actions. We do not buy, rent, or scrape personal data from third-party sources.
4. How We Use Your Personal Data
We use your personal data to run and improve the RecXchange platform and to provide our services to you. Specifically, we use data for the following purposes:
- •To register and identify you as a Member: Creating your account and verifying your credentials so you can access the platform.
- •To facilitate recruiter collaborations: Enabling introductions, vacancy postings, candidate profile sharing, and communications between Members for potential split-fee placements.
- •For communication and support: To send service messages, respond to your inquiries, provide customer support, and keep the platform running smoothly.
- •To provide and record payments and transactions: Using your data for subscription billing, invoicing, commission splits and reconciliation.
- •To facilitate secure fee transfers (Escrow service): If you opt to use our escrow protection service (once available), we will use relevant data to enable that transaction.
- •To improve our platform and services: Analyzing usage data and feedback to develop new features, enhance user experience, and ensure the platform's effectiveness.
- •For marketing (with consent): Sending you newsletters, industry updates, new feature announcements, or promotions only if you have agreed to receive them.
- •To comply with legal and tax obligations: Fulfilling our duties under applicable laws, such as maintaining transaction records for tax auditing.
- •To ensure platform integrity and enforce our terms: Monitoring and using data to prevent fraudulent, unauthorized or harmful activities on RecXchange.
- •To support dispute resolution and legal processes: In the event of a dispute between Members or a legal claim related to platform use, we may process and retain relevant data to help resolve the issue.
We do not use your personal data for any kind of automated decision-making or profiling that has legal or significant effects on you without your explicit consent.
5. Legal Bases for Processing
We process personal data only when we have a valid legal basis under the GDPR and equivalent laws. Under Article 6 of the UK GDPR, the primary lawful bases we rely on are:
- •Consent: We will ask for your consent in situations where it is required, for example, when you subscribe to marketing emails. You have the right to withdraw consent at any time.
- •Contract: We process data that is necessary to perform our contract with you — i.e., to provide the RecXchange services you signed up for.
- •Legal Obligation: If we have a legal duty to process or disclose your data, we will do so. For instance, complying with tax law or responding to a valid legal warrant.
- •Legitimate Interests: We may process your data for the purposes of our legitimate interests (or those of a third party) provided that your rights and interests do not override those interests. Our legitimate interests include maintaining the security of the platform, preventing fraud, and improving our services.
6. Consent and Marketing Communications
We will only send you marketing communications if you have given us clear, affirmative consent to do so. At the point of collecting your contact information, we will ask you to confirm that you wish to receive such emails or updates from us.
You Have Full Control
If you choose to subscribe, you can withdraw your consent at any time:
- •Click the "unsubscribe" link in any marketing email
- •Contact us at privacy@recxchange.com
- •Change your preferences through your account settings
Even if you opt out of marketing, we may still send you essential service or account communications as these are not promotional in nature.
We do not sell or share your personal data with third parties for their own direct marketing purposes without your consent.
7. Data Sharing and Disclosures
We Do Not Sell Your Data
We value your privacy and share personal data only when necessary. We do not sell or rent your personal information to third parties.
However, we may disclose your data to the following categories of recipients in order to run our business and comply with our obligations:
Service Providers
Trusted third-party companies that help us operate RecXchange:
- •Payment Processors (e.g. Stripe, PayPal) for secure processing of subscription payments or escrow transactions.
- •Escrow Agent or Payment Intermediary: If you use the optional escrow service, we will share necessary information with the neutral escrow provider.
- •Cloud Hosting and IT Infrastructure: We use reputable cloud servers and IT providers to host our platform and data.
- •Analytics and Marketing Tools: We may utilize tools or platforms (e.g., Google Analytics, email marketing services) that process data under our instructions.
Other Members of RecXchange
By the nature of the platform, certain information you post may be visible to other approved Members. For example, if you share a job vacancy or candidate profile on RecXchange, those details will be viewable by other recruiters in the network as part of the collaboration workflow. Your basic profile information (name, agency, location, and verified status) is visible to other Members so that they know who they are collaborating with.
Legal Obligations and Safety
We may disclose personal data when required to do so by law or when that disclosure is reasonably necessary to: (i) comply with a legal obligation, regulatory requirement, or governmental request; (ii) enforce our Terms & Conditions or other agreements; or (iii) protect the rights, property, or safety of RecXchange, our Members, or the public.
Business Transactions
In the unlikely event that RecXchange undergoes a major business transaction, such as a merger, acquisition, corporate reorganization, or sale of assets, your personal data might be transferred to the new owner or successor entity as part of that deal. If this happens, we will ensure the new owners use your data in line with this Privacy Policy and applicable law.
All third parties that process personal data on our behalf are contractually obligated to uphold strict confidentiality and security standards in line with GDPR and this Privacy Policy.
8. Member Responsibilities (Candidate Data & Compliance)
RecXchange takes data protection seriously, and we require our Members to do the same. If you, as a Member, upload or share personal data about other individuals (for example, candidate CVs or client contact details), you must ensure you have a lawful basis to do so and that you handle that data responsibly.
➤ Obtain Candidate Consent Before Sharing
You must have the candidate's explicit permission before sharing any candidate's personal information on RecXchange. Prior to uploading or forwarding a candidate's CV, contact details, or any identifiable data to another recruiter through our platform, you should inform the candidate and get their clear consent. Do not submit any candidate's data to RecXchange without their knowledge and agreement.
➤ Comply with Data Protection Laws
You are responsible for handling all personal data accessed through RecXchange in compliance with applicable data protection laws, including UK GDPR, EU GDPR, and any analogous laws in other jurisdictions. Any personal data you obtain via the platform must be kept confidential and used only for the intended recruitment purpose for which it was shared.
➤ No Circumvention or Misuse of Data
In line with our non-circumvention rules, you must not use personal data obtained via RecXchange to go around another Member. If another recruiter introduces a candidate or client to you through the platform, you should not later approach that candidate or client independently for any other business without the original introducer's prior consent. Using someone's data to cut out the person who provided it is a serious breach of trust and of our Terms.
➤ Consequences of Misusing Personal Data
Any misuse of personal data on the platform is taken very seriously by RecXchange. We reserve the right to remove and ban Members who engage in such behavior. In addition, you could face legal consequences under applicable data protection laws for unauthorized use of personal information.
In summary, treat any personal data you access through RecXchange with the same care you would expect others to treat your candidates' or clients' data. Obtain consent, use it only for the intended collaboration, and do not betray the trust of introductions.
9. International Data Transfers
RecXchange operates a global platform, which means personal data may be transferred to or stored in different countries. We are headquartered in the UAE, and we use cloud infrastructure that may be located in the United Kingdom, the European Economic Area (EEA), the United Arab Emirates, or other jurisdictions. Regardless of where data is processed, we apply strong protections to it.
Standard Contractual Clauses
For transfers of personal data out of the UK/EEA, we rely on approved safeguards like the European Commission's or UK's Standard Contractual Clauses (SCCs). These are legal contracts that require the recipient of the data in a third country to protect the data to EU/UK privacy standards.
Adequacy Decisions
Where possible, we may host or transfer data to countries that have been officially recognized by the UK Government or European Commission as having adequate data protection laws. This means your data gets essentially the same protection as in the UK/EU.
Other Safeguards
In some cases, we might use Binding Corporate Rules or other mechanisms approved under GDPR to legitimize data flows. We also employ technical measures (like encryption in transit and at rest) as an additional layer of security for international data.
By using RecXchange, you acknowledge that your personal data (and any candidate data you input) may be transferred and stored across international borders as needed for the platform's functionality. If you require more information about our international data transfer practices or need a copy of the relevant safeguards (e.g. SCCs), please contact us.
10. Data Retention
We retain personal data only for as long as it is necessary to fulfill the purposes described in this policy, or as required by law or legitimate business needs. Retention periods will vary depending on the type of data and the context of your relationship with us:
Active Members
If you are an active Member, we retain your personal data for the duration of your membership. Your profile and related data will be kept as long as you have an account with us and have not requested deletion.
Former Members
If you choose to leave the platform or your membership is terminated, we generally will retain your data for up to 7 years after the end of the membership. This retention period allows us to meet any legal, accounting, or reporting requirements and to have information available in case of any later disputes or inquiries.
Prospective Members and Inquiries
If you contact us but do not ultimately sign up, we may keep your information for up to 12 months. If you haven't become a Member in that time, we will delete or anonymize your inquiry data.
Candidate/Placement Data
If you have engaged in a split-fee placement via RecXchange, details of that transaction may be retained as part of the business record of the deal. We generally align this with the 7-year retention for former members or longer if required by contract or law.
After the applicable retention period ends, we will either securely delete or anonymize your personal data. "Anonymize" means we strip out personal identifiers so that the information can no longer be linked to you.
11. Data Security
We employ strong security measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. We understand that your data is sensitive and we treat it with the utmost care. Our security program includes:
🔐 Encryption
All communications with our website are protected by SSL/TLS encryption (HTTPS). Sensitive data is also encrypted at rest in our databases or servers.
🏢 Secure Infrastructure
We use reputable cloud hosting providers who implement robust physical and network security. Our servers are kept in controlled facilities, and we apply firewalls and monitoring to prevent intrusions.
👥 Access Controls
Personal data is accessible only by those at RecXchange who need it to perform their job (on a "need-to-know" basis). Employee and contractor access is protected with strong authentication.
📚 Staff Training
Our team members are trained in data protection best practices and are bound by confidentiality obligations. We maintain internal policies to ensure we handle data in line with GDPR and other regulations.
🔍 Testing and Auditing
We conduct regular security audits and risk assessments. Our systems are kept up-to-date with security patches. We also utilize monitoring tools to detect suspicious activities.
⚠️ Breach Response
In the unlikely event of a data breach that could pose a risk to your rights or freedoms, we will notify you and the appropriate supervisory authority within 72 hours as required by law.
Your Role in Security
You also play a part in security. Please keep your account credentials (username and password) confidential. Notify us immediately at support@recxchange.com if you suspect any unauthorized use of your account. We will never ask you for your password via email, so beware of phishing attempts.
12. Your Rights
As an individual using RecXchange, you have a number of important rights regarding your personal data. We respect and uphold these rights, which are provided under the UK GDPR, EU GDPR, and similar data protection laws.
✓ Be Informed
You have the right to clear and transparent information about how we use your data. This Privacy Policy fulfills that right.
✓ Access Your Data
You can request a copy of the personal data we hold about you.
✓ Rectification
If any personal data we have is inaccurate or incomplete, you have the right to have it corrected.
✓ Erasure (Right to be Forgotten)
You can ask us to delete your personal data in certain circumstances.
✓ Restrict Processing
You have the right to request that we limit the processing of your data in certain situations.
✓ Data Portability
You can request to receive your data in a structured, commonly used, machine-readable format.
✓ Object to Processing
You have the right to object to certain types of processing, notably for direct marketing.
✓ Not Be Subject to Automated Decisions
You have rights related to automated decision-making and profiling.
How to Exercise Your Rights
To exercise any of these rights, please contact us at privacy@recxchange.com with your request. We will respond within one month (30 days) of receiving your request, as required by GDPR.
These rights are generally free to exercise. We will not charge you a fee for handling a reasonable request.
Right to Lodge a Complaint
If you believe we have not handled your personal data properly or fulfilled your rights, you have the right to lodge a complaint with a data protection supervisory authority. Our lead supervisory authority is the UK Information Commissioner's Office (ICO). You can contact the ICO at 0303 123 1113 or through their website (ico.org.uk).
13. External Links
Our platform or website may contain links to websites, plugins, or services that are not operated by RecXchange. For example, a Member could share a LinkedIn profile link or you might see a link to an article or a third-party service.
This Privacy Policy does not cover those external websites. We are not responsible for the content, security, or privacy practices of any third-party sites. We strongly encourage you to review the privacy policies of every website or service you interact with outside of RecXchange, especially before submitting any personal data to them.
If you believe a link on our platform is pointing to a malicious or inappropriate site, please notify us so we can take action if necessary.
14. Updates to This Privacy Policy
We may update or revise this Privacy Policy from time to time to reflect changes in our business, legal obligations, or the services we offer. If we make material changes (for example, changing how we use personal data or introducing new purposes), we will notify you in a timely manner and as required by law.
Notification may be done via email to our Members, an in-app alert, or an announcement on our website. We will also update the "Last updated" date at the top of this Policy.
We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information. If you continue to use RecXchange after updates to the Policy take effect, we will consider that as acceptance of the new terms to the extent permitted by law.
All prior versions of this Privacy Policy will be archived and available upon request for your reference. We maintain transparency about our privacy practices.
15. Contact Details
We welcome any questions, concerns, or requests regarding this Privacy Policy or your personal data.
RecXchange Portal LLC
Dubai, United Arab Emirates
Trade Licence No: 1508955
Last updated: March 9, 2026