Privacy Policy


Please read the Privacy Policy, this is the legal agreement that you as a Registered User/Visitor make with 360-Transformations (Leading With Pride) when you share your Personal Information (defined below) in order to use this Platform and the Services (defined below)offered therein. This Platform is owned and operated by 360-Transformations which is the owner of the Leading With Pride Program and operates in India in collaboration with Working With Pride and Queertainment Inc. We appreciate the trust and seek to protect the Personal Information that you share to help us provide various Services to the best extent possible, and only use the information in a manner provided in this Privacy Policy.

This Privacy Policy has been drafted in accordance and compliance with (i) the Indian Contract Act, 1872, (ii) the (Indian) Information Technology Act, 2000, and the rules, regulations, guidelines and clarifications framed there under, including  (iii) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”), and (iv) Information Technology (Guidelines for Intermediaries and Digital Media Ethics Code) Rules, 2021.

The Privacy Policy read along with the Terms and Conditions comes into effect from the date and time a Visitor (defined below) registers on the Company’s Website and/or Application and becomes a Registered User (defined below. In this Privacy Policy, we describe the kind of information that we collect about you when you use and access    (the “Website”) and the Application through desktops, mobile phones, smart phones, tablets, plugins and API (collectively the “Platform”) and how we use and disclose that information in relation to the Services provided through the Platform. If you have any questions or comments about the Privacy Policy, please contact us at



We recognize the importance of your personal privacy. Please read the following Privacy Policy to understand how your Personal Information will be treated as you make full use of the Services offered through the Platform. Except as disclosed in this Privacy Policy or as otherwise authorized by you, we will not share your Personal Information with third parties for their marketing purposes. Your trust and confidence is our highest priority.


By using our Services you understand and accept this Privacy Policy along with any changes as may be made from time to time and thereby expressly consent to our collection, storage, processing, usage, disclosure and transfer of Your Information (as defined below) in accordance with this Privacy Policy. If you are not agreeable to this, please do not use the Platform or the Services. You acknowledge that You are providing Your Information out of Your free will. You have the option not to provide us the Information sought to be collected. If You do not provide us Your Information or if You withdraw the consent at any point in time, we will not be able to offer the Services available on the Platform.


As used in these Terms, the following terms shall have the meaning set forth below:

(i)  Confidential Information shall mean all information and materials furnished by a party which: (a) if in written format is marked as confidential, or (b) if disclosed verbally is noted as confidential at time of disclosure, or (c) in the absence of either (a) or (b) is information which a reasonable party would deem to be non-public information and confidential.  Confidential Information shall include, but not be limited to Registered User Information, all types of data, information, ideas, literary/artistic content in the Program, specifications, procedures, source code, software architecture, software design, product designs, personal information, business plans,  projections, marketing data and other similar information of the Company, documentation, the existence and contents of this Agreement, whether such is transmitted in writing, orally, visually, (e.g. video terminal display) or on magnetic media, and shall include all proprietary information, customer and prospect lists, trade secrets, or intellectual property rights such as trade names, trademarks, copyright, patents, designs, know-how, concepts, drawings, flow charts, diagrams and other intellectual property relating to the subject matter of this Agreement owned by the Company.

(ii)  Program shall mean the transformational leadership development training program offered through the Platform.

(iii)  Services means the services being offered to Registered Users by the Platform by providing a transformational leadership development program with various features delivered virtually and also in person.

(iv)  Registered User shall mean any person who is competent to contract under applicable laws and who signs up and registers as a user on the Platform for using the Services.

(v)  Registered User Information means information regarding Registered Users which includes personal information such as name, age, gender, address, date of birth, email address, mobile number, occupation, level of education (Personal Information) and information pertaining to your finances such as Bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation (Sensitive Personal Information), name, email addresses and phone number of the assessor nominated by the Registered User, User Entries, and any other information which may be provided by a Registered User through using or which may be collected by the Platform when the Registered User uses the Services.

(vi)  Visitor refers to any individual/entity who browses the Platform, but has not yet registered. 

(vii)  All other capitalized terms shall have the meaning ascribed to them in the Other Terms.


4.1  Information Provided to Us:

We receive and store Personal Information (i.e. includes information that whether on its own or in combination with other information may be used to readily identify or contact the Registered User) and Non-Personal Information.

Personal Information: Registered Users

You as a Registered User will be required to provide certain Personal/Sensitive Personal Information to use the Platform and Services offered therein when creating an account on the Platform. We may also collect information which would help determine your eligibility to avail the Services offered by the Platform, information which would help us process requests made by you for the use of Services offered by the Company such as age or documents for proof of age, etc. We shall also collect any other information that is required in order to provide smooth mobile experience, including but not limited to SMS access for auto- OTP verification, camera/gallery/contacts access, and other features on the phone or electronic device for offering various functionalities within the Platform. You always have the option to not provide information by choosing not to use a particular Service or feature. Importantly, we only collect Personal Information about you that we consider necessary for achieving the purpose of communicating with you and offering the Services available on this Platform.

Non-Personal Information: Registered Users/Visitors

Information Collected Automatically: When you use the Platform as a Registered User or Visitor, we automatically receive and record information on our server logs from your browser or mobile, including but not limited to your device hardware model, browser type, IP address, operating system version, unique device identifiers, type of device you use, the mobile network information, geographic location, the URL that you just came from, your computer browser information, your ISP, and other technical information. We may also collect information about how your device has interacted with the Platform, including the pages accessed and links clicked. We treat this data as Non-Personal Information, except where we are required to do otherwise under applicable law.

Cookies: We use data collection devices such as “cookies” on certain pages of the Platform to help analyze our web page flow, measure promotional effectiveness, and promote trust and safety. “Cookies” are small files placed on the hard drive of your computer that assist us in providing the Services. We offer certain features that are only available through the use of a “cookie”. We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies”, meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Platform.

By continuing to use the Platform and/or Services you are deemed to have read the Privacy Policy and understood the purpose for which your Personal or Non-Personal Information is being collected and how the same shall be used and granting your express consent to such purpose and use. If, at a later date, you wish to withdraw this consent or have any queries please send us an email at [insert email address   


Use of Personal and Non-Personal Information is an integral part of the Platform, its purpose and our business. We neither rent nor sell your Personal Information to anyone. We may share your Personal Information only as described in this Privacy Policy and related documents.

  • 1 Use of Personal Information:

We will use and store Personal Information of Registered Users to:

(i) deliver Services to you, including registering you for our Services, verifying your identity and authority to use our Services, and to otherwise enable you to use the Platform and our Services;

(ii) to maintain, and improve our Services, including, for example, to provide Services you request (and send related information), develop new features, provide customer support to You;

(iii) develop safety features, authenticate users;

(iv) send updates and administrative messages;

(v) market and promote the Service and for the internal operational and administrative purposes of the Service,

(vi) If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on Platform or Software we may collect such information into a file specific to you;

(vii) to improve our marketing and promotional efforts;

(viii) to analyze Platform usage;

(ix) improve the Platform content and Service offerings;

(x) customize the Platform content, layout, and Services;

(xi) to provide you with a smooth, efficient, safe and customized experience while using the Platform and

(xii) use the information in order to comply with country laws and regulations;

(xiii) You agree that any Personal Information/Sensitive Personal Information provided by you or any other highly sensitive information shared by you through texts, images, videos on the Platform and/or communicated through other means provided by the Company may be collected by the Company to maintain records into a file specific to you.

(xiv) You agree that we may use your Personal Information in the file we maintain about you, and other information we obtain from your current and past activities to: resolve disputes; troubleshoot problems; help promote safe interactions and correspondence; measure consumer interest in the Services provided by us; inform you about online and offline offers, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our Terms; and as otherwise described to you at the time of collection.

5.2 Use of Non-Personal Information:

We will also use Non-Personal Information (including information from online and offline third party sources) to create aggregated data for analytical and other purposes. We use this information to do internal research on your demographics, interests, and behavior to better understand, protect and serve You. This information is compiled and analyzed on an aggregated basis. Unless otherwise stated in this Privacy Policy, We only use this data in aggregate form.

We may freely use Non-Personally Identifiable Information in connection with the Services offered through the Platform, including: to administer the Services being offered thereunder, to understand how well the Service is working, to market the Services and other products and services, to develop aggregate, statistical information on usage of the Service and to generally improve the Service. Collecting this information enables us to better diagnose problems with our server and to administer the Platform, as well as understand the visitors who come to the Platform where they come from, and what content is of interest to them. This information aids us in merchandising and in developing the design and layout of the Platform.


We may also use your Personal Information to deliver information to you that, in some cases, are targeted to your interests, such as new services, rewards and promotions. The following are some circumstances under which and people to whom we would share your Information with from time-to-time:

6.1  Disclosure of Personal Information:

Registered Users: We do not disclose your Personal Information/Sensitive Personal Information to any third party for marketing purposes. Except as otherwise provided under this Privacy Policy, we will disclose your Personal Information to third parties only in the following limited circumstances:

(i) if you use the Service through the Platform, we may disclose your Personal Information/Sensitive Personal Information to our affiliates, agents, employees, consultants or trusted partners who work on behalf of or with us under confidentiality agreements. These entities may use your Personal Information for the purposes stipulated under this Privacy Policy, performing Services, administering promotions, analyzing data and usage of the Service through the Platform, processing payments and account actions, operating the Service or providing support and maintenance services for the same, or providing customer service, offering advice.

(ii) when we have your consent to otherwise share the information.

(iii) Notwithstanding anything to the contrary in this Privacy Policy, We reserve the right to use or disclose Personal Information and any other information we collect in connection with the Service offered through the Platform (a) If We believe that there is a significant/ real/ imminent threat or risk to your health, safety or life or to the health, safety or life of any other person or the public (b) to any successor to our business, including as a result of any merger, acquisition, asset sale or similar transaction, (c) to any corporate affiliate of ours whose privacy practices are substantially similar to ours, (d) to any law enforcement, judicial authority, governmental or regulatory authority, to the extent required by law or legal process, or (e) if in our reasonable discretion, such use or disclosure is necessary to enforce or protect our legal rights or to protect third parties.

6.2 Non-Personally Identifiable Information:

We may disclose other Non-Personally Identifiable Information to third party advertisers and advertising agencies, partners, and other parties in order for us and such third parties to analyze (a) the performance of, to operate and improve the Services offered through the Platform and (b) the behavior of Registered Users and to target offers and services to other users and depending upon their requirements. We may also disclose, use or publish this information for promoting the Services offered under the Platform. These third parties are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific outsourced operation, unless you have explicitly agreed or given your prior permission to them for additional uses.

6.3  Aggregate Information: Because the aggregate information we collect does not specifically identify you, it may be shared with any number of parties. For example, we may disclose anonymous, aggregated information to third parties such as potential business partners, end users, service providers, advertisers, and funding sources, in order to describe our business and operations.


6.4  Network Operators: Use of the Service provided through the Platform may involve use of the services of third party telecommunications carriers, internet service providers and service providers (such as the services of the carrier that provides cell phone service to you). Such carriers and service providers are not our contractors, and any information that a carrier collects in connection with your use of the Service provided through the Platform is not “Personal Information” and is not subject to this Privacy Policy. We are not responsible for the acts or omissions of telecommunications carriers, internet service providers or service providers.


Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. When personal data is no longer needed, we either irreversibly anonymize the data (and we may further retain and use the anonymized information) or securely destroy the data.


You may review, correct, update, change or delete your information at any time by contacting us at To protect your privacy and security, we will verify your identity before granting access or making changes to your Personal Information.

Even after you remove information from the Platform, copies of that information may remain viewable elsewhere, to the extent it has been shared with others or it was otherwise distributed pursuant to your privacy settings. Removed and deleted information may remain on backup media for up to one hundred and eighty (180) days prior to being deleted from our servers or for a period as required by law.  


We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. Registered Users are bound by any changes to the Privacy Policy when they continue to use the Platform after such changes have been first posted.


We take reasonable security measures and procedures, and as specified by applicable law, to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, or unauthorized access, disclosure or modification of Personal Information. While we take these reasonable efforts to safeguard your Personal Information, you acknowledge and agree that no system or transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for the unauthorized use of your information or for any lost, stolen, compromised passwords, or for any activity on your Account via unauthorized password activity. You agree and undertake that you shall not hold Company liable therefore in any way. The use and storage of any information, including without limitation, password, account information, transaction activity and any other information available on your internet access device or computer or mobile phone is at your own risk and responsibility. You furthermore acknowledge and accept that Company may not encrypt all content or communications shared on the Platform.


In accordance with Information Technology Act 2000 and rules made there under, in case of any complaints or grievances you can contact:

Name: Dwight Cook


In the event you wish to make a complaint regarding any violation of the provisions of the Privacy Policy, you may send a written complaint to the Grievance Officer, who shall redress the complaint within one (1) month.


This Policy shall be governed by and construed in accordance with the laws of the Republic of India. The courts at Bangalore, India shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Policy.

This Privacy Policy was last updated on 26 June 2021.