RMT Labs S.A. (“Skillbourg,” “we,” “us,” or “our”) operates Skillbourg.com, an AI-powered recruitment marketplace connecting job candidates with employers across Europe.
- Controller: RMT Labs S.A., 41 Rue Marie-Adélaïde, L-2128 Luxembourg. VAT: LU36102339.
- Data protection contact: gdpr@skillbourg.com
- General support: support@skillbourg.com
- Supervisory authority: Commission Nationale pour la Protection des Données (CNPD), 15 Boulevard du Jazz, L-4370 Belvaux, Luxembourg. You have the right to lodge a complaint with the CNPD at any time.
What Information We Collect
1.1 Information You Provide
When you register and use our platform, we collect: your name, email address, nationality, country of residence, phone number, work eligibility information, salary expectations, your CV, and any information you provide to our support team.
1.2 Your CV
Your CV may contain sensitive personal data (Art. 9 GDPR), such as information that could reveal ethnic origin, religious beliefs, health conditions, or other protected characteristics. We process your CV using AI to extract job-relevant information only.
We obtain your explicit consent for the processing of any sensitive data that may be present in your CV. This consent is:
- specific to the risk that CVs may contain special category data;
- obtained separately from your acceptance of our Terms and Conditions; and
- presented as a distinct choice during registration.
You may withdraw this consent at any time by contacting gdpr@skillbourg.com. Withdrawal will result in the deletion of your CV and associated profile data. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
1.3 AI-Generated Profile
When you upload your CV, we use AI to generate your candidate profile. You have the right to rectification of any inaccurate data — contact gdpr@skillbourg.com.
1.4 Information Collected Automatically
Usage data, device information (IP address, browser type). Analytics cookies are activated only after your consent via our cookie consent manager.
1.5 Company and Recruiter Data
Company account information and recruiter user details necessary to operate business accounts on the platform.
How and Why We Use Your Information
Candidates
| Purpose | Description | Legal Basis |
|---|---|---|
| Account management | Create and maintain your account | Contract — Art. 6(1)(b) |
| CV processing and profile generation | Use AI to generate your candidate profile from your CV | Contract — Art. 6(1)(b) |
| Sensitive data in CVs | Processing of any sensitive personal data present in your CV | Explicit consent — Art. 9(2)(a) |
| Match scoring | Show you fit scores for jobs | Contract — Art. 6(1)(b) |
| Candidate ranking | Rank applicants for recruiter review | Contract — Art. 6(1)(b) |
| Talent discovery | Allow recruiters to browse your profile if you opt in to talent discovery during registration | Consent — Art. 6(1)(a) |
| Platform administration | User management, security, and abuse prevention | Legitimate interest — Art. 6(1)(f) |
| Analytics | Website usage analysis (consent-only) | Consent — Art. 6(1)(a) |
| Communications | Verification emails, notifications | Contract — Art. 6(1)(b) |
Where we rely on legitimate interest, we have conducted a balancing test to ensure that your interests, rights, and freedoms do not override our legitimate interests. You may request information about these balancing tests by contacting gdpr@skillbourg.com.
Companies and Recruiters
| Purpose | Description | Legal Basis |
|---|---|---|
| Company account management | Create and maintain company accounts | Contract — Art. 6(1)(b) |
| Candidate data access | Profiles via applications and talent search | Contract — Art. 6(1)(b) |
| Tax and commercial records | VAT and registration data retention | Legal obligation — Art. 6(1)(c) |
Is providing your data required? Providing your CV is a contractual requirement — our service cannot function without it. Phone number, photo, and video are optional.
AI-Powered Profiling
Skillbourg uses AI to score and rank candidate profiles against job requirements. This constitutes profiling under Art. 4(4) GDPR.
Human oversight: Recruiters make all shortlisting and hiring decisions. AI is advisory only. All applicants are visible — no candidate is automatically excluded.
Non-discrimination: Our algorithm does not use protected characteristics as ranking factors. If you believe our scoring produced a discriminatory outcome, contact gdpr@skillbourg.com to request human review.
Your rights
You have the right to:
- request human review of any decision significantly influenced by automated profiling;
- express your point of view regarding how your profile has been assessed;
- contest decisions influenced by automated profiling;
- object to processing based on legitimate interest under Art. 21(1) GDPR.
Contact gdpr@skillbourg.com to exercise any of these rights.
Anti-Discrimination Commitment
Our AI evaluates job-relevant competencies only. Protected characteristics are not used as ranking factors. Companies using Skillbourg agree not to discriminate. Violations may result in account suspension or termination.
Your Rights
Under the GDPR, you have the following rights:
| Right | How to Exercise |
|---|---|
| Access (Art. 15) | Request a copy of all your data. |
| Rectification (Art. 16) | Correct inaccurate data in your profile. Contact gdpr@skillbourg.com. |
| Erasure (Art. 17) | Delete your account. Profile hidden immediately; data permanently deleted after a 30-day grace period. For immediate deletion, contact gdpr@skillbourg.com. |
| Restriction (Art. 18) | Request restriction of processing. Contact gdpr@skillbourg.com. |
| Portability (Art. 20) | Request your data in machine-readable format. Contact gdpr@skillbourg.com. |
| Object (Art. 21) | Object to processing based on legitimate interest. We will cease processing unless we demonstrate compelling legitimate grounds. |
| Withdraw consent | Withdraw analytics consent via cookie settings. Withdraw talent discovery consent via your profile settings or by contacting gdpr@skillbourg.com. Withdraw sensitive data consent by contacting gdpr@skillbourg.com (see Section 1.2 for consequences). |
| Profiling rights | Request human review, express your view, or contest profiling decisions. See Section 3. |
Contact gdpr@skillbourg.com to exercise any of these rights. We respond within one month (extendable by two months for complex requests). We may verify your identity via your account email.
Data Retention
| Data Category | Retention Period |
|---|---|
| Active candidate data | Duration of active account |
| Inactive candidate data | After a period of inactivity, we will notify you by email before deleting your account and associated data |
| Account deletion | Profile hidden immediately; all data deleted after 30-day grace period |
| Ranking results | 24 months after job closure (legitimate interest: anti-discrimination audit and legal compliance) |
| Job descriptions | Duration of posting + 24 months |
| Company/recruiter data | Duration of relationship + 10 years (Luxembourg commercial law) |
| Analytics data | Per provider defaults (consent-only) |
| Cookie consent records | 12 months, then re-consent required |
Data is permanently deleted or anonymised at the end of the applicable retention period.
International Data Transfers
All candidate data — including storage, AI processing, and email delivery — is processed within the European Union.
Where any service provider transfers data outside the EU, appropriate safeguards are in place in accordance with GDPR Chapter V, including adequacy decisions or Standard Contractual Clauses.
Data Security
We implement appropriate technical and organisational measures to protect your personal data.
Children’s Privacy
Skillbourg is not intended for individuals under 18 years of age.
Changes to This Policy
For material changes, we will notify you via email at least 30 days before the changes take effect, except where changes are required to comply with applicable law or regulatory requirements, in which case changes may take effect immediately upon notification.
Dispute Resolution
The European Commission provides an Online Dispute Resolution platform at https://ec.europa.eu/odr.
Contact Us
- Data protection: gdpr@skillbourg.com
- Platform support: support@skillbourg.com
- Business enquiries: hello@skillbourg.com
- Address: RMT Labs S.A., 41 Rue Marie-Adélaïde, L-2128 Luxembourg
- Supervisory authority: CNPD, 15 Boulevard du Jazz, L-4370 Belvaux, Luxembourg
Have questions about this Privacy Policy or your data? Contact gdpr@skillbourg.com.