Privacy Policy

Last updated: 17 June 2026

This policy explains what personal data the Headway Skills Work Skills Test (the “Assessment”) collects, why we collect it, and the rights you have over it. It applies to the assessment hosted at assessment.headwayskills.com.

Who we are

The data controller is Headway AI ApS (CVR 46466934), Belvederekaj 2, 7. tv., 2450 København SV, Denmark. If you have any questions about this policy or your data, contact us at peter@headwayskills.com.

What we collect

When you take the Assessment, we collect:

• Your answers — your responses to the assessment items and how long each page took (used to score and improve the test).
• About you — your first name, email address and years of work experience.
• Context inferred by the service — approximate country supplied by Cloudflare, browser language, the language selected in the Assessment, and first-touch campaign parameters or external referrer when present. We do not store your IP address in the Assessment database.
• Technical data — a session identifier stored in a cookie so you can leave and resume, and standard infrastructure logs generated when you load the site.

First name, email address and work experience are required to generate, show and deliver your results. Marketing remains optional.

How we use your data, and our legal basis

• To produce and show your results — necessary to provide the service you asked for (GDPR Art. 6(1)(b)).
• To email your results to you — the transactional result email is sent automatically when you submit the final results form. We do this to provide the completed Assessment service (GDPR Art. 6(1)(b)).
• To send you marketing — skill tips, exercises, product updates and offers — only if you opt in with the separate marketing checkbox (your consent, GDPR Art. 6(1)(a)). You can withdraw at any time (see below).
• To improve the Assessment and develop benchmark insights — using anonymized and aggregated data, so individual responses are not identifiable. This is our legitimate interest in building a better, evidence-based product (GDPR Art. 6(1)(f)).

The transactional result email and marketing are separate. Completing the Assessment does not sign you up for marketing; marketing is sent only if you actively select the separate marketing checkbox.

Sharing your results

Your results page has a shareable link (for example, to post on LinkedIn). If you choose to share that link, anyone who has it can see the shared profile — your first name and your top skills. It does not expose your email address, your individual item answers, or your other demographic details. Only share the link if you are comfortable with that.

Who we share data with

We do not sell your personal data. We share it only with service providers that help us run the Assessment, under contracts that require them to protect it and use it only on our instructions:

• Hosting — Hetzner Online GmbH hosts the application and database on servers located in the EU (Helsinki, Finland).
• Email delivery — we use Resend (resend.com) to send your results and any marketing emails you have opted into.

International transfers

Our application and database are hosted within the EU. Our email provider, Resend, is based in the United States, so sending you an email may involve transferring your name and email address outside the EU/EEA. That transfer is covered by appropriate safeguards — the EU Standard Contractual Clauses, under Resend’s data processing terms.

Cookies

We use a single essential cookie (session_id) to keep your place in the assessment and let you resume. It is not used for advertising or cross-site tracking.

How long we keep your data

We keep your personal data (your responses and contact details) for up to 12 months. If you are an active Headway Skills customer, we keep it for as long as your relationship with us is active, and for 12 months after it ends. If you opted into marketing, we keep your contact details until you unsubscribe. Anonymized and aggregated data, which can no longer identify you, may be kept indefinitely. You can ask us to delete your personal data at any time (see below).

Your rights

If you are in the EU/EEA or UK, you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data deleted;
• object to or restrict certain processing;
• withdraw consent (for marketing) at any time — use the unsubscribe link in any marketing email, or contact us;
• receive your data in a portable format;
• lodge a complaint with your supervisory authority. In Denmark this is Datatilsynet (datatilsynet.dk).

To exercise any of these rights, email peter@headwayskills.com.

Children

The Assessment is intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18; if you believe a minor has provided us data, contact us and we will delete it.

Changes to this policy

We may update this policy as the product evolves. We will change the “last updated” date above and, for material changes, take reasonable steps to let you know.

Contact

Questions or requests: peter@headwayskills.com.