Privacy Policy
Registered office: 21st Floor, The Phoenix Building, 23 Luard Road, Wan Chai, Hong Kong S.A.R.
Effective date: 18 May 2026
Last updated: 18 May 2026
privacy@insyteful.ai
Hong Kong S.A.R.
Insyteful Limited (“Insyteful”, “we”, “us”, “our”) is a Hong Kong–incorporated learning technology company. We provide an AI‑powered learning platform for small and mid‑sized organisations across the Asia‑Pacific region.We take privacy seriously. This policy explains how we collect, use, share, and protect personal data — under the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”), the EU General Data Protection Regulation (“GDPR”), the UK GDPR, and other applicable data protection laws.For privacy matters, contact us at privacy@insyteful.ai or by post at the address above.
This policy describes how we handle personal data of:
For platform learner data processed under a customer subscription, Insyteful acts as a data processor on behalf of the customer organisation, which is the data controller. A separate Data Processing Addendum between Insyteful and the customer governs that relationship. This policy applies to all other interactions.
Name, job title, organisation, work email, work phone, work address, professional profile links (e.g. LinkedIn).
Login credentials, account preferences, language and time‑zone settings, role and permissions within your organisation's account.
Courses enrolled, completed, time spent learning, assessment results, skill profiles, certificates earned, learning path progress, manager feedback, and other records of platform activity.
For customer organisations: company billing details, purchase order references, invoices. Payment card details are handled by our payment processor (Stripe) and are not stored by Insyteful.
Records of correspondence with us (email, chat, support tickets, meetings), survey responses, feedback, and call notes.
Marketing preferences, email open and click activity, event attendance, content downloads, webinar registrations.
IP address, browser type, device identifiers, pages viewed, referring URL, time and duration of visits, and similar technical data. Cookies and similar technologies are described in Section 9.
For applicants: CV, cover letter, work history, references, right‑to‑work documentation, interview notes, assessment results.
We do not knowingly collect sensitive personal data (such as data revealing racial or ethnic origin, religious beliefs, health data, or biometric data). If sensitive data is required for a specific purpose (e.g. accessibility accommodations), we will collect it only with your explicit consent and a clear lawful basis.
The table below sets out our processing purposes, the lawful basis we rely on under GDPR, and the corresponding basis under PDPO.
When we rely on consent, you can withdraw it at any time without affecting the lawfulness of processing before withdrawal. When we rely on legitimate interests, we have assessed that those interests are not overridden by your privacy rights, and you can object at any time.
We share personal data only with the following categories of recipients, and only as needed:
All processors are bound by written contracts requiring them to process personal data only on our instructions and to apply appropriate security measures.
For learners using the platform under an employer subscription, we share learner records (e.g. course completions, assessment results, compliance evidence) with that customer organisation. The customer is the data controller for that learner data.
Lawyers, accountants, auditors, tax advisors, and corporate service providers retained by Insyteful.
Where required by law, court order, or lawful regulatory request, including the Hong Kong Inland Revenue Department, the Hong Kong Companies Registry, and relevant financial‑services or data‑protection regulators.
If Insyteful is involved in a merger, acquisition, financing, restructuring, or sale of all or part of its business, personal data may be transferred to the relevant counterparty or successor entity, subject to confidentiality and continued protection.
We share personal data with any other third party only with your specific, informed consent.
We do not sell personal data. We do not share personal data with third parties for their own marketing purposes.
Insyteful is based in Hong Kong. Our service providers are located in Hong Kong, Singapore, other Asia‑Pacific jurisdictions, the European Union, the United Kingdom, and the United States.
Where we transfer personal data across borders, we rely on appropriate safeguards, including:
You can request more information about the safeguards in place for specific transfers by emailing privacy@insyteful.ai.
We retain personal data only for as long as necessary for the purposes set out in this policy.
At the end of the retention period, we securely delete or fully anonymise the data.
Our website uses:
We do not currently use advertising or cross‑site tracking cookies. You can manage non‑essential cookies through our cookie banner and your browser settings.
A separate Cookie Notice sets out the specific cookies in use, their purpose, and their duration.
Subject to applicable law, you have the right to:
To exercise any of these rights, email privacy@insyteful.ai. We will respond within 30 calendar days. We may ask you to verify your identity before acting on a request.
If you are dissatisfied with our response, you have the right to complain to:
We use appropriate technical and organisational security measures, including:
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, affected individuals within statutory timeframes (72 hours under GDPR; without undue delay under PDPO).
Insyteful's services are designed for business use by professionals. We do not knowingly collect personal data from individuals under the age of 18. If you believe we have collected data from a minor, please contact us and we will delete it.
Our website and platform may contain links to, or integrate with, third‑party websites and services. This policy does not apply to those services. We encourage you to read the privacy policies of any third party before providing personal data to them.
We may update this policy from time to time to reflect changes in our practices, services, or legal requirements. Material changes will be communicated through the website and, where appropriate, by direct notice to active customers. The “Last updated” date at the top of this policy shows when it was last revised. We encourage you to review this policy periodically.
Privacy queries and rights requests: privacy@insyteful.ai
Privacy Officer
Insyteful Limited
21st Floor, The Phoenix Building23 Luard RoadWan ChaiHong Kong S.A.R.