Annex NL — Netherlands & European Union

For countersigned originals, contact legal@sercxi.io.

GDPR obligations, WAADI position, EU AI Act treatment of AI-assisted candidate assessment.

NL.1 Contracting Entity and Law

EMEA mandates are contracted by Sercxi B.V. [ENTITY TBC — insert KvK number, registered address], governed by the laws of the Netherlands.

NL.2 GDPR Roles

Sercxi is an independent controller for candidate-sourcing and a processor for personal data provided by the Client. The lawful basis for candidate processing is legitimate interest (Art. 6(1)(f) GDPR), balanced by a documented Legitimate Interest Assessment and candidate transparency at first contact.

NL.3 WAADI

Sercxi provides executive search advisory and does not operate as a temp-work agency (uitzendbureau). Where the arrangement engaged would fall within WAADI, Sercxi will confirm registration status in the Engagement Letter.

NL.4 EU AI Act

Where AI-assisted tools are used in candidate assessment, Sercxi treats such use as a high-risk activity under Annex III of Regulation (EU) 2024/1689. All automated outputs are subject to meaningful human review by a Sercxi partner, and candidates are informed of AI involvement in accordance with the AI Disclosure page.

NL.5 Dispute Resolution

Disputes are resolved by arbitration under Netherlands Arbitration Institute (NAI), seat Amsterdam, in English, one arbitrator.

For questions or to request the full text of any gated document, contact legal@sercxi.io.