Privacy Policy
On this page 1. Who we are 1/15
1. Who we are
GenHQ Ventures Limited ("GenHQ") is registered at 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF. References to "we" or "us" throughout this policy refer to GenHQ. For the purposes of this Privacy Policy, we are the data controller of your personal information.
This Privacy Policy outlines how we process your information in compliance with relevant data protection laws, including the General Data Protection Regulation (EU 2016/679), the Data Protection Act 2018, and the GDPR as incorporated under UK law and amended from time to time ("UK GDPR", and collectively the "Data Protection Laws").
If you provide personal information to us on behalf of someone else, you acknowledge that this notice will apply to that data and that you are responsible for informing those third parties that this notice will apply to their personal data and for collecting and recording their consent where necessary.
We may make changes to this Privacy Policy from time to time to reflect new processing activities, government regulations, new technologies, or other developments in data protection laws. We encourage you to check the current version on our Website regularly.
2. GenHQ's privacy principles
Data processing at GenHQ is based on the following principles:
- We are committed to safeguarding the privacy and security of your personal data and processing it in a fair, lawful, and transparent manner.
- We only collect and use your personal data where we believe we have a valid legal basis to do so.
- The personal information we request from you is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.
- Your personal information is kept no longer than is necessary for the purposes for which it is processed.
- We ensure personal information stored within our records is kept accurate and up to date.
- Your personal information will be processed in accordance with your data subject rights.
- We will ensure that your personal data is securely disposed of at the end of the appropriate retention period.
- Our staff are appropriately trained on their privacy obligations and AI literacy.
3. What GenHQ does
GenHQ is a marketplace for AI-native creative work. It connects:
- Creatives: individual creatives who create profiles, show portfolios, apply for work, and may commission project collaborators.
- Companies: buyers, brands, studios, or employers who post jobs or project briefs and hire creatives.
- Agencies: hybrid users who may represent or provide creatives and may also hire or package creative services for clients.
4. How GenHQ uses your personal information
GenHQ is the controller of your personal data where we collect this data for our own requirements, such as to run our marketplace, improve our product, or carry out fraud-prevention checks. We are also the controller where you contact us directly by email or otherwise as a recruitment candidate. GenHQ does not sell your personal data.
5. Legal grounds we rely on
We will only process your personal information where we have a legally valid reason to do so. Under the GDPR this is called a legal basis, and more than one legal basis may apply depending on the processing activity.
- How we use your information
- To run our marketplace, including management of accounts, listings, applications, messaging, payments, badges, and scores.
- Personal information we may process
- Account details, including name, email, password or OAuth identity, and for project owners and hiring organisations, workspace and lead-contact details. Portfolio details, including roles, tools, skills, rates, availability, headline, bio, and uploaded or linked work. Listing activity, including job listings, project briefs, applications, messages, reviews, and shortlists. Payment records via Stripe, creative identity-verification outcomes via Stripe Identity, and public company-registry records plus work-email confirmation evidence for companies and agencies via OpenCorporates and GenHQ.
- Legal grounds for processing
- Performance of a contract: the processing of this personal information is necessary to provide our services to you via our marketplace or is necessary as a pre-contractual step in order to provide these services.
- How we use your information
- To provide our matching and searching services to you.
- Personal information we may process
- Account details, portfolio details, and listing activity, including job listings, project briefs, applications, messages, reviews, and shortlists.
- Legal grounds for processing
- Performance of a contract: the processing of this personal information is necessary to provide our matching and searching services to you via our marketplace or is necessary as a pre-contractual step in order to provide these services.
- How we use your information
- To provide prospective customers who have expressed an interest in our marketplace with additional information.
- Personal information we may process
- Your contact and identifying details, marketing preferences, and behaviour and usage data.
- Legal grounds for processing
- Consent, where you or someone on your behalf has confirmed your consent; or legitimate interests, where we have a legitimate interest in providing additional information to people who have actively expressed an interest in our services or products.
- How we use your information
- To process your application where you have applied for a role at GenHQ.
- Personal information we may process
- Identification and contact data, including full name, date of birth, email address, phone number, and other identification or contact data you provide to us. Employment and qualifications data, including your resume, previous employers, roles, academic institutions, and related information.
- Legal grounds for processing
- Consent, where you or someone on your behalf has confirmed your consent.
- How we use your information
- For our own information management purposes, including managing accounting records, analysing financial results, internal audit requirements, and receiving professional advice.
- Personal information we may process
- Contact data, including full name, organisation, email address, and phone number.
- Legal grounds for processing
- Consent; legal obligation, where we need to comply with obligations relating to the security and operation of our systems and maintenance of accounting records; or performance of a contract, where properly managing your information is necessary in order to provide services to you.
- How we use your information
- Communicating marketing information to you via post, phone, email, text message, or social media and developing and tailoring our marketing activities.
- Personal information we may process
- Contact data, including full name, organisation if you represent a legal person, email address, phone number, marketing preferences, and behaviour and usage data.
- Legal grounds for processing
- Consent; or legitimate interests, where we have a legitimate business need to tailor advertising to and market to customers and prospective customers who show an interest in us.
- How we use your information
- To prevent, detect, and investigate fraud, such as by using third-party databases to verify your identity.
- Personal information we may process
- Your contact and identifying details and your location.
- Legal grounds for processing
- Legal obligation: we have a legal obligation to prevent, detect, and investigate fraud.
- How we use your information
- For research and analytical purposes, to enhance our service quality, training, and information security.
- Personal information we may process
- Information shared during your interactions with us, including information via our Website.
- Legal grounds for processing
- Consent; or legitimate interests, where we have a legitimate business need to use your personal information to enhance our service, training, and information security.
- How we use your information
- To communicate with you to resolve any data subject rights requests or complaints you may have.
- Personal information we may process
- Contact data, including full name, email address, and phone number.
- Legal grounds for processing
- Performance of a contract, where processing is necessary to respond to your request in connection with services we provide to you; or legal obligation, where we need to process personal data to comply with statutory obligations relating to your complaint.
6. Who we share personal information with
We will not share your personal data other than as outlined in this Privacy Policy. We may share your personal data with our staff or contractors where necessary to carry out the purposes set out above.
Personal data may also be shared with third parties such as service providers, data processors and their affiliates, subcontractors, or delegates who assist with running our Website and providing our services, including IT service providers, accountants, marketing partners, email hosting services, Stripe, and OpenCorporates. Company and agency verification sends the selected public registry reference to OpenCorporates; email confirmation is delivered through our email provider. If you choose document verification, your supporting PDFs are stored privately with Bunny and accessed by authorised GenHQ reviewers to assess your company application. These documents are not displayed on your public profile.
- We may disclose personal information to professional advisers including lawyers, auditors, and insurers.
- If we sell or buy any business or assets, we may disclose certain personal data to the prospective seller or buyer.
- If all or substantially all of GenHQ's assets are acquired by a third party, personal data held about our customers may be one of the transferred assets.
- We may disclose or share personal data to comply with a legal or regulatory obligation, for the prevention of crime, or where necessary to protect the vital interests of a person.
- We may disclose personal data to enforce or apply our terms and conditions or to establish, exercise, or defend the rights of GenHQ, our staff, clients, or others.
Our third-party service providers and data processors are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.
7. International data transfers
To deliver GenHQ's services to you, it may be necessary for us to transfer your personal data to service providers and business partners located outside of the UK or EEA (an "International Transfer").
Whenever an International Transfer of your personal data occurs, we ensure an appropriate degree of protection is afforded to it by using appropriate safeguards.
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Information Commissioner's Office or the European Commission.
- Where we use service providers based outside the UK and EEA, we may use the International Data Transfer Agreement or Addendum approved by the UK Information Commissioner's Office or the standard contractual clauses approved by the European Commission.
- We may also use other valid transfer mechanisms in accordance with applicable laws.
If you want further information on the specific mechanism relied on by GenHQ for an International Transfer, please contact our Data Protection Officer using the details below.
8. How long we retain your personal data for
We keep account data such as your name and email while your account is active and for up to 6 years after closure where required for tax, dispute, and legal purposes.
Messages and engagement records are retained as part of the marketplace's verified history while needed for marketplace integrity, dispute handling, and legal purposes.
Company verification PDFs are removed from active storage 90 days after approval or rejection. Unconfirmed document applications expire after 7 days; applications awaiting more information expire after 90 days without a response, and their PDFs are removed. Applications awaiting our review remain available until a decision is made. We retain the review outcome and audit history for marketplace integrity.
We delete or anonymise data when it is no longer needed.
9. Matching and profiling
GenHQ ranks search results and computes signals such as the profile-strength score and badges to surface relevant matches. This profiling helps discovery but does not make decisions that produce legal or similarly significant effects about you.
Hiring and award decisions remain with the customer or GenHQ team. Marketplace profiles and listings may go live automatically when required information, payment, verification, and safety checks pass, while GenHQ can remove, suspend, or review content where trust, safety, payment, or legal risk appears.
10. Your rights as a data subject
Depending upon where you reside, you have various rights regarding your personal data. For example, you may have the right to ask us for a copy of your personal information, ask us to correct mistakes, change the way we use your information, or ask us to delete it. We will either do what you have asked or explain why we cannot, usually because of a legal or regulatory issue.
To contact us about any of your data subject rights, please use the Data Protection Officer details below. In some cases we may not be able to comply with your request because of our obligations to comply with other legal or regulatory requirements. We will always respond to any request you make and, if we cannot comply, we will tell you why.
The following rights may be available to you under the GDPR:
- Access: you are entitled to a copy of the personal information we hold about you and certain details of how we use it, including any profiling or automated decision-making.
- Rectification: you can ask us to update or amend personal information you believe is incorrect, including personal information input into profiles we have created about you.
- Erasure: in certain circumstances you can ask us to erase your personal information, although legal and regulatory obligations may mean we cannot comply. Erasure may restrict our ability to provide our services to you.
- Restriction: you can ask us to stop using your personal information, although this may restrict our ability to provide our services to you.
- Data portability: you can ask that we transfer personal information you have provided to us in connection with our services to another third party of your choice.
- Objection: you can object to processing of all or some of the personal data we hold about you, including processing for marketing or profiling.
- Automated decision-making: you have the right not to be subject to decisions made automatically by inputting your personal information into a system or computer.
- Withdraw consent: where we rely on consent, you can withdraw your consent to further use of your personal information. In some cases we may not be able to provide our services to you if you withdraw consent.
- Lodge a complaint: you can complain to the relevant data protection authority in the country where you reside if you object to the way we use your personal information.
GenHQ will respond to you or exercise your rights within 30 days. If the request is very complex or the number of requests received is very high, this period may be extended by 60 days. In that case, we will notify you about the extension and the reasons for it within 30 days of your request.
Save as described in this Privacy Policy or provided under applicable data protection laws, there is no charge for exercising your legal rights. If requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee or refuse to act on the request.
11. Security
We are committed to ensuring that your information is secure. GenHQ has implemented appropriate technical and organisational security measures to prevent the loss of, damage to, or unauthorised destruction of personal data and the unlawful access to or processing of such data.
We have systems in place to control your data in a way that minimises its exposure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect.
12. Cookies
Necessary cookies keep the site secure and working, including session, CSRF, and account cookies. These are always on.
With your permission we also use analytics, advertising, and personalisation cookies to understand how the marketplace is used and to make our marketing more relevant. Guests can choose these categories from the cookie banner or Cookie settings on public pages. Your choices are stored for six months.
We use Google Consent Mode so optional tags only run after you grant the matching category.
13. External links
Our Website makes use of certain third-party applications and websites which are subject to their own privacy policies and website terms and conditions. Where you choose to access one of these applications or links, GenHQ will not be the data controller and does not control how your data may be processed within those applications and websites.
14. Children
Our services and our Website are not intended for or directed at children under the age of 16 years, and we do not knowingly collect data relating to children.
15. Contact details of the Data Protection Officer
If you have any questions or want to exercise any of your rights described in this Privacy Policy, you can contact the Data Protection Officer using the details below.
Address: The Data Protection Officer, GenHQ Ventures Limited, 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF.
Email: privacy@genhq.io.
If you have any questions or complaints regarding our Privacy Policy or practices, please contact our Data Protection Officer. You also have the right to make a complaint at any time with a supervisory authority in the territory where you work, normally live, or where any alleged infringement of data protection laws occurred.
The supervisory authority in the UK is the Information Commissioner's Office, which can be contacted at https://ico.org.uk or by telephone on 0303 123 1113.