1. WHO WE ARE

GenHQ ("GenHQ," "we," "us," or "our") is an online community and education platform providing training, resources, and community access for entrepreneurs and business owners.

Data Controller: GenHQ The Great Barn, Wilton Park, Beaconsfield, HP9 2WH, United Kingdom Email: [email protected]

2. INFORMATION WE COLLECT

A. Information You Provide Directly

Account/Registration Data: Name, email address, username, and password when you create an account or join our Skool community.

Profile Information: Any biography, photo, location, or other details you add to your profile.

Payment Information: Processed by our third-party payment processor (e.g., Stripe). We do not store full credit card numbers.

Communications: Messages, emails, support requests, survey responses, or feedback you send us.

Community Content: Posts, comments, questions, or other content you submit within our community.

Course/Program Participation: Enrollment data, course progress, and completion records.

B. Information Collected Automatically

Usage Data: Pages viewed, links clicked, features accessed, and time spent on our platforms.

Device & Technical Data: IP address, browser type, operating system, device identifiers, and referring URLs.

Cookies & Similar Technologies: See Section 6 for details.

Email Engagement Data: Whether you open emails we send and which links you click.

C. Information from Third Parties

Platform Data: Information from Skool about your membership and activity.

Payment Processors: Transaction confirmation and billing status from processors like Stripe.

Marketing & Analytics Platforms: Data from Meta (Facebook/Instagram), Google, or email service providers.

Referrals: Information provided by others who refer you to our community.

3. HOW WE USE YOUR INFORMATION

We use the information we collect to:

- Create and manage your account and membership

- Deliver courses, content, community access, and services you've enrolled in or purchased

- Process payments and send transaction confirmations

- Send emails, newsletters, program updates, and promotional communications (where you have opted in or where permitted by law)

- Respond to your questions, comments, or support requests

- Improve our platform, content, and user experience through analytics

- Personalize your experience and deliver relevant content

- Run advertising campaigns on platforms such as Facebook, Instagram, and Google

- Comply with legal obligations and enforce our Terms of Service

- Detect and prevent fraud, abuse, or security incidents

B. Use of Community Content for Marketing and Advertising

By posting content within the GenHQ community — including written posts, comments, photos, videos, testimonials, results, or other submissions — you grant GenHQ a non-exclusive, royalty-free, worldwide, perpetual license to use, reproduce, adapt, publish, and display that content across our marketing channels, including but not limited to social media platforms (Facebook, Instagram, TikTok, YouTube), paid advertising campaigns, email marketing, website pages, and promotional materials.

We will never misrepresent your results or words. Where reasonably practicable, we will credit you or seek your approval before using your content in paid advertising. You may withdraw this permission at any time by contacting [email protected], though this will not affect any prior use.

4. LEGAL BASIS FOR PROCESSING (GDPR / UK GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data only when we have a valid legal basis:

Contract Performance: Processing necessary to fulfill your membership or purchase.

Legitimate Interests: Processing for our legitimate business interests, such as improving our services or preventing fraud, where your rights do not override ours.

Consent: Where you have given clear, specific consent — such as subscribing to our email list. You may withdraw consent at any time.

Legal Obligation: Processing required to comply with applicable law or regulatory requirements.

5. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We may share your information with:

A. Service Providers

- Skool – Community hosting platform

- Stripe – Secure payment processing

- GoHighLevel / Email Marketing Platform – Email and CRM automation

- Meta (Facebook/Instagram) – Advertising and audience management

- Google Analytics / Google Ads – Analytics and advertising

- Zoom or similar video platforms – Live sessions and webinars

These providers are contractually required to use your data only to perform services for us.

B. Business Transfers If GenHQ is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you if this occurs.

C. Legal Requirements We may disclose your information if required by law, court order, or government authority, or to protect the rights and safety of GenHQ, our members, or the public.

D. With Your Consent We may share your information for other purposes when we have obtained your explicit consent.

6. COOKIES AND TRACKING TECHNOLOGIES

We and our third-party partners use cookies, pixels, and similar tracking technologies to:

- Keep you logged in and remember your preferences

- Understand how you use our content and community

- Measure the effectiveness of our advertising

- Deliver personalized advertising across the web

Types of Cookies:

Essential Cookies: Required for core functionality. Cannot be disabled.

Analytics Cookies: Help us understand usage patterns (e.g., Google Analytics).

Marketing/Advertising Cookies: Track ad performance and retargeting (e.g., Meta Pixel, Google Ads).

Preference Cookies: Remember your settings.

EU/UK users: Non-essential cookies will only be set with your consent. You can manage cookies through your browser settings at any time. For more information, visit allaboutcookies.org.

7. EMAIL COMMUNICATIONS

By joining our community or purchasing from us, you may receive transactional emails (receipts, account notices) and, where you have opted in, marketing emails (newsletters, promotions, updates).

You can unsubscribe at any time by clicking the "Unsubscribe" link in any marketing email or by emailing [email protected].

Transactional emails related to your account or purchases may not be opted out of while your account is active.

We comply with the CAN-SPAM Act (US), CASL (Canada), and UK/EU GDPR email marketing rules.

8. DATA RETENTION

We retain your personal information for as long as your account is active or as needed to provide our services, and as required by law (e.g., financial records are typically retained for 6–7 years under UK law). When data is no longer needed, we securely delete or anonymize it.

9. SECURITY

We implement commercially reasonable technical and organizational security measures to protect your personal information. However, no method of internet transmission is 100% secure. In the event of a data breach affecting your rights, we will notify you as required by applicable law.

10. INTERNATIONAL DATA TRANSFERS

GenHQ is based in the United Kingdom. If you are accessing our services from outside the UK — including from the EU, US, Canada, or Australia — your information may be transferred to and processed in countries with different data protection laws. For transfers from the EU/EEA, we rely on Standard Contractual Clauses (SCCs) or other appropriate safeguards as required by applicable law.

11. YOUR RIGHTS – EU, UK, AND EEA RESIDENTS (GDPR / UK GDPR)

You have the right to:

Access: Request a copy of the personal data we hold about you.

Rectification: Request correction of inaccurate or incomplete data.

Erasure: Request deletion of your personal data ("right to be forgotten"), subject to legal limitations.

Restrict Processing: Request that we limit how we use your data in certain circumstances.

Data Portability: Receive your data in a structured, machine-readable format.

Object: Object to processing based on legitimate interests or for direct marketing.

Withdraw Consent: Where processing is based on consent, withdraw it at any time.

To exercise any of these rights, email [email protected]. We will respond within 30 days. You may also lodge a complaint with:

UK: Information Commissioner's Office (ICO) – ico.org.uk

EU: Your national data protection authority (edpb.europa.eu)

12. YOUR RIGHTS – CALIFORNIA RESIDENTS (CCPA / CPRA)

California residents have the right to:

Know: Request disclosure of the personal information we've collected, its sources, purposes, and with whom it's shared.

Delete: Request deletion of your personal information, subject to certain exceptions.

Correct: Request correction of inaccurate personal information.

Opt Out of Sale: We do not sell personal information.

Non-Discrimination: We will not discriminate against you for exercising your rights.

Categories of personal information collected: Identifiers (name, email, IP address); internet activity (browsing, community interactions); commercial information (purchase history); inferences drawn from the above.

To submit a request, email [email protected] with the subject line "California Privacy Request." We will respond within 45 days.

13. YOUR RIGHTS – CANADA AND AUSTRALIA

Canada (PIPEDA / Quebec Law 25): You may request access to or correction of your personal data and withdraw consent at any time. Quebec residents have additional rights including data portability and the right to be forgotten.

Australia (Privacy Act 1988): You may request access to or correction of your personal information. If unsatisfied with our response, you may contact the Office of the Australian Information Commissioner at oaic.gov.au.

Contact us at [email protected] for any of the above requests.

14. CHILDREN'S PRIVACY

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children. If you believe we have done so inadvertently, please contact [email protected] and we will delete the information promptly.

15. THIRD-PARTY LINKS AND SERVICES

Our community and communications may contain links to third-party websites. We are not responsible for their privacy practices. Our use of Skool means Skool's own Privacy Policy also applies — please review it at skool.com/privacy.

16. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date and notify you via email or prominent notice in our community. Continued use of our services constitutes acceptance of the updated policy.

17. CONTACT US

GenHQ The Great Barn, Wilton Park, Beaconsfield, HP9 2WH, United Kingdom Email: [email protected]

We aim to respond to all privacy-related inquiries within 30 days.