Privacy Policy

1. Who we are

The Organizational Accountability Chain Snapshot ("the Snapshot," "the Service") is provided by Clearness Coaching Limited ("we," "us," "our"), a coaching practice based in Hong Kong.

Contact for privacy matters: lucy.qian@clearnesscoaching.com

2. What information we collect

When you complete the Snapshot, we collect:

• Contact information: your email address, and optionally your name.
• Company/organizational information: your company name (or a company code assigned to your organization), and demographic details you provide about your role and organization.
• Your survey responses: your answers to the diagnostic questions, including a free-text reflection question.
• Derived results: scores and a summary category calculated from your answers.
• Technical information: basic browser/device information (user agent), used only for troubleshooting. We do not collect your IP address, precise location, or any tracking identifiers beyond what is listed here.

We do not collect this information unless you choose to provide it by completing the Snapshot, and you must explicitly consent before your responses are saved.

3. Why we collect it, and how we use it

We use this information to:

• Generate your personalized diagnostic report (shown on-screen and as a downloadable PDF).
• Email you your progress-save link, a completion confirmation, and your report, if you provide an email address.
• Allow your coach (Clearness Coaching) to review your results as part of a professional coaching engagement.
• Improve the Snapshot tool itself, using aggregated, non-identifiable data only (see Section 5).

We do not use your information for advertising, and we do not sell your information to any third party.

4. Who we share it with

We use a small number of third-party services to operate the Snapshot. Each acts as a data processor on our behalf — they do not independently use your data for their own purposes:

• Supabase — our database and file storage provider. Your data is hosted in a Singapore data center.
• Postmark — our transactional email provider, used to send the emails described in Section 3.
• Plausible Analytics — a privacy-focused, cookieless analytics service used only on our public-facing pages to understand overall traffic. Plausible does not track individual survey respondents or their answers.

We do not otherwise share, sell, or disclose your personal data to any third party, except where required by law.

5. How long we keep your information

We retain your identifiable information for 36 months from the date you complete (or last save progress on) the Snapshot.

After 36 months, your record is automatically anonymized rather than deleted outright: your email address, technical information, and free-text response are permanently removed, and your downloadable PDF report is deleted from storage. Your numerical scores and category results are retained indefinitely in anonymized form, so we can understand patterns across many respondents over time — but this anonymized data can no longer be linked back to you.

If you would like your data deleted earlier than this schedule, see Section 7.

6. Where your data is stored

Your data is stored on servers located in Singapore, within the same Asia-Pacific region as Hong Kong. We do not transfer your identifiable data outside this region.

7. Your rights

You have the right to:

• Access the personal data we hold about you.
• Correct any inaccurate personal data.
• Request early deletion of your data, ahead of the standard 36-month retention period.

To exercise any of these rights, contact us at lucy.qian@clearnesscoaching.com. We aim to respond within 40 days, in line with Hong Kong's statutory requirements.

8. Security

We take reasonable technical measures to protect your data, including:

• Encryption of data in transit (HTTPS) and at rest.
• Restricted database access — only authorized administrators, who must authenticate with a password and a second verification factor (two-factor authentication), can view respondent data.
• A logged record of administrative actions taken on respondent data.
• Regular automated backups.

No system can guarantee absolute security, but we take these precautions seriously given the sensitive, professional nature of the information you share.

9. Children's data

The Snapshot is a professional tool intended for use by adult executives and organizational leaders. We do not knowingly collect data from children, and the Service is not directed at them.

10. Changes to this policy

We may update this policy from time to time. The "Last updated" date at the top will reflect the most recent revision. Material changes will be reflected on this page before they take effect.

11. Contact us

Questions about this policy, or about your data, can be sent to lucy.qian@clearnesscoaching.com.