GENPLIFY
Genplify Limited
Unit 2A, 17/F, Glenealy Tower, No.1 Glenealy, Central, Hong Kong S.A.R.
Business Registration No.: 79681950
PDPO & GDPR Compliant
Effective Date: 1 January 2026
Genplify Limited (“Genplify”, “we”, “us”) is a company incorporated in Hong Kong SAR (Business Registration No. 79681950), with its registered address at Unit 2A, 17/F, Glenealy Tower, No.1 Glenealy, Central, Hong Kong S.A.R.. We operate the Genplify platform at genplify.com, a cloud-based SaaS service for AI proficiency assessment and training.
For questions about this Privacy Policy or your personal data, please contact us at: legal@genplify.com.
This Privacy Policy explains how we collect, use, share, and protect personal data when you use our website and Service. It applies to: Customer administrators who register for and manage accounts; Authorised Users (typically employees or contractors of our Customers) who use the platform to complete assessments and training; and visitors to our website.
Where we process personal data on behalf of a Customer (i.e., as a data processor), the Customer’s own privacy policy governs the relationship with the relevant individuals. This Privacy Policy applies to the extent that Genplify acts as a data controller.
When a Customer registers: name, email address, company name, job title, billing information (processed by our payment provider; we do not store full card details).
When Authorised Users use the Service: name and email address (as provided by the Customer); assessment responses, completion times, and interaction data; proficiency scores and analytics generated by the Service.
Automatically collected: IP address, browser type and version, operating system, device type; pages visited, time spent, referral source; cookies and similar technologies (see Section 9).
If you contact us: the content of your communications, including support requests and feedback.
We use personal data to: provide, maintain, and improve the Service; generate assessment results and reports; administer Customer accounts and process payments; provide customer support.
We use anonymised and aggregated data (which cannot identify any individual) to produce industry benchmarks, improve our assessment methodology, and publish research. This is a core function of the Service and is described in our Terms of Service.
We may use your email address to send service-related communications (e.g., account notifications, security alerts, billing information). We will only send marketing communications with your prior consent (opt-in), and you can unsubscribe at any time.
We use technical data to protect the Service against fraud, abuse, and security threats, and to comply with applicable legal obligations.
We collect and process personal data in accordance with the six Data Protection Principles of the PDPO. We collect data only for purposes directly related to the Service, inform data subjects of such purposes, and do not use data for purposes beyond those specified without consent.
Where the GDPR or UK GDPR applies, we rely on the following legal bases: Contract: processing necessary for the performance of our contract with the Customer; Legitimate interests: processing for the purposes of improving the Service, ensuring security, and producing anonymised benchmarks, where such interests are not overridden by the rights and freedoms of the individual; Consent: for marketing communications and non-essential cookies; Legal obligation: where we are required to process data by law.
We do not sell personal data. We may share personal data with: service providers and sub-processors who assist us in operating the Service (e.g., cloud hosting, payment processing, analytics), subject to contractual data protection obligations; the Customer organisation that manages the Authorised User’s account (Assessment Results and reports are accessible to the Customer’s administrators); professional advisers (lawyers, auditors) where necessary; law enforcement or regulatory authorities where required by law. A list of our current sub-processors is available in the legal section of genplify.com.
Genplify is based in Hong Kong SAR. Personal data may be processed and stored in Hong Kong and, where relevant, in other jurisdictions where our sub-processors operate.
Where we transfer personal data from the EEA or UK to Hong Kong or other jurisdictions without an adequacy decision, we implement appropriate safeguards, including the EU Standard Contractual Clauses (SCCs) or the UK International Data Transfer Agreement (IDTA), as applicable. Details of these safeguards are set out in our Data Processing Agreement.
We retain personal data for the duration of the Customer’s subscription. Following termination, we retain personal data for up to 30 days to allow data export, after which it is securely deleted. Anonymised and aggregated data (from which individuals cannot be identified) may be retained indefinitely for benchmarking and research purposes. We may retain certain data for longer periods where required by law (e.g., billing records for tax purposes).
We use only essential cookies that are strictly necessary for the Service to function. These cookies cannot be disabled because the Service would not work without them. We do not use analytics, advertising, or tracking cookies.
The following cookies are set when you use the Service:
We use browser local storage for a single functional purpose: storing a timestamp of the last successful account synchronisation to prevent unnecessary repeat requests. This data is not shared with any third party and does not contain personal information.
We do not use Google Analytics, advertising pixels, social media tracking scripts, or any other third-party tracking technologies. We do not use advertising or tracking cookies for targeted advertising purposes. Your browsing activity on our platform is not shared with advertisers or data brokers.
If you are a data subject under Hong Kong law, you have the right to: request access to your personal data (Data Access Request); request correction of inaccurate personal data (Data Correction Request). To exercise these rights, please contact us at legal@genplify.com. We will respond within 40 days of receiving a valid request.
If you are a data subject in the EEA or UK, you have the right to: access your personal data; rectify inaccurate or incomplete personal data; erase your personal data (right to be forgotten); restrict processing of your personal data; data portability (receive your data in a structured, commonly used, machine-readable format); object to processing based on legitimate interests; not be subject to a decision based solely on automated processing (including profiling) that produces legal or similarly significant effects. To exercise these rights, please contact us at legal@genplify.com. We will respond within 30 days. If you are unsatisfied with our response, you have the right to lodge a complaint with your local supervisory authority (e.g., the CNIL in France, the ICO in the UK).
The Service generates assessment scores using a combination of automated scoring and psychometric analysis. These scores are provided to the Customer for informational purposes. Genplify does not make any employment decisions about Authorised Users. Any decisions based on Assessment Results are made by the Customer, and the Customer is responsible for ensuring compliance with applicable laws regarding automated decision-making.
We implement appropriate technical and organisational measures to protect personal data, including: encryption at rest and in transit; access controls and multi-factor authentication; regular security assessments; employee training on data protection; incident response procedures. No system is perfectly secure, and we cannot guarantee the absolute security of your data. If we become aware of a data breach, we will notify affected parties in accordance with applicable law.
The Service is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will delete it promptly.
We may update this Privacy Policy from time to time. Where changes are material, we will notify Customers via email and update the “Effective date” above. We encourage you to review this Privacy Policy periodically.
Genplify Limited
Unit 2A, 17/F, Glenealy Tower, No.1 Glenealy, Central, Hong Kong S.A.R.
Email: legal@genplify.com
For complaints under the PDPO: Office of the Privacy Commissioner for Personal Data, Hong Kong (www.pcpd.org.hk)
For complaints under the GDPR: your local supervisory authority (e.g., CNIL in France, ICO in the UK)
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