Data and privacy
Adeptify Platform Data Handling
How the Adeptify platform handles the data of the people who take part, and of the organizations and consultants who engage us.
This page is for the people who take part in our work, for the organizations and consultants who engage us, and for their data-protection officers. It describes how the platform handles personal data, as it is now.
This website's own forms and fonts are covered by the privacy notice. The outside services the platform uses are listed on sub-processors.
Who we are
Adeptify is operated by Center for Transformative Leadership AS (org. no. 916 323 611), a Norwegian company. Norway is in the EEA, so the EU's General Data Protection Regulation (GDPR) applies to us directly.
Who decides
In data protection, the controller decides why and how personal data is used. A processor handles it on the controller's behalf.
- When an organization engages us, the organization is the controller of its participants' data, and we are its processor.
- When a partner consultant works with their own clients and decides how their data is used, the consultant is the controller and we are their processor. Where the consultant acts for an organization, we are a sub-processor.
- We are the controller where there is no client: someone trying the assessment at our invitation, or a participant who keeps their account after an engagement. We are also the controller of the development copy, of testimonials and pilot feedback, and of inquiries sent through this website.
What data, and what the platform does with it
Depending on what a person takes part in, the platform holds:
| What | For example |
|---|---|
| Account and contact | For example Name, email address, role, organization, and the projects a person belongs to |
| The interview | For example The transcript of the assessment interview |
| Written responses | For example Written responses to other developmental assessments that partner consultants use with their clients |
| Voice | For example Spoken answers and dictated reflections, turned into text as the person speaks. The platform does not keep the audio. |
| What the platform derives | For example Linguistic measurements, the analyses, and the AI-written report |
| Development | For example Reflections, journal entries, learning-loop notes, and the development mentor's comments |
| Technical | For example Sign-in sessions and request logs |
We do not ask for health information or other special categories of personal data. Answers are in a person's own words, so we suggest leaving such details out.
What the platform does with it
- The interview. An AI interviewer asks the questions. They appear as text and are read aloud in a synthetic voice, which the person can mute. Answers can be spoken or typed.
- The measurement and the analysis. Our own software, using standard language-analysis tools, measures the transcript. AI models then analyze it against our rubrics and write the report. The analysis works from a pseudonymized copy of the transcript.
- The report. The development mentor reads it first and releases it to the person. Reports are read on the platform; a PDF copy is made in the reader's own browser.
- Learning loops. The person practices a skill in their own work, with reflections and a journal. In audio mode, an AI practice partner talks the loop through with them, using a synthetic voice and speech-to-text.
- Written responses. If a person asks for prompts while writing, the text so far is sent to an AI model, which asks them to elaborate or clarify. Feedback prepared from the responses reaches the person when their consultant releases it.
Alongside the platform
- Preparing debriefs and learning loops. Our development mentors also use AI tools we have set up for this work. The tools read the person's report and written responses, and a debrief's transcript when the debrief is recorded. They and their providers are on the sub-processor page.
- Partner consultants' own tools. A partner consultant who saves a person's material from the platform, such as a report, is responsible for how they use it from then on, including in any AI tools of their own.
What we do and don't do with it
- We use personal data only to deliver the service: the assessment, the report, development activities and the development mentor's support. Where an organization or a consultant engages us, we use it on their instructions.
- Spoken answers are turned into text, and only the text is assessed. The assessment does not analyze voice, face or other physical signals, and it does not try to read emotions.
- We write instructions for general-purpose AI models; we do not train them.
- The AI providers we use do not use participants' data to train their models.
- We keep a development copy only with the person's consent (below).
The development copy
A pseudonymized copy of a participant's assessment records, which we keep to develop and improve the assessment.
- Kept only with the person's consent, asked separately from agreeing to the interview. Declining changes nothing. Where there is a client, only with its agreement in the engagement.
- We are its controller.
- Stored under a random code. The link to the person is held separately, visible only to our administrators, so that the person can withdraw.
- For our internal use only: never published, never shared.
- Kept for up to five years from the interview, then deleted.
- It is still personal data, so all the rights below apply.
- Interviews taken before this consent existed are used for development only where the person agreed to that in another way.
Development, selection, or both
The assessment can serve a person's development, an organization's decision about a person's readiness for a role, or a decision followed by development. Which it serves is agreed in writing before it begins, and the person is told. When it informs a decision, the report informs the judgment of the people making it: Adeptify does not rank or recommend, and the decision stays with people. Selection brings added obligations for the organization, which we set out with it before the engagement begins.
Our assessment uses AI, and we tell everyone who takes it so. Under the EU AI Act, using AI to inform decisions about hiring or promotion is a high-risk use. The Act's requirements for it apply from 2 December 2027, and we are preparing for them.
Who sees what
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When the assessment serves development
The report is the person's and their development mentor's. The organization does not see it unless the person chooses to share it. What else the organization sees, for example that the person took part, is set out in writing for each engagement.
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A development report stays one
A development report never informs a decision, even if the person offers to share it. If a decision needs the assessment, a new one is agreed for that use.
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When it informs a decision
The decision-makers named in writing in advance see the report. How much of it they see, the summary or the fuller layers, is set out for each engagement. The person can always see what the decision-makers see. A debrief is agreed for each engagement. An engagement can serve a decision and then the person's development, when that is agreed at the outset.
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Development mentors
A development mentor sees the participants in the projects they are assigned to, and releases each report to the person.
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Adeptify's administrators
Our administrators work with the data itself, to run the service and to support the people using it.
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Technical maintenance
The people who maintain the platform's hosting and cloud accounts can reach the data, for maintenance only.
One of the people who maintain our hosting and cloud accounts works from the USA.
Where data is stored
The platform's data is stored with Cloudflare, in its European region. Requests are handled in Cloudflare's network, normally at the data center nearest the person using the platform.
The AI and voice services we use process data where the sub-processor page says. Some of them are in the USA or do not fix where they process it.
Keeping and deleting
- During an engagement, the client sees what was agreed for it.
- When a client's access ends is agreed with the client, and can be revisited as the work goes on.
- A participant's own account is separate from the client's access. Their report, reflections and learning loops stay in it, on the platform, for as long as they use it. Nothing needs to be downloaded.
- Unused accounts are deleted after three years without use, after an email warning.
- The development copy is kept for up to five years from the interview.
Your rights
If the platform holds your data, you can:
- see your data on the platform, save your report as a PDF, and ask us for a copy of everything we hold about you;
- ask for your data to be corrected or deleted;
- withdraw your consent at any time, including your consent to the development copy. Withdrawing does not undo what was done before;
- stop an assessment at any point;
- complain to Datatilsynet, the Norwegian Data Protection Authority.
Where an organization or a consultant is the controller of your data, you can go to them or to us. Either way, we help them answer.
Consent
Before the assessment interview, the platform shows a consent text, and the person agrees to it before the interview begins. The platform records which version they agreed to and when, and offers the text as a download.
When a partner consultant uses another developmental assessment with their clients, the consultant tells them how their data is used.
Testimonials and pilot data
- We publish a testimonial only with the person's written consent to the exact words and to how they are named: name and role, role only, or anonymous. They can withdraw it, and it is then removed.
- We use pilot feedback and outcome data only anonymized and aggregated, never for a group small enough to identify anyone, and only with the organization's agreement and each participant's consent.
- We name an organization as a client only with its written agreement.
Each pilot agreement sets out the specifics: what feedback is collected and when, what we may publish, whether and how the organization is named, its review of any text before publication, and how long the data is kept.
Contact
For questions about how we handle data, or a request about your own, write to privacy@adeptify.co. Center for Transformative Leadership AS, Norway.
Questions about your data?
Write to privacy@adeptify.co →Last updated: 27 October 2026