Draft — pending legal review. The wording below has been drafted for
counsel review; it must be approved before the Snapshot is made public
(pre-launch checklist §13).
Privacy Policy
Qognexus Readiness Snapshot — Echelon Labs
What we collect
When you complete a Readiness Snapshot we process your answers to the seven questions,
your first name, last name, job title, and work email, and basic technical metadata
(referrer, UTM parameters, locale, time taken).
Why we process it
To generate your Snapshot report and send it to you, and — only if you separately opt in —
to send you occasional insights on change readiness. The two consents are recorded separately;
you can withdraw the marketing consent at any time via the unsubscribe link in any email.
How AI is used in your report
Your report includes a short written narrative that reflects back the tension your answers
point to. That narrative is generated by an artificial-intelligence language model from the
answers you give — it is not written by a person for each report. Everything else — the
questions, the scoring logic, and the structure of the report — is designed and fixed by us;
the AI only writes that one narrative passage.
- Who provides the AI. The model is operated by Anthropic PBC, which
processes your answers solely to generate your narrative and acts as our processor under a
data processing agreement. Under that agreement, your responses are not used to train
Anthropic's models.
- International transfers. Where generating your narrative involves
transferring personal data outside the EEA or the UK, that transfer is covered by the European
Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum,
together with Anthropic's data processing agreement.
- No automated decisions about you (GDPR Article 22). The report is
informational — a diagnostic read, not a decision. It does not approve, reject, rank, or score
you as an individual, and it produces no legal or similarly significant effect. No
solely-automated decision-making within the meaning of Article 22 of the UK and EU GDPR
takes place.
- Transparency (EU AI Act Article 50). We disclose here, plainly, that
the written narrative in your report is generated by AI. If you would like to understand how
your report was produced, contact us at
snapshot@qognexus.com.
Retention (to be finalized by legal)
The final policy must state the research-retention basis: pseudonymised responses, retained
under legitimate interests for 36 months, with a route to object.
Your rights
You may request access to, correction of, or deletion of your personal data, and you may
object to processing. Contact snapshot@qognexus.com.
Policy version: 1.0 (draft)