Version 2026-10-11

Master Subscription Terms and Candidate Terms of Use

1. Parties, Scope and Contractual Structure

1.1 Provider

These Master Subscription Terms and Candidate Terms of Use (the “Terms”) are issued by HexaCrewTools, a trading name of DEVECE Aviation Services by Cesare Paolo De Vecchi, ul. Farbiarska 65G, 02-862 Warszawa, Poland, NIP 9512447039 (the “Provider”).

1.2 Customers and the Agreement

The Provider supplies the Services to airlines and recruitment agencies (each a “Customer”) under an executed order form or other written commercial agreement (an “Order Form”).

The Order Form, these Terms and the data processing agreement between the Provider and Customer (the “DPA”), together with any documents expressly incorporated by the Order Form, constitute the “Agreement”.

The identity of each Customer is specified in its Order Form.

1.3 Application to Candidates and Authorised Users

Clauses concerning account access, acceptable use, confidentiality, intellectual property, AI features and data protection apply to Authorised Users to the extent relevant to their use of the Services.

Clause 6 and other provisions expressly applicable to Candidates govern access through recruitment links supplied by a Customer. A Candidate does not become a Customer or acquire a paid subscription by using such a link.

1.4 Order of Precedence

For commercial matters, an expressly inconsistent provision of an Order Form prevails over these Terms. For the processing of personal data on behalf of the Customer, the DPA prevails over an inconsistent provision of these Terms. Mandatory applicable law prevails in all cases.

2. Definitions

“Agreement” has the meaning given in clause 1.2.

“Authorised User” means an individual issued an account by or for a Customer to access the Services in a role permitted by that Customer.

“Candidate” means an individual participating in a Customer’s cabin crew recruitment process through a link provided by that Customer.

“Customer Content” means content, instructions, documents and materials provided by or on behalf of a Customer or its Authorised Users for use with the Services, including recruitment criteria and assessment forms.

“Customer Data” means data processed within the Services on behalf of a Customer, including Candidate submissions, assessment records, recruiter entries and Customer Content containing personal data.

“DPA” means the data processing agreement entered into by the Provider and Customer in accordance with Article 28 of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

“Order Form” has the meaning given in clause 1.2.

“Services” means the aviation recruitment software and functionality made available by the Provider under the Agreement, subject to the scope specified in the Order Form.

3. Description of the Services

3.1 Recruitment Workflows

The Services support assessment-day organisation and selection workflows for cabin crew recruitment, including information-day registration, Candidate check-in, document collection and review, employment-history gap analysis, online assessments, recruiter scoring and forms, and filing of test results to Candidate records. Supported documents include passports, full-length photographs and curricula vitae (“CVs”).

3.2 Access Models

Authorised Users access the Services through issued accounts, with permissions determined by assigned roles. Candidates access only the check-in, document-upload, assessment or other Candidate-facing steps made available through links sent by the Customer. Candidate links do not grant access to a recruiter’s account or to other Candidates’ records.

3.3 Customer-Controlled Recruitment

The Services provide workflow support and information for the Customer’s recruiters. The Customer is solely responsible for recruitment criteria, review of applications, assessment outcomes, offers and employment decisions. The Provider does not act as the employer, recruitment decision-maker or guarantor of any Candidate’s suitability.

4. Subscription, Access and Authorised Users

4.1 Limited Right of Use

Subject to the Agreement, the Provider grants the Customer a non-exclusive, non-transferable right to permit its Authorised Users to access and use the Services for the Customer’s internal aviation recruitment operations during the subscription period specified in the Order Form. No ownership of the Services is transferred.

4.2 Role-Based Permissions

The Customer shall assign appropriate roles, restrict access to authorised functions and records, and keep its list of Authorised Users current. The Customer shall promptly revoke or request removal of access when an Authorised User leaves the Customer’s organisation, changes duties or otherwise ceases to require access.

4.3 Credentials and Security

Authorised Users shall protect account credentials, shall not share accounts or impersonate another user, and shall report suspected unauthorised access to the Customer and, where appropriate, the Provider. The Customer is responsible for actions taken through accounts it has authorised, except to the extent attributable to the Provider’s breach of the Agreement or applicable law.

5. Customer Obligations

5.1 Lawful Recruitment and Transparency

The Customer shall establish and document an appropriate lawful basis for processing Candidate data; provide Candidates with the information required by applicable data protection and recruitment law; and identify the Customer as the controller of its recruitment records. Such information shall explain where AI-assisted functions support the process and shall not describe those functions as making final recruitment decisions.

5.2 Human Assessment and Fair Use

The Customer shall ensure that a recruiter reviews every assessment outcome and any AI-generated suggestion before it is relied upon in a decision. The Customer shall independently consider accuracy, relevance, fairness and any legal restrictions applying to suitability questions, document checks and recruitment criteria.

5.3 Authority to Supply Materials

The Customer warrants that it has the necessary rights and permissions to supply Customer Content and to instruct the Provider to process Customer Data. The Customer shall not require the Provider to process data unlawfully or outside the documented instructions permitted by the DPA.

5.4 External Testing Providers

Where a Customer uses a third-party testing provider, including ClassMarker, the Customer remains responsible for its choice and permitted use of the relevant assessments, subject to any responsibilities expressly assigned to the Provider in the Agreement and DPA.

6. Candidate Terms of Use

6.1 Restricted Purpose

A Candidate may use a recruitment link only for that Candidate’s own application and only for the purpose for which the Customer supplied it. A Candidate shall not share or misuse a link, attempt to access another Candidate’s information or access recruiter-only functions.

6.2 Accurate Information and Own Documents

A Candidate shall submit information that is accurate to the best of the Candidate’s knowledge, use documents relating to that Candidate, and correct any material error brought to the Candidate’s attention. A Candidate must not submit another individual’s passport, photograph, CV or identifying details as the Candidate’s own.

6.3 Assessments

A Candidate shall personally complete assessments assigned to that Candidate, without impersonation or unauthorised assistance, and comply with lawful assessment instructions communicated by the Customer. Where an online test records IP addresses or events indicating that the test window was left, those events may be included in the assessment record for human consideration; an event is not, by itself, a finding of misconduct.

6.4 No Promise of Employment

Access to an assessment, successful document submission or completion of any Service does not constitute an offer of employment, acceptance into a recruitment programme or a representation about the Customer’s final decision.

7. Acceptable Use

Each Customer, Authorised User and Candidate shall use the Services lawfully and shall not:

• circumvent authentication, role permissions, security measures or rate limits;
• interfere with the Services, introduce malicious code or conduct unauthorised security testing;
• scrape, extract or obtain access to records beyond the permitted recruitment purpose;
• upload content without the required rights, or content that infringes applicable law or third-party rights;
• misrepresent identity, manipulate assessment integrity data or use another individual’s credentials;
• copy, reverse engineer or create derivative software from the Services, except to the extent such restriction is prohibited by mandatory law.

8. Automated Assistance and AI Features

8.1 Document Analysis

Passport information and full-length photographs are checked on the Provider’s server, including optical character recognition, machine-readable zone checks, passport-expiry checks and checks relating to full-length photographs. The Provider does not submit passports or full-length photographs to third-party document-analysis services. Infrastructure hosting and storage remain subject to the DPA.

8.2 CV Extraction

CVs are converted to text on the Provider’s server. Identifiers, including names, contact details, passport numbers and dates of birth, are replaced with placeholders before redacted content is submitted to the Google Gemini API to identify work and education history. If a page cannot be read as text, an image of the relevant page may be submitted with identifying sections redacted. Redaction and extraction are technical safeguards and assistance mechanisms, not a guarantee that all errors or identifying fragments are eliminated.

8.3 Assessment Assistance

Automated rules may flag passport expiry or employment-history gaps exceeding 12 months as questions for a recruiter. AI may suggest points for written assessment answers. Flags, extracted histories and suggested points are advisory and require independent human review. The Services do not make solely automated decisions with legal or similarly significant effects, and do not use emotion recognition.

8.4 AI Interview Practice

Where AI interview practice is made available to a signed-in user, the user is informed that the interaction is with an AI system. Microphone audio is transmitted to Simli through a Daily room for the practice interaction. Camera data remains on the user’s device. The Provider does not record or score the user’s camera or microphone content in this practice feature. A hashed IP address and a one-year device cookie named “hxi_device” are used to limit sessions.

8.5 Limits of Outputs

AI-generated or automatically extracted information may be incomplete, incorrect or context-dependent. The Customer shall verify material outputs against source records and shall not treat them as employment decisions, legal advice or determinations of a Candidate’s fitness for a role.

9. Intellectual Property and Customer Content

9.1 Services

The Provider retains its rights in the software, interfaces, workflows, documentation and other materials forming the Services, together with associated intellectual property rights. No licence is granted beyond the limited access expressly set out in the Agreement.

9.2 Customer Content and Customer Data

As between Provider and Customer, the Customer retains its rights in Customer Content and Customer Data, subject to any rights of the relevant Candidate or other right holder. The Customer authorises the Provider and its permitted sub-processors to host, transmit, transform, display and otherwise process such material solely as necessary to supply the Services and comply with the Agreement and documented instructions.

9.3 Candidate Materials

A Candidate retains any rights the Candidate holds in submitted materials. Submission permits processing for the relevant Customer’s recruitment process, subject to the Customer’s privacy information and the DPA; it does not transfer ownership of Candidate materials to the Provider.

10. Confidentiality

10.1 Protected Information

Each party shall protect non-public commercial, technical and operational information disclosed by the other party in connection with the Agreement, including non-public Customer Data, and shall use it only for permitted contractual purposes. Each party shall restrict disclosure to recipients who require access for those purposes and are bound by appropriate confidentiality obligations or duties.

10.2 Exceptions and Required Disclosure

Confidentiality does not apply to information demonstrably public without breach, already lawfully known to the recipient, independently developed without use of confidential information, or lawfully received without a duty of confidence. A disclosure required by law or lawful authority may be made to the required extent, with prior notification where lawful and practicable.

10.3 Personal Data

Where confidential information contains personal data, applicable data protection law and the DPA also govern its handling.

11. Data Protection

11.1 Allocation of Roles

For Candidate recruitment records processed on behalf of a Customer, the Customer acts as controller and the Provider acts as processor under the DPA. The Provider acts as controller for website visits, contact enquiries, Authorised User account management and security data, accounts on its earlier online testing platform and AI interview practice, as described in the Privacy Notice.

11.2 Processing Instructions and Sub-processors

The Provider shall process Customer personal data in accordance with the DPA, including its provisions on documented instructions, confidentiality, security, assistance, sub-processors, international transfers and return or deletion. The applicable sub-processors and processing categories are described in the Privacy Notice and governed contractually by the DPA.

11.3 Candidate Requests

The Customer is responsible for responding to data subject requests and for providing the information required by Articles 13 and 14 GDPR in relation to Customer-controlled recruitment processing. The Provider shall assist as required by the DPA. A Candidate may contact the recruiting Customer about application records, including corrections and erasure requests.

11.4 Privacy Notice

The Provider’s Privacy Notice describes processing for which the Provider is controller and explains the Provider’s role when handling Candidate data for a Customer. The Privacy Notice supplements, but does not replace, the Customer’s own Candidate privacy information.

12. Fees, Invoices and Payment

Subscription charges, any other fees, invoicing arrangements, payment terms and applicable commercial adjustments are governed exclusively by the Order Form or other written Agreement between Provider and Customer. Candidates do not incur a subscription charge under these Terms by accessing Customer-issued recruitment links.

13. Service Availability and Changes

13.1 Standard of Performance

The Provider shall supply the Services with reasonable skill and care. Availability may be affected by maintenance, network or hosting interruptions, security incidents and systems outside the Provider’s control. No uptime percentage, service-credit arrangement or support response time applies unless expressly stated in the Order Form.

13.2 Changes to Functionality

The Provider may maintain and modify the Services, including changes required for security, legal compliance or technical operation. Where a change materially affects an agreed service commitment, the parties’ rights and remedies are determined by the Agreement and applicable law.

14. Suspension and Termination

14.1 Suspension

The Provider may suspend access to the extent reasonably necessary to address an active security threat, unlawful use, unauthorised access or a material breach of the Agreement. The Provider shall, where lawful and practicable, notify the Customer of the reason for suspension and restore access when the relevant grounds have been resolved. Any suspension for non-payment is subject to the Order Form and applicable law.

14.2 Term and Termination

The subscription term, renewal and ordinary termination arrangements are specified in the Order Form. Either party may seek termination for a material breach in accordance with the Agreement and applicable law, allowing a reasonable opportunity to remedy a breach where remedy is possible and appropriate. Termination does not remove accrued payment obligations or rights that must survive by their nature.

14.3 Accounts and Candidate Links

Upon expiry or termination, the Customer’s subscription rights cease, and the Provider may disable related Authorised User accounts and Candidate links, subject to any agreed transitional access and legal obligations.

15. Data Return, Deletion and Retention

15.1 Customer Instructions

Return and deletion of Customer Data following termination or upon Customer request shall be carried out in accordance with the DPA and the applicable documented instructions, subject to legal retention obligations and technically necessary backup cycles.

15.2 Selection Records

In the ordinary course, Candidate selection data is deleted two years after the applicable assessment day by an automated weekly process, or sooner at the Customer’s request. Encrypted backups are retained for 30 days. Retention for other processing categories is described in the Privacy Notice and is not extended merely because a subscription ends.

15.3 Authorised User Accounts

Authorised User accounts are retained while in use and deleted at the Customer’s request, subject to any legally required retention and applicable backup handling.

16. Warranties, Disclaimers and Liability

16.1 Skill and Care

The Provider shall exercise reasonable skill and care in supplying the Services.

16.2 No Outcome Warranty

To the extent permitted by law, the Provider does not warrant that recruitment results will predict employment outcomes, that the Services are fit for a particular purpose, or that their operation will be continuous or error-free. These disclaimers do not displace the express reasonable-skill-and-care obligation.

16.3 Aggregate Liability Limit

Subject to clause 16.5, each party’s total aggregate liability arising out of or in connection with the Agreement during any 12-month period is limited to the fees paid by the Customer to the Provider under the Agreement during that same period, or EUR 100 if no fees were paid in that period.

16.4 Excluded Loss

Subject to clause 16.5, neither party shall be liable to the other for loss of profit, loss of opportunity, loss of an offer of employment or loss that was not reasonably foreseeable when the Agreement was entered into, whether arising in contract, tort or otherwise.

16.5 Mandatory Exceptions

Nothing in the Agreement excludes or limits liability for intentional harm; death or personal injury caused by negligence; or any liability that cannot lawfully be excluded or limited under Polish law or other mandatory applicable law. Clauses 16.3 and 16.4 do not reduce any mandatory rights of a Candidate or other consumer.

17. Governing Law and Jurisdiction

17.1 Business Disputes

The Agreement and non-contractual obligations connected with it are governed by Polish law. Subject to mandatory rules of jurisdiction, the courts of Warsaw, Poland, have jurisdiction over disputes between the Provider and a Customer.

17.2 Consumer Protection

Where a Candidate or other user qualifies as a consumer, nothing in these Terms deprives that consumer of the mandatory protections of the law of the country in which the consumer habitually resides, where such protections apply. A consumer may bring proceedings before the courts of the consumer’s country of residence where permitted by applicable law. Any jurisdiction provision in these Terms is subject to mandatory consumer protection rules.

18. Changes to These Terms

18.1 Amendments

The Provider may amend these Terms to reflect changes in the Services, applicable law, security requirements or business operations. Each revised version shall identify its effective version date.

18.2 Notification

The Provider shall notify affected Customer account holders of material changes through the Services, by email or through another communication channel established under the Agreement. Where an amendment materially changes the Customer’s contractual rights or obligations, its application shall be subject to the Order Form, applicable law and any required Customer agreement.

18.3 Candidate Access

Updated Candidate Terms shall be made available through the relevant Candidate-facing interface or an accessible link. Changes shall not retrospectively remove mandatory rights or alter completed recruitment outcomes.

19. Notices and Contact

19.1 General Enquiries

General enquiries regarding the Services may be submitted through the contact form on the Provider’s website at hexacrewtools.com.

19.2 Data Protection Enquiries

Requests and enquiries concerning personal data processed by the Provider in its capacity as controller may be directed to dataprotection@hexacrewtools.com. Where a request relates to Customer-controlled Candidate records, the Provider may refer the requester to the relevant Customer and shall provide assistance in accordance with the DPA.

19.3 Contractual and Legal Notices

Formal legal notices to the Provider shall be sent to the business address identified in clause 1.1, unless a different notice procedure is expressly agreed in the Order Form. Notices to the Customer shall be sent to the contact details or address identified in the Order Form, subject to any agreed notice requirements.

19.4 Electronic Communications

Operational communications, account notices and service-related information may be provided electronically. Formal notices concerning termination, breach or legal proceedings must comply with the applicable Agreement and any mandatory requirements governing their form or delivery.

20. General Provisions

20.1 Entire Agreement

The Agreement constitutes the entire agreement between the Provider and Customer concerning its subject matter and supersedes prior discussions, proposals and representations relating to that subject matter, except where exclusion is prohibited by applicable law.

20.2 Severability

If any provision of the Agreement is held invalid, unlawful or unenforceable, the remaining provisions shall continue in effect to the extent permitted by law. The affected provision shall be interpreted or replaced, where legally permissible, in a manner that most closely reflects its lawful commercial purpose.

20.3 No Waiver

A failure or delay by either party to exercise a contractual right does not constitute a waiver of that right. A waiver applies only to the specific circumstances for which it is validly given.

20.4 Assignment

Neither party may transfer the Agreement or its contractual rights and obligations without the other party’s consent, except where otherwise expressly permitted by the Order Form or mandatory applicable law.

20.5 Independent Parties

The Provider and Customer are independent contracting parties. Nothing in the Agreement establishes a partnership, joint venture, employment relationship or general agency between them. Neither party may bind the other except where expressly authorised.

20.6 Third-Party Rights

Except for rights expressly granted to Candidates, Authorised Users or other beneficiaries under these Terms, and except where mandatory law provides otherwise, the Agreement does not confer contractual enforcement rights on third parties.

20.7 Survival

Provisions concerning accrued payment obligations, intellectual property, confidentiality, data protection, data return and deletion, liability, governing law and dispute resolution shall survive expiry or termination to the extent required to give effect to their purpose.

20.8 Language

These Terms are issued in English. Where a translation is made available, any inconsistency shall be resolved by reference to the English version, except where mandatory applicable law requires otherwise.

20.9 Interpretation

Section headings are provided for convenience and do not affect interpretation. References to legislation include amendments and replacements applicable from time to time. The words “including” and “includes” are illustrative and do not limit the preceding terms.