uses, and shares information about you and the choices you have regarding this
use our products, services, and technology platforms (including the websites and mobile
applications that help us provide the coaching services) (collectively, the “Services”).
services, or applications you may access through our Services. We encourage you to
review the privacy policies of those third parties for more information regarding their
Name and address of the data controller
The data controller is responsible in accordance with the purposes of the General Data
Protection Regulation (GDPR) in accordance with Indian Laws regulations is:
IDQ Innovation Pvt Ltd,
A-27, II Floor
Mohan Co-operative Industrial Estate
New Delhi – 110044, India
PIN CODE: 110044
by revising the date at the top of the policy. In some cases, such as a material change in our
practices, we may provide you with additional notice, such as adding a statement to our
homepage or sending you an email notification. We encourage you to review the Privacy
Policy whenever you access the Services to stay informed about our information practices
and the ways you can help protect your privacy.
COLLECTION OF INFORMATION
If you visit our website or use our mobile applications we will collect certain information about
you. For all users and visitors see Information We Collect Automatically below for details on
what we collect via technology. We collect information you provide directly to us when
interacting with us or using the Services. The specific information we collect depends on the
context of your interactions with Peakperformer as detailed below.
Prospective employees or coaches:
We collect information if you apply for a job or apply to become a coach, request customer
support, or otherwise communicate with us. We will need to collect certain personal
information from you in order to process your application, such as your name, email address,
phone number, location, and work history. This information is used to evaluate your
experience and communicate with you among others.
Sensitive Personal Information or Demographic Information
To be a coach in Peakperformer, you are not required to provide any sensitive personal
information such as financial or demographic information. However, there may be times,
such as testing a new tool or feature, staffing a specific program for customers, or
conducting research studies, where we will ask for your consent to collect demographic
information such as gender, race or ethnicity, or pronouns, or we may request your consent
to record your session. In all such instances your involvement and providing such
information is voluntary, and will have no impact on your ability to coach if you decline. In the
case you provide consent, such consent may be withdrawn at any time.
If you are a registrant on our website and use our coaching services via our website or one
of our mobile applications (“Member”), you will need to provide certain personal information
in order to register your account, such as: name, email address, phone number, location,
and your role or title. This information is required at registration so that we can:
1) create your account;
2) ensure you are matched with a coach in an appropriate time zone;
3) ensure you receive the applicable surveys or questionnaires commensurate with your
We will also collect information as it relates to your use of the platform. For example, we
collect information when you download our mobile application(s) and the versions used.
Through your use of the Services, you will also provide us information to facilitate your
coaching experience. For example, to help you choose the right coach, you will respond to
surveys to help us match you with a coach that aligns with your coaching goals. While these
surveys will help us match you with the right coach, the surveys do not collect any personally
identifying information. You will also be asked to complete an assessment that will allow you
to gain insight into your strengths and weaknesses by asking you a series of questions about
general wellbeing, work-life balance, and stress. To facilitate a robust and meaningful
coaching experience, both you and your coach will have access to your survey responses.
We may also collect information such as your coaching platform usage, development
programs planned and attended, engagement status, session ratings, title, employment
details, and any other information you choose to provide in conjunction with the Services.
You may be asked, at various places within the platform, to provide your opinions on
BetterUp’s services and quality of coaching. These opinions or reviews will be used to
improve our services, and in some cases, may be shared with the coach, on a de-identified
basis, for quality or educational purposes.
Information collected Automatically :
When you access or use the Services, we automatically collect information about you,
including the following:
● Log Information: We log information about your use of the Services, including the
type of browser you use, access times, pages viewed, your IP address, and the page
you visited before navigating to the Services.
● Information Collected by Tracking Technologies: We use different technologies to
collect information, including web beacons. Web beacons are electronic images that
may be used in our Services or emails and help deliver cookies, count visits, and to
understand usage and campaign effectiveness. For more information about cookies,
and how to disable them, please see “Information Collected By Cookies” below.
● Browser local storage. We also store data locally on your device to enhance the
user experience for our Services. For example, browser local storage allows us to
save the state of your current page so that when you return at a later time or refresh
the browser, the page will remain the same. We may also use browser local storage
to: (i) save a list of items the user last used on the website or Services (such as
events and properties the user selected) so we can display “recently viewed items”;
or (ii) marking once a user has seen a tutorial, video, tooltip or onboarding flow so
that the user only sees the content one time.
● Mobile Services. We may also collect information from your mobile device, such as
but not exclusively, the first time the mobile application is opened, mobile carrier, and
the type of device that is being used, if you have downloaded our applications. In
addition, in the event our mobile applications crash on your mobile device, we will
receive information about your mobile device model and OS version, which allows us
to identify and fix bugs and otherwise improve the performance of our Services. We
send you push notifications from time-to-time such as reminders for coaching
sessions. If you no longer wish to receive these types of communications, you may
turn them off at the device level. To ensure you receive proper notifications, we will
need to collect certain information about your device such as operating system and
user identification information. We use mobile analytics software to allow us to better
understand the functionality of our Mobile Software on your phone. This software
may record information such as how often you use the application, the events that
occur within the application, aggregated usage.
Information collected by Cookies:
Cookies are text files placed on your computer to collect standard Internet log information
and visitor behaviour information. When you visit our websites, we may collect information
from you automatically through cookies or similar technology.
Furthermore, we may allow third-party advertising companies (such as Facebook, Google,
Twitter, Quora and Bing) to place cookies on our website. These cookies enable such
companies to track your activity across various sites where they display Ads and record your
activities, so they can show Ads that they consider relevant to you as you browse the
Internet. These cookies store information about the content you are browsing, together with
an identifier linked to your device or IP address.
when interacting with our website which help us to analyse the use and performance of our
website and services and also to improve the delivery and value of various services and
products offered by us.
What types of cookies do we use?
There are a few different types of cookies, however, our website uses:
● Persistent Cookies. We use persistent Cookies to improve your experience of using
the cookie message which first appears when you use the Sites.
● Session Cookies. Session Cookies are temporary and deleted from your machine
when your web browser closes. We use session Cookies to help us track internet
usage as described above.
● Analytical/Performance Cookies. Analytical cookies allow us to recognise and count
the number of visitors and see how many visitors move around our website while
they are using it. This helps us improve the way our website works, for example, by
ensuring the users find what they are looking for.
● Functionality Cookies. Functionality Cookies recognise when you return to the
website. This enables the company to create greater content for you and remember
your likes and dislikes and other preferences.
● Targeting Cookies. Targeting Cookies records the visit to our website, the pages
navigated to and the links clicked upon. It helps to formulate information relevant to
the user’s area of interests.
How to manage cookies?
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for
doing so vary from browser to browser, and from version to version. Disabling some cookies
form the website, may have a negative impact and may result in some non-availability of
If you want to remove previously stored Cookies, you can manually delete the Cookies at
any time. However, this will not prevent the Sites from placing further Cookies on your device
unless and until you adjust your Internet browser setting as described above.
You can however obtain up-to-date information about blocking and deleting cookies via
● https://support.google.com/chrome/answer/95647 (Chrome)
● https://www.opera.com/help/tutorials/security/cookies/ (Opera)
te-manage-cookies (Internet Explorer)
● https://support.apple.com/kb/PH21411 (Safari)
These opt-out mechanisms rely on cookies to remember your choices. If you delete your
cookies, use another computer or device, or change browsers, you will need to repeat this
process. In addition, opting out of interest-based ads will not opt you out of all ads, but rather
only those ads that are personalized to your interests.
Data protection principles
Where third parties process data on behalf of IDQ, we endeavour to obtain assurances from
such third parties that your Personal Data will be safeguarded consistently. We understand
that it will be accountable for the processing, management and regulation, and storage and
retention of all Personal Data held in the form of manual records and on computers.
All Personal Data obtained and held by the Company will:
● be processed fairly, lawfully and in a transparent manner
● be collected for specific, explicit, and legitimate purposes
● be adequate, relevant and limited to what is necessary for the purposes of
● be kept accurate and up to date. Every reasonable effort will be made to
ensure that inaccurate data is rectified or erased without delay
● not be kept for longer than is necessary for its given purpose
● be processed in a manner that ensures appropriate security of Personal Data
including protection against unauthorised or unlawful processing, accidental
loss, destruction or damage by using appropriate technical or organisation
● comply with the relevant laws and procedures for international transferring of
Personal Data applicable to us.
Legal basis for processing your Personal Data
Certain jurisdictions require that we have a lawful basis to justify our processing of your
Where applicable, the lawful basis that IDQ relies upon to justify a particular processing
activity may differ from the lawful basis used to justify a different processing activity.
IDQ relies on the following lawful basis to process Personal Data, as permitted under
● Processing necessary for the negotiation, execution, or performance of
● Processing to comply with legal and regulatory obligations
● Processing in furtherance of our legitimate interests, including our interests to
conduct legitimate business activities (such as improving our products and
services, to communicate with you, to secure our systems, among other
● Processing necessary to protect vital interest of a user or any other natural
● Processing necessary for public interest
● Processing based on your consent
We may obtain your consent to collect and use certain types of Personal Data when we are
required to do so by law.
Once consent is obtained from the individual to use his or her information for those
purposes, IDQ has the individual’s implied consent to collect or receive any supplementary
information that is necessary to fulfil the same purposes. Express consent will also be
obtained if, or when, a new use is identified.
Consent may also be implied where a user is given notice and a reasonable opportunity to
opt-out of his or her personal information being used for mail-outs, the marketing of new
services or products, and the client, customer, member does not opt-out.
Subject to certain exceptions (e.g., the personal information is necessary to provide the
service or product, or the withdrawal of consent would frustrate the performance of a legal
obligation), individuals can withhold or withdraw their consent for IDQ to use their personal
information in certain ways.
with your Personal Data, you consent to collection, storage, and processing of your Personal
If you refuse or withdraw your consent, or if you choose not to provide us with any required
Personal Data, we may not be able to provide you the services that can be offered on our
Purpose of collecting Personal Data
We collect your Personal Data for the following purposes
● To fulfil or meet the reason you provided the information;
● We use your information for managing and processing purposes, including, but
not limited to, tracking attendance, progress and completion of a Program. As
part of our management and processing of the Program, we will use certain
Personal Data to administer exams, projects, and other assessments for the
Program. For example, as part of an exam, IDQ may use certain information
collected from you in order to verify your identity or to monitor your
performance during the exam to confirm that you are abiding by the applicable
testing rules or requirements;
● To send you updates about the Programs, other IDQevents, platform
maintenance or new services provided , among other things, through itself or
through third parties, via email, SMS, phone call or any other medium;
● Provide Chat Room services;
● To enhance the quality of our content and product offerings;
● Compliance with security and other mandatory policies and building access;
● Providing information to relevant external authorities for tax, social security and
other purposes as legally required;
● Conducting surveys to assess your satisfaction, including but not limited to its
processes or policies;
● Setting up and maintaining accounts and subscriptions with third parties that
provide information and research services or communication services;
● Making decisions about your continued engagement, employment or
● Dealing with legal or regulatory disputes or investigations involving you, our
work, or other partners, employees, workers and contractors, including
accidents at work, potential and actual negligence claims and professional
● To monitor use of our information and communication systems to ensure
compliance with our IT and document management policies;
● To ensure network and information security, including preventing unauthorized
access to our computer and electronic communications systems and
preventing malicious software distribution;
● Business management and planning, including accounting, auditing and
● Planning or reviewing options in relation to the operation or management;
● Keeping registers required by law or regulation;
● Communicating with you, for example to respond to inquiries;
● Enhancing the safety and security of the services and preventing fraud, or
protecting our or our customers’, or your rights or property;
● Enforcing applicable terms and conditions and other applicable policies;
Disclosure of Personal Data
● Examples of third parties with whom IDQ may share Personal Data includes:
With government bodies, including tax and social security authorities, to
comply with applicable laws (including employment and tax laws), to obtain
licenses or approvals, and upon request during an audit or assessment;
● With suppliers, subcontractors and service providers, to maintain an efficient
and commercially viable business, including technology, telecom, internet
● With professional advisers, consultants, and employment and recruitment
agencies, to conduct background verification and reference checks, administer
benefits and payroll, deal with disciplinary and grievance issues and maintain
emergency contact details;
● With our legal advisors and external auditors for legal advice and to conduct
● With service providers for business continuity management and contingency
planning in the event of business disruptions.
● With certain companies in order to establish a membership to participate in
digital wallets, payment services or rewards programme
We require all third parties to respect the security of your Personal Data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your
Personal Data for their own purposes and only permit them to process your Personal Data
for specified purposes and in accordance with our instructions.
Organization and Responsibilities
IDQ will maintain records of data processing as required by the laws.
The ‘Data Protection Officer’ (DPO) has the specific responsibility of overseeing data
protection and ensuring that we comply with the data protection principles and relevant
legislation. The DPO will ensure that the Data Processing Register is kept up to date and
demonstrates how the data protection principles are adhered to by our activities. Individual
members of staff have a duty to contribute to ensure that the measures outlined in the
Register are accurately reflected in our practice.
Our compliance with relevant policies and regulatory requirements in respect of data
protection as part of our Data Management Strategy will be periodically monitored internally
by a designated governance group. All employees, volunteers, consultants, partners, or
other parties who will be handling Personal Data on behalf of Peakperformer will be
appropriately trained and supervised where necessary.
The collection, storage, use and sharing of Personal Data will be regularly reviewed by the
Data Protection Officer, the Governance Group, and any relevant business area. We will
adhere to relevant codes of conduct where they have been identified and discussed as
Where there is likely to be a high risk to individuals rights and freedoms due to a processing
activity, we will first undertake a Data Protection Impact Assessment (DPIA) and consult with
the relevant supervisory authority prior to processing, if necessary.
Conflicts of Law
This Policy is intended to comply with the laws and regulations in the place of establishment
and of the countries in which company operates. In the event of any conflict between this
Policy and applicable laws and regulations, the latter shall prevail.
The Company has taken the following steps to protect the Personal Data of relevant
stakeholders, which it holds or to which it has access:
● it appoints or employs employees with specific responsibilities for: o the
processing and controlling of data
– the comprehensive reviewing and auditing of its data protection systems and procedures
– overviewing the effectiveness and integrity of all the data that must be protected.
– There are clear lines of responsibility and accountability for these different roles.
● it provides its employees with information and training to make them aware of
the importance of protecting Personal Data, to teach them how to do this, and
to understand how to treat information confidentially
● it can account for all Personal Data it holds, where it comes from, who it is
shared with and also who it might be shared with
● it carries out risk assessments as part of its reviewing activities to identify any
vulnerabilities in its Personal Data handling and processing, and to take
measures to reduce the risks of mishandling and potential breaches of data
security. The procedure includes an assessment of the impact of both use and
potential misuse of Personal Data in and by the Company
● it recognises the importance of seeking individuals’ consent for obtaining,
recording, using, sharing, storing and retaining their Personal Data, and
regularly reviews its procedures for doing so, including the audit trails that are
needed and are followed for all consent decisions. The Company understands
that consent must be freely given, specific, informed and unambiguous. The
Company will seek consent on a specific and individual basis where
appropriate. Full information will be given regarding the activities about which
consent is sought. Relevant individuals have the absolute and unimpeded right
to withdraw that consent at any time
● it has the appropriate mechanisms for detecting, reporting and investigating
suspected or actual Personal Data breaches, including security breaches. It is
aware of its duty to report significant breaches that cause significant harm to
the affected individuals to the relevant supervisory authority, and is aware of
the possible consequences
● it is aware of the implications international transfer of Personal Data
Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it
will be reported to the relevant supervisory authority within 72 hours of the Company
becoming aware of it and may be reported in more than one instalment. Individuals will be
informed directly in the event that the breach is likely to result in a high risk to the rights and
freedoms of that individual. If the breach is sufficient to warrant notification to the public, the
Company will do so without undue delay.
External Links on our website
For your convenience we may provide links to sites operated by organizations other than
IDQ (Peakperformer)(“Third Party Sites”) that we believe may be of interest to you. We do
not disclose your Personal Data to these Third-Party Sites unless we have a lawful basis on
which to do so. We do not endorse and are not responsible for the privacy practices of these
Third-Party Sites. If you choose to click on a link to one of these Third-Party Sites, you
Third-Party website collects and uses your Personal Data