LeaderForge Privacy Policy

This Privacy Policy explains how Dataphi Analytics Labs Private Ltd ("LeaderForge", "we", "us", or "our") collects, uses, shares, and protects personal information when you use:

• the LeaderForge website and web application at https://leaderforge.ai and its subdomains; and
• the LeaderForge mobile applications for iOS and Android (collectively with the website, the "Services").

This is a single, common policy covering all of the above. By using the Services, you agree to the practices described here. If you do not agree, please do not use the Services.

1. About LeaderForge

LeaderForge is a leadership-development and coaching platform. Organizations ("Customers") use LeaderForge to deliver coaching programs, learning content, assessments, journaling, and progress reporting to their members ("Participants"), and to enable coaches and engagement managers to support those Participants. Participants can also enrol individually and LeaderForge provides the same services.

2. Scope of this policy

This policy applies to personal information we process across the website and the mobile apps. It does not cover:

• third-party websites, products, or services we link to (they have their own policies); or
• your employer's or organization's own use of your data outside the Services.

3. Controller vs. processor (important for organization members)

LeaderForge is a business-to-business platform, so responsibility for your data depends on how you use it:

• When your organization provides LeaderForge to you (for example, your employer enrolls you in a coaching program), that organization is typically the data controller and decides why and how your data is processed. LeaderForge acts as a data processor / service provider and processes your data on the organization's behalf and instructions. If you have questions about that processing or want to exercise your rights, please contact your organization first; we will support them in responding.
• When you interact with us directly (for example, visiting our website, contacting us, or signing up independently), LeaderForge is the data controller.

4. Information we collect

We collect the following categories of information:

a. Account and identity information.

Name, email address, password (stored only as a secure hash), profile photo (if you upload one), role (e.g., participant, coach, engagement manager, administrator), organization/tenant membership, and language or display preferences.

b. Coaching and assessment content.

This is the core of the Services and may include information you or others provide about you:

• responses to self-assessments, 360-degree feedback, quizzes, and adaptive ("competency") assessments;
• journal entries you write;
• messages and chat you send within the Services;
• reactions, comments, notes, and progress on learning content and videos;
• coaching notes, feedback, and reports associated with your programs.

Some of this content can be personal and reflective in nature. We handle it as confidential.

c. Usage and device information.

How you interact with the Services (pages/screens viewed, features used, actions taken), plus technical data such as IP address, browser type, operating system, device type and identifiers, app version, and diagnostic/crash logs.

d. Mobile device permissions (mobile apps only).

With your permission, the apps may access:

• Camera / photos — only if you choose to take or upload a profile photo or other content;
• Push notifications — to send you program reminders and updates (see Section 11);
• Device information — basic device details used for compatibility, security, and diagnostics.

You can grant or revoke these permissions at any time in your device settings.

e. Cookies and similar technologies.

On the website we use cookies and local storage for authentication (keeping you signed in), preferences, security, and analytics. See Section 10.

f. Communications.

If you contact support or us directly, we keep those communications.

Payments.

LeaderForge does not collect or store payment card details within the Services; billing (if any) is handled between us and your organization under separate agreement.

5. How we use information, including AI features

We use personal information to:

• provide, operate, and secure the Services and your account;
• deliver coaching programs, learning content, assessments, journaling, scheduling, and messaging;
• generate assessment results, competency reports, and personalized development insights;
• send you service-related and program-related notifications (including push notifications);
• provide customer support and respond to your requests;
• monitor, debug, and improve reliability, performance, and safety of the Services;
• detect, prevent, and address fraud, abuse, and security incidents; and
• comply with legal obligations.

Artificial-intelligence (AI) processing. Some features use AI to turn your content into helpful output — for example, generating narrative feedback and development insights from your assessment responses, and processing text, documents, or speech you provide. To do this, the relevant content is sent to our AI subprocessor (Microsoft Azure OpenAI Service, and related Azure Document Intelligence and Azure Speech services) solely to generate the feature output for you. Under Microsoft's terms for these enterprise services, your content is not used to train the underlying foundation models and is not shared with other customers. We do not use your private coaching or assessment content to train our own models for unrelated purposes.

We do not sell your personal information, and we do not use your private coaching, journal, or assessment content for advertising.

6. Third-party service providers (sub-processors)

We use trusted third parties to run the Services. They process personal information only on our instructions and under appropriate contractual protections. Our current key sub-processors are:

7. Legal bases for processing (EEA/UK)

Where the EU/UK GDPR applies and LeaderForge is the controller, we rely on: performance of a contract (to provide the Services), legitimate interests (to secure and improve the Services), consent (e.g., for certain cookies, push notifications, and optional camera access — which you can withdraw), and legal obligation. Where your organization is the controller, they determine the legal basis.

8. How we share information

We share personal information only as follows:

• Within your organization's program. Coaching is collaborative: your coaches, engagement managers, and program administrators within your organization may see information appropriate to their role (for example, your assessment results and progress). 360-degree feedback is presented in aggregate; we design reports so individual raters' responses are not singled out.
• With subprocessors (Section 6), under contract.
• For legal reasons — to comply with law, enforce our terms, or protect the rights, safety, and security of users and the public.
• In a business transfer — as part of a merger, acquisition, or sale of assets, subject to this policy.
• With your consent — for any other sharing.

We do not sell personal information or share it for cross-context behavioral advertising.

9. International data transfers

We and our subprocessors may process information in countries other than yours, including the United States. Where required, we use appropriate safeguards (such as the European Commission's Standard Contractual Clauses) for such transfers.

10. Cookies and analytics

On the website we use:

• Strictly necessary cookies/local storage for sign-in, security, and core functionality; and
• Analytics (e.g., Google Analytics) to understand usage and improve the Services.

You can control non-essential cookies through your browser settings and any cookie controls we provide.

11. Push notifications

The mobile apps can send push notifications for program reminders and updates. We use Firebase Cloud Messaging and store a device push token to deliver them. You can turn notifications off at any time in your device settings.

12. Children's privacy

The Services are intended for use by adults in a professional context and are not directed to children. We do not knowingly collect personal information from anyone under 16. If you believe a child has provided us personal information, contact us and we will delete it.

13. Data retention

We retain personal information for as long as your account is active and as needed to provide the Services, and afterward as required to comply with legal obligations, resolve disputes, and enforce agreements. Where LeaderForge acts as a processor, retention and deletion follow your organization's instructions and our agreement with them. When no longer needed, we delete or de-identify the information.

14. Security

We use technical and organizational measures to protect personal information, including encryption in transit, hashed passwords, access controls, tenant isolation, and monitoring. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

15. Your rights and choices

Depending on where you live, you may have the right to access, correct, delete, port, or restrict/object to the processing of your personal information, and to withdraw consent. You can exercise many of these directly in the app (for example, editing your profile or deleting your account). To make a request, use the contacts in Section 17.

• EEA/UK residents (GDPR): the rights above, and the right to lodge a complaint with your local data protection authority.
• California residents (CCPA/CPRA): the rights to know, delete, correct, and opt out of "sale"/"sharing" (we do not sell or share personal information as defined by the CPRA), and the right not to be discriminated against for exercising your rights.
• Organization members: if your organization is the controller, we will refer your request to them or act on their instructions.

We will not discriminate against you for exercising your rights. We may need to verify your identity before acting on a request.

16. Changes to this policy

We may update this policy from time to time. We will post the updated version here with a new "Last updated" date and, where appropriate, notify you. Your continued use of the Services after changes take effect constitutes acceptance.

17. Contact us

Dataphi Analytics Labs Private Ltd.

1124, Prestige Pinewood, Koramangala I Block, Bengaluru - 560034

Privacy inquiries: support@leaderforge.ai

Store-specific note

This policy is the privacy policy referenced by our listings on the Apple App Store and Google Play Store. It is published at https://leaderforge.ai/privacy-app. Our data collection and use, as summarized in the stores' privacy labels/Data Safety forms, are described in full above.