Privacy Policy

1.1 Becoming Quotient (BQ) is the brand of Longitudinal Human Private Limited, a company incorporated in India with its registered office at Office 9C, Parvati Industrial Estate, Sun Mill Compound, Lower Parel, Mumbai 400013, Maharashtra (we, us, our). References to BQ include its successors and permitted assigns under the applicable service agreement. Any transfer remains subject to the corporate-event safeguards below and does not itself authorise new data purposes.

1.2 Our role depends on who determines the purpose and means of the particular processing. Where we determine those matters, including for our direct relationship with individuals, their continuing development records and separately authorised research and BQ model improvement, we act as Data Fiduciary. Where an Enterprise provides programme set-up data or instructs us to process administration or commissioned operational analytics solely on its behalf, it is the Data Fiduciary and we act as its Data Processor under our contract. Independent cross-customer research and commercial analytics are not deemed necessary programme administration. The enterprise data processing agreement records the allocation by activity. Contract labels do not override the roles required by Applicable Data Protection Law.

1.3 Psychometric assessments may be administered on the platform of our assessment partner under written instructions and safeguards. The assessment notice identifies the provider, processing locations and information shared with BQ. We use the results to deliver the requested assessment and development service within its licence. Applying existing licensed statistical norms and any necessary, disclosed calibration to score your requested assessment are service activities. Using your submitted data to create or update cross-customer norms or for optional assessment-provider research is a distinct purpose requiring a clear provider-specific notice, separate affirmative permission and the necessary rights and lawful basis. BQ’s Research Switch does not by itself permit independent provider reuse, and anonymising new source data does not bypass these requirements. This does not permit an AI provider to train or develop its own models from platform data. If you or your organisation give us an existing report from another provider, we use it to inform development questions and pathways; we do not represent that we independently validated or re-scored it. Further predictive, research or training use requires the relevant licence and permissions. The supplier must have the rights to provide it. Enterprise disclosure requires the applicable notice and lawful authorisation.

1.4 This policy covers everyone whose personal data we handle: visitors to becomingquotient.com, people who contact us, join a waitlist or take part in a survey, individual users of the BQ platform, whether they join through an organisation or on their own, coaches on our bench, and the representatives of organisations we work with.

1.5 It does not cover websites or services operated by others that we may link to. Their privacy practices are their own.

2.1 Personal data means information about an individual who is identifiable by or in relation to it, including through combinations with other reasonably available information. Removing a name or replacing it with a code does not by itself make the information anonymous.

2.2 Processing means anything we do with personal data, including collecting, storing, using, sharing and deleting it.

2.3 Data Principal is the person the personal data is about. Data Fiduciary is the person that, alone or together with others, determines the purpose and means of processing personal data. Data Processor is a person that processes personal data on behalf of a Data Fiduciary. These expressions are used in this policy consistently with Applicable Data Protection Law.

2.4 Enterprise means an organisation that commissions a BQ programme for its people. Individual means a person who uses the BQ platform, whether through an organisation that has commissioned a programme or by signing up with us directly. Coach means a person who applies to join, or is on, the BQ coaching bench.

2.5 kairo is BQ’s AI companion, which supports practice and reflection between coaching sessions. BQ Proprietary Development Framework means BQ’s proprietary development framework, including its competency and development models, constructs, dimensions, methods, scoring and interpretation approaches, taxonomies, mappings and related materials, as developed or updated by BQ from time to time subject to the applicable agreement, excluding materials owned by the Enterprise or third parties.

2.6 Anonymous Insights means lawfully created anonymous datasets, aggregated statistics, benchmarks, generalised behavioural patterns, reports, studies and model improvements from which no individual is identifiable, having regard to means reasonably available, and which do not disclose or enable reconstruction of an Enterprise’s confidential information or restricted third-party material. Creating them must comply with the original data permissions, including the Research Switch where applicable.

3.1 We use access controls and appropriate logical segregation to separate private individual development information from the Enterprise-facing service. We disclose identifiable information to an Enterprise only within the categories described below, as explained in the applicable programme notice, and on the required consent or other lawful basis.

3.2 Where a person signs up with us directly rather than through an employer, no Enterprise is involved in that relationship and no organisation receives anything about them, unless they have specifically agreed to a particular sharing.

3.3 An Enterprise receives aggregated cohort reporting designed so that individuals cannot reasonably be identified, including agreed analyses of behavioural patterns and organisational micro-cultures. We assess small-group, linkage and inference risks and suppress or generalise outputs where needed. The Enterprise may also receive the limited individual-level information identified in the programme notice: programme context and development purpose, authorised end-of-programme observations, manager-provided ratings, an approved coaching progress report excluding private session content, and account, participation, attendance and utilisation information needed to administer the programme. The BQ Capability Profile requires the separate standing sharing approval described below. Sharing additional Growth Passport information or using data for a purpose or recipient outside that approval requires fresh specific permission. These categories do not give the Enterprise access to raw psychometric data, private coaching notes or recordings, kairo conversations or private reflections, directly or through inferences that reveal that content. Enterprises must not try to identify people from aggregated reports.

3.4 We protect an Enterprise’s confidential information, including its competency framework, strategy and commercial information, under our enterprise agreement. We use it to deliver, administer and protect the service and for other expressly permitted lawful purposes, including authorised mapping of personal development results into the BQ Proprietary Development Framework for portability. An individual’s research consent does not permit us to disclose Enterprise confidential information or override Enterprise or third-party rights. Naming an Enterprise or publishing its confidential content requires that Enterprise’s specific prior written approval; permission required for any identifiable person must be obtained separately.

3.5 Some programmes include a BQ Capability Profile: selected capability indicators, working preferences, development progress and supported predictive insights into current or future internal role, project or team suitability. Before sharing, we show the categories to be shared, the Enterprise recipients and the purposes. At onboarding, the sharing switch may be presented as the proposed on setting, but no sharing is activated until you separately select Confirm profile sharing. You can instead select Keep private through an equally accessible choice; silence or general acceptance of the terms is not confirmation. Once confirmed, the standing permission stays on within that scope until you switch it off or the relevant Enterprise relationship ends. It is optional and declining does not prevent core coaching or development services. The Enterprise must use these insights for meaningful human assessment of suitability, not promotion, demotion, appraisal, pay, discipline, exit or solely automated employment decisions. Predictions are estimates, not guarantees. The profile excludes raw psychometric data, private coaching and kairo content, recordings and private reflections, including inferences that reveal that content. Additional Growth Passport information, a materially different purpose or recipients outside the authorised scope require fresh specific permission. Withdrawal stops future sharing and use dependent on it; we notify the Enterprise to cease that use and erase its copy unless it has a separate lawful ground for limited retention or use, which it must explain. Withdrawal does not reverse a decision lawfully completed beforehand.

4.1 We do not sell personal data. BQ supports development and provides the agreed behavioural and predictive analytics; it does not make employment decisions on an Enterprise’s behalf. BQ Capability Profile predictions support meaningful human assessment of current or future internal role, project or team suitability and must not be used for promotion, demotion, appraisal, pay, discipline or exit. They are estimates based on available information, not promises of happiness, suitability or performance, and are not a basis for solely automated employment decisions. Enterprise disclosures remain limited to the categories, permissions and safeguards in this policy and the programme notice. BQ may commercially offer Anonymous Insights under the conditions below.

4.2 When we run a survey, whether to understand what professionals and organisations need or to promote our work, the survey page links to this policy and taking part is voluntary. Some surveys are anonymous. Where a survey asks for your name, email address or other identifying details, it says so before you begin. We use responses for the purposes described in that survey notice, including permitted aggregated findings. Publishing identifiable information about you requires your specific permission, and naming an organisation or publishing its confidential content requires that organisation’s authorised written approval; your response alone does not provide that authority. We do not add survey responses to a development record unless you ask us to.

4.3 Research and BQ model improvement is optional, off and unchecked at onboarding. If you affirmatively switch it on, we may use the data categories identified in the notice for the specified behavioural research, predictive analytics, studies, reports, benchmarks and BQ model training and validation purposes described above. These include understanding which roles or working environments may suit people, patterns linked to fulfilment at work, relationships between profiles and outcomes, and aggregated organisational micro-cultures. BQ may develop commercial products from that work. We minimise identifying details, including in free text, before research use; linkable information remains personal data. Your permission does not supply consent for a manager, peer, coach or other person, or override Enterprise confidentiality or third-party licences. We obtain the additional rights and lawful permissions needed. Recording or quality-review permission is not research consent. We do not train general-purpose AI models on session recordings themselves. Sanitised session text may be used for the expressly notified BQ research or model-improvement purpose only with both participant and coach’s affirmative Research Switch permissions, required permissions for any other people whose data is used, and the necessary confidentiality and third-party rights. Research consent does not authorise individual-level disclosure to an Enterprise. You can keep research off and continue using core coaching and development services.

4.4 BQ may retain, combine, publish and commercially license lawfully created Anonymous Insights, including after withdrawal or the end of a service, subject to the source permissions and confidentiality and IP safeguards described above. This right does not permit identifiable-data sales, reconstruction of protected Enterprise material or identifiable private-content disclosure. We assess model and output risks and treat recoverable personal data as protected. You may switch research off at any time: we stop new consent-dependent research use and address identifiable research data and processors as the law requires, subject to limited lawful retention. We do not bypass that choice by first anonymising new data for optional research. Withdrawal does not undo lawful past processing or enable us to retrieve already anonymous information by your identity. Necessary service delivery, security and operational analytics continue only within their separately notified lawful purposes; optional cross-customer research and training are not reclassified as necessary service administration. Materially new research purposes or data categories require a fresh notice and consent where required.

4.5 kairo is BQ’s AI companion, including renamed, successor, upgraded or replacement systems providing substantially the same function. Relevant conversation content is processed to generate responses, maintain context, update your development record and run safety checks. Third-party AI providers process that content under written safeguards restricting use to supplying and securing the authorised service, and may perform specifically authorised processing for BQ under BQ’s instructions. They are not permitted to use platform data for their own model training or development or unrelated purposes. Provider retention is limited to the lawful instructed purpose and necessary security safeguards. BQ’s own optional training on kairo information requires the Research Switch and the safeguards above. The applicable AI notice identifies provider categories, locations and relevant retention. Your private kairo conversations, and inferences that reveal them, are excluded from Enterprise reports and the BQ Capability Profile. kairo does not make employment decisions or other decisions producing legal or similarly significant effects on you. It is not an emergency or medical service, may not detect a risk, and should not be relied on to contact emergency services. Safety information and referral prompts may be provided. Limited lawful disclosures remain possible as described below.

4.6 Where you have agreed to receive updates from BQ, we may note whether a message was opened or a link clicked, so that we send you only what is useful. You can opt out at any time using the link in any message or by writing to us, and we will still send you the messages needed to run your account.

5.1 You can see your own record.

5.2 Your coach sees what is needed to coach you well, within the programme.

5.3 Your Enterprise receives only the aggregated and limited identified programme information described above and in your programme notice. Optional BQ Capability Profile sharing requires separate affirmative confirmation and stays within its disclosed scope; additional sharing requires the further approval described above. Enterprise reporting does not disclose raw psychometric data, private coaching notes or recordings, kairo conversations or private reflections, directly or through inferences that reveal that content. A change to individual account status does not give the former Enterprise access to your individual account or its later development record.

5.4 Our personnel access personal data on a need-to-know basis under confidentiality duties, access controls and appropriate logging. We maintain reasonable technical and organisational safeguards appropriate to the information and risks, including access management, encryption where appropriate, incident handling and security review. No method of transmission or storage can be guaranteed completely secure; this does not reduce our duties under Applicable Data Protection Law.

6.1 If you apply to the BQ coaching bench, we collect your professional details and application responses and create evaluation records, including any assessment results used in the selection process. Assessment providers process data under the arrangements explained in the assessment notice. Where we decide how coach application and engagement data is used, we act as Data Fiduciary. Evaluation may use the BQ Proprietary Development Framework; this does not transfer any ownership of your personal data or BQ’s framework.

6.2 We use this to assess your application and, if you are recommended to the bench, to build your coach record and match you to coaching engagements.

6.3 Your application responses and evaluation records are held securely in our internal systems. They are not provided to any Enterprise unless you have specifically agreed to that, and they do not form part of any individual participant record.

6.4 You may withdraw consent and request access, correction or erasure using the contact details below, subject to Applicable Data Protection Law. If the information concerned is necessary to assess, engage or match you, withdrawal may prevent us from continuing the affected application or engagement; we will explain that consequence. Withdrawal does not affect lawful prior processing or retention on another applicable legal ground.

7.1 Our website may use cookies and similar technologies that are necessary to operate, secure and maintain the website and remember essential preferences.

7.2 If we introduce analytics, advertising or other non-essential cookies or similar technologies, we will provide appropriate information and choices before using them where required.

8.1 We share personal data only as set out here, and never sell it.

(a) Service providers acting for BQ. We use providers for hosting, assessments, AI response generation, video sessions, communications, payments, support and analytics. Where they process personal data on our behalf, they are bound by written instructions and safeguards appropriate to that processing. The applicable service notice and, for enterprise processing, the data processing agreement identify relevant providers or categories and locations. If a provider instead determines an independent purpose, we explain the relevant disclosure and lawful basis rather than describe it as BQ’s processor.

(b) Legal, safety and regulatory purposes. We may disclose the minimum necessary information to comply with law, a court order or an authorised regulator’s lawful request, to establish, exercise or defend legal claims, or to protect life or physical safety where Applicable Data Protection Law permits. We assess the legal basis and necessity of the disclosure; this is not routine reporting of private development content to an Enterprise.

(c) Corporate events. If BQ is involved in a merger, acquisition, reorganisation, business transfer or permitted assignment, personal data may transfer to its successor or permitted assignee to continue the relevant service and obligations. We provide applicable notice, require the recipient to assume the relevant protections and obtain any consent or other authorisation required by law. A corporate transfer does not itself authorise a new processing purpose or override your consent choices.

(d) Your Enterprise. Only the limited programme reporting and separately authorised sharing described in this policy and the applicable programme notice, subject to the stated use and confidentiality restrictions.

(e) Integrations you choose. If you connect your calendar or a workplace tool to the platform, for example to schedule coaching sessions, the information needed for that integration passes to that provider under its own terms. You can disconnect an integration at any time, although that does not remove information the provider already holds.

8.2 We remain responsible for personal data handled by our Data Processors on our behalf.

9.1 Personal data may be processed in India and other locations disclosed in the applicable service or assessment notice. We comply with applicable transfer restrictions and use contractual safeguards with recipients. Where the SPDI Rules apply, a recipient must provide the same level of protection required by those Rules and the transfer must be necessary for a lawful contract with you or made with your consent. Any additional country, sector or Significant Data Fiduciary restrictions that become applicable also apply.

9.2 Any particular India-only hosting commitment applies to the data and service for which it is expressly made in the applicable notice or enterprise agreement. Other processing, including provider support and AI inference, is covered by the relevant location disclosures and lawful safeguards.

10.1 We retain personal data only for as long as necessary for the notified lawful purposes, including a continuing individual service you have chosen, or as law requires. The relevant service notice describes applicable retention arrangements and consequences of closure or withdrawal.

10.2 When Enterprise sponsorship ends, including through employment termination or the end of the Enterprise’s service, your account transitions to individual status under the arrangement you accepted at onboarding, unless you close it or exercise applicable withdrawal or erasure rights. We enable verified personal access and preserve your permitted personal development history and Growth Passport. Relevant Enterprise competency results are mapped into the BQ Proprietary Development Framework under the agreed rights, with Enterprise-confidential and restricted third-party material removed. Mapping is a developmental interpretation, not a claim that different scales are equivalent. Employer and sponsored coach access ends unless separately authorised for a continuing service. Conversion alone does not create a charge; paid individual services require your acceptance of the applicable price and terms. The individual service terms govern available features, access, retention and export and do not promise perpetual hosting or free service. Before a planned closure or service discontinuation we give the export opportunity provided by those terms. On withdrawal or closure we stop the affected consent-based processing and erase personal data as the law requires, subject to limited retention on another applicable legal ground. Protected backup copies expire under the applicable cycle unless law requires earlier deletion. Existing Anonymous Insights are governed by the conditions above.

10.3 Where we act as an Enterprise’s Data Processor, our retention, export and deletion arrangements are set out in the data processing agreement and its retention schedule, subject to Applicable Data Protection Law. The Enterprise cannot use those instructions to control information for which BQ independently acts as Data Fiduciary.

10.4 Security and processing logs and any other information subject to mandatory retention are retained for the periods and in the locations required by Applicable Data Protection Law, with access limited to the permitted purpose.

11.1 You may exercise the rights available under Applicable Data Protection Law. The following describes the rights provided by the DPDP framework as the relevant provisions commence; existing rights under other applicable law are unaffected. We also honour the express consent choices in this policy.

(a) Access. To a summary of the personal data we process about you as well as the processing activities undertaken in relation to such data, as well as information pertaining to the identities of all other entities with whom personal data has been shared by us, along with a description of the personal data so shared.

(b) Correction and completion. To have inaccurate or misleading data corrected or incomplete data completed.

(c) Erasure. To have your personal data erased where it is no longer needed for the specified purpose for which it was collected for, subject to any requirement to retain such data for a longer period under applicable laws.

(d) Withdraw consent. You may withdraw as easily as you gave it, through the relevant account or session control or by contacting us below. Research and BQ Capability Profile sharing are separate onboarding choices; recording/transcription and quality review are separate session choices. Turning off one optional choice does not turn on another or prevent unrelated core services. Withdrawal stops the future processing dependent on that permission and does not invalidate lawful earlier processing; the retention and Anonymous Insights conditions above apply.

(e) Grievance redressal. To raise a grievance with us and have it addressed (see Clause 13).

(f) Nomination. To nominate another person to exercise your rights in the event of your death or incapacity.

11.2 To make a request, use the privacy settings where available or contact us below. We may request proportionate information to verify your identity and the scope of your request. We respond within the applicable legal period and explain any lawful refusal or retention exception. Where we act only as an Enterprise’s processor, we may refer your request to that Enterprise and assist it.

12.1 BQ is intended only for people aged 18 or over. We do not offer the service to children and do not knowingly allow a person under 18 to create an account, take an assessment or participate in a programme. Individuals and Enterprises must not enrol a child. We may take proportionate steps to verify age where appropriate.

12.2 If you believe a child’s personal data has been submitted, contact us. We will investigate, restrict the affected processing and delete the information unless limited retention is required by law.

13.1 If you have any question or concern about your personal data, or wish to exercise a right under this policy, contact our privacy contact:

Privacy contact and Grievance contact, Longitudinal Human Private Limited:

Email: privacy@becomingquotient.com

Website: becomingquotient.com

Post: Office 9C, Parvati Industrial Estate, Sun Mill Compound, Lower Parel, Mumbai 400013, Maharashtra, India

13.2 We acknowledge privacy complaints and seek to resolve them promptly. Where the SPDI Rules apply, we address the grievance within one month of receipt. Other requests and grievances are handled within the applicable statutory period; once the relevant DPDP grievance provisions apply, the published response period will not exceed ninety days.

13.3 You may use the complaint or appeal routes available under Applicable Data Protection Law, including the Data Protection Board of India when the relevant jurisdiction and procedure apply and after completing any legally required prior grievance process. This policy does not restrict access to any competent authority or court where the law permits it.

14.1 We may update this policy to reflect changes to the service, processing or law. We publish the current version with its effective date and give notice of material changes through an appropriate channel. If a new purpose or change requires consent, we obtain it before the relevant processing; merely updating this policy does not supply that consent or authorise retroactive use inconsistent with an existing consent.

15.1 This policy is published in English. Where the DPDP law requires, we will make it available in other languages listed in the Eighth Schedule to the Constitution of India on request.