AI Transparency Statement

Jaicob B.V.

Version: 1.0, August 2026

1. About this statement

Jaicob B.V. ("Jaicob", "we", "our", or "us") operates an AI-powered recruitment platform. Artificial intelligence is at the core of what we build, and we believe that everyone who comes into contact with our platform has the right to know when AI is involved, what it does, what it does not do, and who remains responsible.

This statement explains, in plain language:

  • which parts of our platform use AI;
  • how we make sure you always know when you are interacting with AI;
  • how humans stay in control of decisions that affect candidates;
  • what our AI systems are never allowed to do; and
  • what rights you have and how to exercise them.

This statement is written for three audiences: candidates whose applications are handled through our platform, the companies that use our platform (our clients), and anyone else who interacts with our AI features. It supplements, and should be read together with, our Privacy Policy and Terms and Conditions.

This statement describes how our platform is designed and operated as of the version date above. It is provided for transparency purposes and does not constitute legal advice.

2. Our role under the EU AI Act

The European Union has adopted the AI Act (Regulation (EU) 2024/1689), a law that regulates how AI systems may be developed and used. AI systems used for the recruitment and selection of people are classified as "high-risk" under Article 6(2) of the AI Act, read together with Annex III, point 4(a). This is because recruitment decisions can have a significant impact on people's lives and opportunities.

Our platform falls within this category. Under the AI Act, Jaicob acts as the provider of these AI systems: we develop them, we document them, and we are responsible for designing them so that they can be used safely, transparently, and under meaningful human oversight.

The companies that use our platform to recruit (our clients) act as deployersunder the AI Act. They decide how the platform is used in their hiring process and carry their own obligations, such as informing candidates and ensuring that qualified people oversee the system's output. We provide our clients with detailed instructions for use and compliance documentation to support them in this role.

As a provider of high-risk AI systems, we maintain, among other things:

  • a risk management process covering the lifecycle of our AI features;
  • technical documentation describing how our AI systems work;
  • data governance procedures for the data used by our AI features;
  • automatic logging of AI system activity (see Section 8);
  • human oversight mechanisms built into the product (see Section 5); and
  • a quality management system for the development and maintenance of our AI features.

3. Where our platform uses AI

Not everything in our platform is AI. Many features are ordinary software: an applicant tracking system, a CRM, scheduling, and messaging. The following features do use AI:

  • AI Sourcing: searching public and licensed professional data sources to identify potential candidates that match a vacancy.
  • AI Matching and screening:comparing a candidate's profile or application against the requirements of a vacancy and producing a match score, screening summary, or ranking as decision support for recruiters.
  • AI Agents: software agents that carry out recruitment tasks such as drafting and sending outreach messages, following up with candidates, answering candidate questions, and preparing shortlists, within limits and approval rules configured by the client.
  • AI interviews and conversations: structured screening conversations with candidates by chat, SMS, or voice call, in which an AI system asks questions and records answers.
  • Copilot:an AI assistant for recruiters that answers questions about their own data and performs tasks at the recruiter's request.
  • Document understanding: extracting structured information from documents such as CVs and resumes, so that candidates and recruiters do not have to re-type it.

AI outputs in our platform are decision support. They inform recruiters; they do not replace them. Section 5 explains how this is enforced.

4. You will always know when you are interacting with AI

The AI Act (Article 50) requires that people are informed when they interact with an AI system. We build this disclosure into the product itself, so that it does not depend on manual steps:

  • Conversations and chat: our AI agents are instructed to identify themselves as AI. They are never allowed to claim to be a human being, to use a fake human identity, or to deny being an AI system when asked.
  • Voice calls: if an AI voice feature is used to call you, you are told at the start of the call that you are speaking with an AI system, before the substantive conversation begins.
  • Text messages (SMS): AI-assisted text message conversations disclose the involvement of AI, and you can stop them at any time by replying STOP.
  • Email outreach: messages drafted or sent by AI agents are sent on behalf of a named, real recruiting organisation, and our AI identifies itself as an AI assistant when this is asked or relevant.

These disclosure rules are not region-dependent. We apply them to all conversations on our platform, regardless of where you are located, because we consider them good practice everywhere (and because similar rules exist outside the EU, such as the California "B.O.T." disclosure law).

You are never required to complete a conversation with an AI system. If you prefer to speak with a human, you can say so at any point, or contact the company that reached out to you directly.

5. Humans remain in control

The AI Act (Article 14) requires that high-risk AI systems are designed so that humans can effectively oversee them. The GDPR (Article 22) additionally protects people against decisions based solely on automated processing that significantly affect them. Our platform is built around both principles:

  • No fully automated hiring or rejection decisions. Match scores, screening results, and rankings are advisory. The decision to reject, disqualify, hire, or advance a candidate is made by people, not by the platform.
  • Mandatory human approval for negative decisions. For clients operating under EU rules, actions that negatively affect a candidate, such as disqualifying a candidate or rejecting an application, always require explicit approval by a human recruiter before they take effect. This safeguard is enforced in our software and cannot be switched off by configuration.
  • Configurable approval rules for other actions. Clients control which additional agent actions require human approval, and can review, approve, or refuse each proposed action individually.
  • Full visibility of agent activity. Every run of an AI agent, and every individual step and tool action within that run, is recorded and visible to the client, so recruiters can see exactly what an agent did and why.
  • Interruptibility. Clients can pause or stop AI agents, and candidates can end AI conversations at any time.

We also warn our clients explicitly against "automation bias": the tendency to accept an AI suggestion without genuine review. Approving an AI proposal is a real decision, and our documentation and product design treat it as one.

6. What our AI systems never do

Some uses of AI are prohibited outright by the AI Act (Article 5), and others are excluded by our own design choices. Our platform does not, and is not allowed to:

  • Infer emotions. We do not use emotion recognition or emotion inference in screening, scoring, interviews, or any other recruitment feature. Emotion inference in the workplace context is prohibited by Article 5(1)(f) of the AI Act, and no such analysis exists anywhere in our platform.
  • Use protected personal characteristics in AI evaluation. Attributes such as gender, nationality, and date of birth are deliberately withheld from the information our AI evaluation features receive. Our AI features are also instructed not to infer such characteristics.
  • Perform biometric categorisation or identification. Voice conversations are processed for transcription and conversation purposes only. We do not create voice prints, do not identify people by their voice, and do not derive personal characteristics from biometric data.
  • Score people socially. We do not evaluate people based on social behaviour or personal characteristics unrelated to the specific vacancy.
  • Pretend to be human. As described in Section 4, our AI never impersonates a human being.
  • Make final decisions about people on its own. As described in Section 5.

7. Data quality, fairness, and bias monitoring

AI systems can reproduce biases present in data. We take this risk seriously, because in recruitment it translates directly into unfair treatment of real people. Our measures include:

  • Excluding sensitive attributes from evaluation, as described in Section 6, so that AI assessments are based on job-relevant information such as skills, experience, and qualifications.
  • Structured, vacancy-specific evaluation. Match and screening features assess candidates against the requirements of the specific vacancy, not against generic profiles.
  • Retaining anonymised decision records for bias monitoring.We keep records of AI-assisted assessments in an anonymised form, from which directly identifying information has been removed, so that outcomes can be analysed for signs of disparate impact over time. Because these records are anonymised, they can be retained for monitoring and audit purposes even after a candidate's personal data has been deleted.
  • Ongoing quality measurement. We measure the behaviour of our scoring and screening features on an aggregate basis and investigate anomalies.
  • Supporting formal bias audits. Clients subject to bias audit obligations (for example under New York City Local Law 144) can obtain a structured export of anonymised assessment data from us for use by an independent auditor.

8. Logging and record keeping

The AI Act requires high-risk AI systems to automatically record events while they operate (Article 12) and requires providers to keep these logs for at least six months (Article 19). Our platform does this by design:

  • every AI agent run is recorded, including each individual step, tool action, and outcome within the run;
  • AI-assisted assessments and the approval or refusal of proposed agent actions are recorded;
  • logs are retained for at least six months, and longer where the client's configuration or applicable law requires it; and
  • logs are available to the client for inspection and to supervisory authorities where the law requires it.

Retention of logs is balanced against data protection law: where logs contain personal data, they fall under the retention and deletion rules described in our Privacy Policy, and records kept longer for audit purposes are anonymised.

9. The AI models we use

Our platform is built on large language models and other machine-learning models from established third-party providers (so-called general-purpose AI models), combined with our own logic, guardrails, and evaluation layers. About these models:

  • we contract with model providers under data processing agreements, as required by Article 28 GDPR;
  • candidate and client data submitted to these models through our platform is not used by the model providers to train their models, based on the contractual commitments in place;
  • we host and process data in the European Union wherever the required capability is available in the EU, and apply the international transfer safeguards described in our Privacy Policy where it is not; and
  • we select, configure, and test the models we use, and we remain responsible for how they behave within our platform. An up-to-date list of our subprocessors, including AI model providers, is available to clients as part of our data processing agreement.

10. Your rights as a candidate

If your application or profile was handled using our AI features, you have the following rights:

  • The right to know.The company you applied to (or that contacted you) must inform you that AI is used in its recruitment process. Our platform's built-in disclosures (Section 4) support this, and our client documentation requires it.
  • The right to an explanation. Under Article 86 of the AI Act and Article 22(3) GDPR, you can request a clear and meaningful explanation of the role AI played in a decision that affected you. Our platform can generate a written explanation of the main elements that contributed to an AI-assisted assessment, which the recruiting company can share with you.
  • The right to human involvement. You can ask for a decision to be reviewed by a human being. As described in Section 5, negative decisions already require human approval on our platform; on request, the recruiting company must also be able to explain and reconsider a decision with human involvement.
  • The right to opt out of AI conversations. You may decline an AI interview or AI voice call and ask for a human alternative. Declining an AI conversation may affect timing, but the recruiting company remains responsible for treating your application fairly.
  • Your data protection rights. Access, rectification, erasure, restriction, portability, and objection, as described in our Privacy Policy.

Who to contact.The company you applied to decides how your data is used and is your first point of contact for these rights (it is the "data controller" under the GDPR and the "deployer" under the AI Act). If you contact us instead, we will help route your request and provide the recruiting company with the technical information needed to answer it. We will never leave a candidate's rights request unanswered because of this division of roles.

Complaints. You can lodge a complaint about the use of your personal data with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, www.autoriteitpersoonsgegevens.nl) or the supervisory authority in your own country. Complaints about the use of an AI system as such can be lodged with the market surveillance authority designated in your country under the AI Act.

11. What we expect from our clients

Compliance in recruitment AI is shared work. As deployers, our clients must use the platform in line with our instructions for use. In particular, clients must:

  • inform candidates that AI is used in their recruitment process, before it is used on them;
  • inform their own employees and employee representatives where required (Article 26(7) AI Act);
  • assign oversight of the platform to people with the competence, training, and authority to exercise it;
  • genuinely review AI proposals instead of approving them automatically;
  • use the AI features only for recruitment and selection, their intended purpose; and
  • keep logs and cooperate with candidates' rights requests as described above.

We publish detailed compliance documentation for clients, including instructions for use and a deployer checklist, in our client documentation portal at developers.jaicob.ai.

12. Security

AI features run on the same secured infrastructure as the rest of our platform: data encrypted at rest and in transit, strict access controls, EU-based hosting, and independent security certifications (including ISO 27001:2022). The full description of our security measures, breach procedures, and certifications is in our Privacy Policy.

13. Outside the European Union

Our platform is also used outside the EU, and AI rules differ per country and per state. Our approach is to apply our strictest safeguards, such as AI disclosure and human involvement in decisions, everywhere, and to support region-specific obligations where they exist. For example, we support bias audit data exports for clients subject to New York City Local Law 144, and our AI disclosure practices are consistent with the California B.O.T. Act. Clients remain responsible for verifying the rules that apply to their own hiring locations, and our documentation helps them do so.

14. Changes to this statement

We update this statement when our AI features change in a way that matters for transparency, when the law changes, or when we improve our practices. The version number and date at the top of this page always reflect the current version. Significant changes are announced to our clients; the AI Act's documentation requirements also oblige us to keep our instructions for use up to date.

15. Contact

Questions about this statement, or about how our platform uses AI, are welcome:

  • Jaicob B.V.
  • Burgemeester Stekelenburgplein 199, 5041 SC Tilburg, the Netherlands
  • Email: support@jaicob.ai
  • Chamber of Commerce (KvK): 92883761