Acceptable Use Policy

Last updated: May 24, 2025

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1. Introduction and Scope

This Acceptable Use Policy ("AUP") governs the use of the software, platform, APIs, and services provided by Wintro ("Service"). This Policy applies to all Customers, administrators, employees, contractors, and end-users ("Users") accessing the Service.

By accessing or using the Service, you agree to comply with this AUP. This Policy is incorporated by reference into the Wintro Terms of Service and/or Master Services Agreement. Its purpose is to ensure the lawful, responsible, and secure use of Wintro and to protect the integrity of the hiring ecosystem.

2. General Use Requirements

Users agree to use the Service solely for lawful, legitimate internal business purposes related to talent acquisition, employee referrals, and professional networking. Users must comply with all applicable local, state, national, and international laws, treaties, and regulations (including those related to data privacy, international communications, and export laws).

3. Prohibited Activities

Users shall not use the Service to engage in, facilitate, or encourage any of the following activities:

3.1. Illegal or Harmful Behavior

  • Conducting or facilitating any unlawful activity.
  • Uploading, transmitting, or distributing viruses, worms, malware, Trojan horses, or any other destructive code.
  • Engaging in activity that is harassing, threatening, abusive, defamatory, libelous, or invasive of another’s privacy.
  • Impersonating any person or entity, or falsely stating or otherwise misrepresenting an affiliation with a person or entity.

3.2. System Integrity and Security

  • Interfering with or disrupting the integrity, performance, or security of the Service or the data contained therein.
  • Attempting to gain unauthorized access to the Service or its related systems or networks.
  • Conducting any penetration testing, vulnerability scanning, or similar activities without Wintro’s prior explicit written consent.
  • Reverse engineering, decompiling, or disassembling any portion of the Service to derive source code or underlying algorithms.
4. Referral Integrity and Candidate Interactions

As Wintro facilitates employee referrals and hiring rewards, maintaining the integrity of the recruitment process is paramount.

4.1. Fraud and Misrepresentation

‍Users are strictly prohibited from:

  • Submitting referrals for "fake" candidates or fabricating professional histories.
  • Creating duplicate accounts or manipulating the platform to fraudulently obtain referral bonuses or financial incentives.
  • Referring candidates with whom the User has no genuine professional connection, in violation of the Customer’s specific internal referral program rules.

4.2. Outreach and Anti-Spam

‍When using the Service to contact candidates, Users must:

  • Refrain from "spamming" or sending unsolicited bulk messages in violation of applicable laws (e.g., CAN-SPAM, GDPR).
  • Respect the rights of individuals who have opted out or requested not to be contacted.
  • Avoid using high-pressure tactics or harassment to compel candidates to apply.

4.3. Non-Discrimination

‍Users shall not use the Service or its data to exclude, target, or discriminate against candidates based on race, color, religion, sex, sexual orientation, gender identity, national origin, veteran, or disability status.

5. Network Syncing and Third-Party Integrations

Wintro allows Users to sync professional networks to leverage network intelligence.

5.1. Authorization

‍Users represent and warrant that they have the authority to access and process the data synced to the Service. Users may sync accounts they personally own; or third-party network data that is lawfully accessible to the User for which the User holds a valid commercial license or right to access. Users are strictly prohibited from syncing accounts by using unauthorized credentials, or by logging into accounts belonging to others without express permission.

5.2. Data Extraction and Scraping

‍Users may not use the Service to scrape, harvest, or mass-export data regarding candidates or networks surfaced by Wintro, except via official export features provided within the interface.

5.3. Third-Party Compliance

‍Users agree to comply with the Terms of Service of any third-party platform integrated with Wintro. Wintro is not responsible for violations of third-party user agreements committed by the User.

6. Artificial Intelligence and Automated Decision Making

Wintro utilizes Artificial Intelligence (AI) to surface recommendations and match candidates.

6.1. Human-in-the-Loop Requirement

‍Users acknowledge that Wintro’s AI provides recommendations and insights, not definitive hiring decisions. Users agree not to use Wintro as the sole determinant for hiring, firing, or promotion decisions. All AI-generated suggestions must be reviewed by a human decision-maker.

6.2. No Manipulation

‍Users may not input misleading, biased, or fraudulent data into the system with the intent of manipulating the AI’s output, matching algorithms, or recommendation engine.

7. Data Privacy and Sensitive Information

7.1. Lawful Basis

‍Users agree to only upload or submit candidate data for which they have a lawful basis (e.g., legitimate interest or consent) under applicable data protection laws (such as GDPR or CCPA).

7.2. Sensitive Data

‍Unless explicitly required for the hiring process and permitted by law, Users shall not upload "Special Categories" of data (as defined by GDPR), including data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic/biometric data, or health data.

7.3. Candidate Rights

‍Users must promptly comply with any candidate requests regarding their data rights (e.g., right to erasure, rectification, or objection) and notify Wintro immediately if a data subject exercises these rights regarding data stored within the Service.

8. Account Security

Users are responsible for maintaining the confidentiality of their login credentials. Users may not share passwords or account access with unauthorized individuals. Company Administrators are responsible for revoking access for employees who leave the organization or change roles.

9. Monitoring and Enforcement

Wintro reserves the right, but assumes no obligation, to monitor the use of the Service to ensure compliance with this AUP. Wintro may, at its sole discretion:

  • Investigate violations of this Policy.
  • Suspend or terminate access to the Service for any User found to be in violation.
  • Remove or disable access to any content that violates this Policy.
  • Cooperate with legal authorities and third parties in the investigation of alleged wrongdoing.
10. Reporting Violations

If you become aware of any violation of this Policy, you must immediately report it to Wintro at legal@wintro.ai.

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