Section 1: YOUR PRIVACY MATTERS
Mind Purpose Leadership Privacy Policy
At Mind Purpose Leadership Pvt. Ltd., trust is central to every relationship we build. This includes being clear about the personal information we collect, why we use it and how we protect it.
This Privacy Policy explains how we handle personal information when you visit our website, contact us, book a conversation, enrol in a program, use our digital services or engage with us individually or through an organisation.
Privacy at a Glance
Four Data Governance Principles
October 24, 2021
1. Identity
2. Policy Scope
Version 2.4 — Comprehensive data governance standard applicable to all enterprise leadership programs, executive coaching engagements, and the Spark app platform.
Mindpurpose Leadership acts as the primary data controller for all corporate coaching, team alignment workshops, and digital application operations.
Applies universally across executive coaching relationships, leadership assessments, enterprise development programs, and the Spark digital app.
3. Policy Purpose
4. Confidentiality
Purpose Limitation
Provides full clarity on personal data collection, legal processing bases, corporate compliance, and participant privacy protections.
Strict adherence to executive coaching panel standards ensures total individual session confidentiality and secure reflective records.
Data collected is used exclusively to deliver tailored executive coaching solutions, enhance team alignment, and measure workplace development impact.
Data Minimization
Enterprise Security
Participant Rights
We gather only the essential professional context required to facilitate impactful coaching dialogues, leadership assessments, and digital features.
Rigorous enterprise encryption and strict access protocols safeguard all participant assessment records, coaching notes, and personal data.
Leaders maintain clear rights to access, inspect, export, update, or request the deletion of their personal platform data.
SECTION 2: TRANSPARENT BY DESIGN
The Information Involved in Your Relationship with Us
We collect and handle personal data to deliver tailored executive coaching, platform access, and organizational leadership development programs. Here is how information is gathered, categorized, and managed across our interactions.
Direct Information
Booking & Payment
Coaching Data
Includes contact details, job title, organizational affiliation, and communication preferences provided when requesting information, enrolling in programs, or registering for Spark digital access.
Covers invoicing details, corporate sponsor billing metadata, payment confirmations, and transaction histories required to process coaching engagements and program enrollments securely.
Includes assessment responses, reflection logs, action plans, and goal metrics shared during executive coaching sessions or platform-guided leadership development workflows.
Sponsored Engagements
Website & App Usage
Covers corporate sponsor alignment objectives, organizational sponsor feedback, aggregated progress benchmarks, and cohort milestone metrics managed under enterprise agreements.
Includes IP address, device identifiers, session logs, browser types, and navigation activity captured while accessing our website or Spark platform features.
Purposes for Processing Your Data
Every data point processed within Mind Purpose Leadership serves a defined operational, analytical, or regulatory purpose across seven core areas.
1. Program Execution
2. Spark Personalization
3. Progress Analytics
4. Billing Compliance
To deliver tailored executive coaching, conduct team workshops, and administer leadership assessment tools efficiently across your organization.
To customize individual learning paths and track participant growth milestones on our Spark digital leadership development platform.
To compile aggregated performance insights, measure organizational capability benchmarks, and evaluate overall executive coaching efficacy.
To manage enterprise contract billing, issue accurate program invoices, verify payment processing, and fulfill corporate statutory accounting.
5. Program Communication
6. Enterprise Reporting
7. Governance & Security
To deliver essential schedule updates, coaching session reminders, digital platform access notices, and crucial administrative announcements.
To provide corporate executive sponsors with anonymized leadership engagement trends, program attendance, and cohort progress completion rates.
To enforce system security protocols, protect against unauthorized access, and fulfill all applicable data protection legal mandates.
Consent & Voluntary Disclosure
By participating in our coaching programs or accessing the Spark platform, you consent to personal data collection and processing as described. You retain the right to withdraw voluntary consent at any time, subject to statutory obligations or active enterprise agreements.
Cookie & Web Analytics Panel
Children’s Data Notice
We utilize essential and performance cookies to maintain secure platform sessions, remember login preferences, and evaluate site navigation. You can manage or disable cookie preferences anytime through your web browser parameters.
Our executive coaching services, corporate programs, and Spark mobile application are strictly intended for professional adults aged 18 and older. We do not knowingly collect, retain, or solicit personal information from individuals under 16.
SECTION 3: HANDLED WITH RESPONSIBILITY
How We Protect and Manage Your Information
We handle personal data strictly to deliver executive coaching, digital platform services, and organizational development with uncompromising technical security, rigorous governance, and complete operational transparency.
CORE PRIVACY GUARANTEE
We Do Not Sell Personal Information
Mind Purpose Leadership never sells, rents, leases, or trades personal data, assessment findings, or coaching records to third parties for marketing, advertising, or commercial monetization under any circumstances.
Five Information Sharing Categories
Assigned Executive Coaches
Spark App Platform Partners
Enterprise Program Sponsors
Shared exclusively with certified executive coaches and program facilitators bound by strict confidentiality and non-disclosure obligations.
Processed via encrypted cloud hosting, database management, and authentication services operating under enterprise SOC 2 security standards.
Corporate sponsors receive high-level aggregate cohort analytics. Individual session notes, reflections, and personal entries are never disclosed.
Regulatory & Legal Compliance
Corporate Restructuring
Disclosed only when mandated by applicable law, court order, subpoena, or binding statutory duty to protect legal rights or physical safety.
In the event of a merger, acquisition, or asset reorganization, data handling commitments remain strictly preserved under this policy.
Eight Essential Security Measures
1. AES-256 Encryption
2. Role-Based Access
3. SOC 2 Type II
4. Multi-Factor Auth
Full encryption for stored databases and active TLS 1.3 transit tunnels.
Strict least-privilege permissioning for essential delivery teams.
Independent annual compliance audits of cloud architecture.
Enforced MFA across all administrative and staff access points.
5. Vulnerability Scans
6. Anonymization
7. 24/7 Telemetry
8. Breach Protocols
Continuous automated code scans and quarterly penetration tests.
Psychometric metrics stored decoupled from direct identifiers.
Real-time infrastructure threat detection and intrusion prevention.
Documented incident response SLA ensuring 72-hour notice.
CROSS-BORDER GOVERNANCE
International Data Processing Panel
Personal data collected during global leadership development programs may be stored and processed in ISO-certified data facilities located across North America, Europe, and Asia-Pacific. All international transfers strictly rely on EU Standard Contractual Clauses (SCCs), UK Data Transfer Addendums, and compliance with applicable data residency frameworks.
LIFECYCLE TIMELINES
Seven-Row Data Retention Schedule
Row 1: Executive Coaching Notes
Row 2: Spark Platform Credentials
Retained for 3 years post-program completion, then permanently and securely deleted.
Maintained throughout active subscription plus 90 calendar days prior to purging.
Row 3: Psychometric Assessments
Row 4: Financial & Billing Records
Stored for 5 years to enable longitudinal growth tracking for organizational leaders.
Retained for 7 years in compliance with statutory financial and audit mandates.
Row 5: Support Correspondence
Row 6: System Audit Logs
Retained for 24 months following the date of final communication resolution.
Maintained on a rolling 12-month window for security verification.
Row 7: De-Identified Aggregate Metrics
Retained indefinitely in fully anonymized research databases for industry benchmark reporting.
SUBPROCESSOR NOTICE
Third-Party Services Governance
Our platforms utilize evaluated third-party subprocessors for essential cloud hosting, video conferencing, and system diagnostic logging. Each vendor undergoes strict security diligence and remains contractually restricted from using data for any secondary purpose.
YOUR INFORMATION, YOUR CHOICES
How to Exercise Your Privacy Rights
At Mind Purpose Leadership, you maintain full authority over your personal information. Review your statutory entitlements, request procedures, and direct contact channels below.
Right to Access
Right to Rectification
Right to Erasure
Request a complete copy of the personal data, coaching records, assessment logs, and digital platform metrics we maintain about your executive profile.
Correct inaccurate, out-of-date, or incomplete profile details, professional organizational context, or email notification preferences at any time.
Ask us to delete your personal information and coaching activity records when ongoing data retention is no longer necessary or legally required.
Right to Data Portability
Right to Object
Right to Restrict
Receive your personal data in a structured, standard, machine-readable format to seamlessly transfer to another designated organization or service provider.
Opt out of direct promotional updates, analytical telemetry, or automated leadership assessment profiling at any point through your preference settings.
Limit how we process your information while data accuracy disputes, identity verification requests, or legal claims are actively being reviewed.
Communication Choices
Policy Updates & Notice
Manage how Mind Purpose Leadership communicates with you. Unsubscribe from marketing updates or coaching insights via the link in any email, or adjust notification settings inside the Spark App.
We periodically review this policy to reflect platform enhancements and legal requirements. Material revisions will be posted here with an updated date stamp and notified via email prior to implementation.
SUBMISSION WORKFLOW
Five Steps to Submit a Privacy Request
01
STEP ONE
02
STEP TWO
03
STEP THREE
Identify Request
Verify Identity
Send Credentials
State clearly which specific data right you wish to exercise regarding your coaching records, Spark App activity, or executive development profile.
Provide valid account credentials or organizational identity details to ensure secure and authorized access to sensitive leadership records.
Transmit your written request directly to our privacy office at privacy@mindpurpose.com or submit through our secure client communication portal.
04
STEP FOUR
05
STEP FIVE
Formal Assessment
Final Fulfillment
Our Grievance Officer reviews your submission within five business days, confirms request validity, and formally acknowledges receipt.
Receive complete fulfillment, comprehensive data delivery, or confirmed administrative resolution within our statutory thirty-day response period.
DIRECT CONTACT & GOVERNANCE
Privacy Contact & Grievance Panel
If you have questions, concerns, or wish to escalate a formal privacy request, our designated Data Protection and Grievance Officer is available for direct consultation.
support@mindpurpose.in
PRIVACY DESK EMAIL
30 Days
MAXIMUM RESPONSE PERIOD
Grievance Officer
DESIGNATED COMPLIANCE AUTHORITY