DigitalGenius Limited Privacy Policy

DigitalGenius Limited Privacy Policy

Digital Genius Limited ("Digital Genius", "we", "our", or "us") is committed to protecting and respecting your privacy.

  1. Our approach to privacy

This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies as a result of you using our website at digitalgenius.com (the "Site").

Digital Genius is headquartered in London, United Kingdom and is the data controller of the personal information we hold about you.

Digital Genius has appointed an internal data protection officer for you to contact if you have any questions or concerns about our personal information policies or practices. If you would like to exercise your privacy rights, please use the contact information set out at the end of this privacy policy.

Digital Genius acts as the data controller. However, in relation to certain personal information that we process through our platform on behalf of our business customers (for example, message content, audio and transcripts from individuals who interact with our customers' services ("end-users")), our customer is the data controller and Digital Genius acts as a processor.

This policy sets out the information we collect and use as a data controller.

2. Personal information we collect about you and how we use it

The table at Annex 1 sets out the categories of personal information we collect about you, how we use that information and the legal basis on which we rely to process it.

The recipients with whom we may share your personal information are set out in the 'Recipients of personal information' section below.

We do not sell personal information to anyone; we only disclose personal data to third-party service providers or supporting vendors. From time to time, Digital Genius Limited receives personal information about individuals from third parties. Typically, information collected from third parties will include further details on your employer or industry. We may also collect your personal data from a third-party website (e.g. LinkedIn) if it is required to deliver our services.

More generally, we
a. collect personal information that you voluntarily submit directly to us when you use our Site. This can include information you provide to us when you register for an account and user profile, correspond with us, request a demo, complete a contact form, or otherwise submit an enquiry, request or message through our Site (including via any chat function on our Site), or use some other feature of our Site.
b. may also collect personal information from third parties, such as social networks.
c. We also automatically collect personal information indirectly about how you access and use the Site and information about the device you use to access the Site.
d. If you apply for a role with us, we also collect the personal information you provide as part of your application, such as your name, contact details, CV and other application data, which we use for recruitment and assessment purposes.

We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Site. If you choose not to provide such personal information, we may not be able to provide access to certain aspects of the Site to you or respond to your other requests.

3. Anonymous data

We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Site and developing new products and features. We may also share such anonymised information with others.

4. Artificial intelligence and automated processing

We are an artificial intelligence company. The AI-powered services we provide to our business customers which involve processing end-user content such as messages, audio and transcripts are, when carried out to deliver those services, performed in our capacity as a processor, on our customers' documented instructions, and are governed by the relevant customer's own privacy notice rather than this policy. However, where we use such data (including end-user content) to train, develop and improve our own AI models and services for our own purposes, we do so as a controller, and that processing is described in this policy. We carry out such training only to the extent permitted under the relevant customer agreement and Data Processing Addendum (DPA).

This policy covers only the limited automated processing we carry out as a data controller, for example, using analytics to understand how our Site is used and to communicate with prospects, customers and job applicants.

In that controller capacity, we do not take decisions producing legal effects concerning you, or similarly significantly affecting you, based solely on automated processing without human involvement. Where we train, develop or improve our own AI models and services for our own purposes, we use anonymised or aggregated data wherever possible. Where anonymised or aggregated data is not sufficient, we process personal information as a controller for these purposes in reliance on our legitimate interests in developing, testing and improving our products and services (Art 6(1)(f)), having balanced those interests against your rights and freedoms. You may object to this processing as described in the 'Your rights in respect of your personal information' section below.

  1. Data storage and retention

Your personal information is stored by Digital Genius on its servers, and on the servers of the cloud-based database management services Digital Genius engages, located in the United States. Digital Genius retains service data for the duration of the customer's business relationship with Digital Genius and for a period of time thereafter, to analyse the data for Digital Genius's own operations, and for historical and archiving purposes associated with Digital Genius's services.

Digital Genius retains customer data until such time as it no longer has business value and is purged from Digital Genius systems. All personal information that Digital Genius controls may be deleted upon verified request from data subjects or their authorised agents, subject to legal, regulatory, or similarly compelling issues that prohibit or allow exceptions to deletion.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

6. Recipients of personal information

We may also share your personal information with the following (as required in accordance with the uses set out in Annex 1):

(a) Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf. Depending on the activity, these may include cloud hosting and infrastructure providers, analytics and business intelligence providers, CRM and marketing providers, identity and authentication providers, accounting and billing providers, recruitment and applicant-tracking providers, and our professional advisers.

(b) Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

(c) Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Digital Genius, its users or others.

(d) Other members of the Digital Genius group: we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1.

We may also share your personal information with the following (as required in accordance with the uses set out in Annex 1):


(a) Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf. Depending on the activity, these may include cloud hosting and infrastructure providers, analytics and business intelligence providers, CRM and marketing providers, identity and authentication providers, accounting and billing providers, recruitment and applicant-tracking providers, and our professional advisers.


(b) Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.


(c) Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Digital Genius, its users or others.

(d) Other members of the Digital Genius group: we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1.

We may also share your personal information with the following (as required in accordance with the uses set out in Annex 1):

(a) Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf. Depending on the activity, these may include cloud hosting and infrastructure providers, analytics and business intelligence providers, CRM and marketing providers, identity and authentication providers, accounting and billing providers, recruitment and applicant-tracking providers, and our professional advisers.

(b) Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

(c) Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Digital Genius, its users or others.
(d) Other members of the Digital Genius group: we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1.

7. Marketing and advertising

From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on your products and services.

Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

We will only send you marketing messages if you have given us your consent to do so, unless consent is not required under applicable law (e.g. in certain circumstances where we have a pre-existing customer relationship your consent is not required). You can withdraw your consent or opt out of receiving further communications at a later date by clicking on the unsubscribe link at the bottom of our marketing emails.

We may also ask third parties to send you messages asking for your feedback on our behalf. If you give us permission to do so, we may share your contact details with such parties for this purpose.

8. Storing and transferring your personal information

Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage.


International Transfers of your Personal Information. Digital Genius has operations in the United Kingdom and in the United States. Information we collect about you will be processed in either or both countries. The United States has not sought nor received a finding of "adequacy" from the United Kingdom under Article 45 of the UK GDPR. Pursuant to Article 46 of the UK GDPR, Digital Genius provides for appropriate safeguards by entering binding, standard data protection clauses (SCCs), enforceable by data subjects in the European Economic Area (EEA) and the UK, together with a Data Processing Addendum (DPA) with its vendors wherever feasible and appropriate.

Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage.


International Transfers of your Personal Information. Digital Genius has operations in the United Kingdom and in the United States. Information we collect about you will be processed in either or both countries. The United States has not sought nor received a finding of "adequacy" from the United Kingdom under Article 45 of the UK GDPR. Pursuant to Article 46 of the UK GDPR, Digital Genius provides for appropriate safeguards by entering binding, standard data protection clauses (SCCs), enforceable by data subjects in the European Economic Area (EEA) and the UK, together with a Data Processing Addendum (DPA) with its vendors wherever feasible and appropriate.

9. Your rights in respect of your personal information

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:


(a) Right of access. You have the right to obtain access to your personal information.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f) Right to withdraw consent. If you have provided consent to any processing of your personal information, you have a right to withdraw that consent.


You also have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.


Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.


If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. You may also review and edit some of the personal information you have submitted to us by logging into your account on our Site.


You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:


(a) Right of access. You have the right to obtain access to your personal information.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f) Right to withdraw consent. If you have provided consent to any processing of your personal information, you have a right to withdraw that consent.


You also have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.


Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.


If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. You may also review and edit some of the personal information you have submitted to us by logging into your account on our Site.


You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

10. Cookies and similar technologies

Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. The specific cookies we use are set out in our cookie policy which you can access here.

11. Links to third party sites

Our Site may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

12. Changes to this policy

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page

13. Contacting us

Please contact [INSERT EMAIL ADDRESS] if you have any questions, comments and requests regarding this Privacy Policy.

This privacy policy was last modified on the 17th August 2026.

Annex 1 - Personal information DigitalGenius collectes and how it is used

Category of personal information

How we use it

Legal basis for processing

Contact details (name, business, email, phone number). Source: provided by you directly, or obtained from third parties such as LinkedIn or other social networks.

Provision of services on the Site; administration of account; responding to your enquiries, requests and messages submitted through our Site (including via any chat function); marketing and advertising; to communicate with you regarding changes to our policies, other terms and administrative information such as reminders, technical notices, updates and security alerts

Performance of a contract and to take steps prior to entering into a contract (Art 6(1)(b)); for marketing, either consent (Art 6(1)(a)) where required or legitimate interests (Art 6(1)(f)); for administrative communications, legitimate interests (Art 6(1)(f))

Technical information (IP address, browser type, internet service provider, device identifier, login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location)

Analytics; Improve the Site to ensure content is presented in the most effective manner; Marketing and advertising; To ascertain your preferences

Consent (Art 6(1)(a)) for analytics and advertising cookies (where required under PECR); legitimate interests (Art 6(1)(f)) for security, fraud prevention, and ensuring the Site functions and content is presented effectively

Usage data (clickstream to, through and from the Site, pages viewed and searched for, page response times, length of visits, referral source/exit pages, page interaction information, date and time pages accessed, and website navigation and search terms used)

Analytics; Improve the Site; Marketing and advertising; To ascertain your preferences

Consent (Art 6(1)(a)) for analytics and advertising cookies (where required under PECR); legitimate interests (Art 6(1)(f)) for improving the Site and understanding how it is used

Job applicants — Name, contact details, CV and application data

Recruitment and assessment

Art 6(1)(b) contract; Art 6(1)(a) consent; Art 6(1)(c) legal obligation

Prospects and marketing contacts — Name, work email, job title, employer, phone. Source: provided by you directly, or obtained from third parties such as LinkedIn or other social networks.

Sales and marketing outreach, demos, responding to enquiries

Art 6(1)(a) consent OR Art 6(1)(f) legitimate interests (subject to the Privacy and Electronic Communications Regulations (PECR))

Customer personnel (platform users) — Name, work email, job title, account credentials, MFA factors, dashboard usage

Provide platform access, account administration, support and security

Art 6(1)(b) contract / Art 6(1)(f) where the individual is not the contracting party

Customer personnel (platform users) — Name, work email, job title, account credentials, MFA factors, dashboard usage

Provide platform access, account administration, support and security

Art 6(1)(b) contract / Art 6(1)(f) where the individual is not the contracting party

End-user content

Training, developing, testing and improving our own AI models and services, using anonymised or aggregated data wherever possible

Legitimate interests in developing and improving our own products and services (Art 6(1)(f)); use of end-user content for this purpose is carried out as a controller to the extent permitted under the relevant customer agreement and DPA