A Degree Above

Privacy Policy

At A Degree Above (“our”, “us” or “we”), we value your privacy and are committed to being fair, accountable, and transparent in how we handle your personal information. Our Privacy Policy (“Policy”) outlines how we collect, use, and disclose your personal information when you use our website (altius.adegreeabove.org and altius-app.adegreeabove.org) (“Sites” or “Websites”) or our services (“Service”) including the Altius platform. The obligations and responsibilities set out in the Privacy Policy are in addition to any other applicable policies or agreements entered into with A Degree Above and any applicable laws and/or regulations. We collect and process your personal information only after providing you with clear and accessible notice regarding the purposes of collection and processing, and after obtaining your valid consent where such consent is required. Consent, where relied upon as the basis for processing, is obtained through a clear affirmative action and is free, specific, informed, unconditional and unambiguous, and is limited to the personal data necessary for the specified purpose. A Degree Above only uses personal information as outlined in this Policy.

Note that in general, we will use the personal information we collect from you only for the purposes described in this Policy or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you if and where this is permitted by applicable data protection laws. During our relationship with you, we may collect information other than what is detailed in this Privacy Notice. If we ask you to provide information voluntarily, then the personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

1. About Altius and A Degree Above

Altius is an artificial intelligence-powered platform operated by A Degree Above that enables business professionals to engage in AI-assisted professional roleplay simulations, obtain AI-generated coaching insights, evaluations and scores, and participate in related training and debrief activities.

2. Application of the Digital Personal Data Protection Act, 2023

This Policy is drafted with reference to, and A Degree Above is committed to complying with, the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025 (together, the “DPDP Law”), to the extent applicable, in addition to any other data protection law that may apply to your personal information. Under the DPDP Law, A Degree Above acts as a “Data Fiduciary” in relation to your personal information, and you, as the individual to whom the personal information relates, are a “Data Principal”. Terms such as “personal data”, “processing” and “consent” used in this Policy carry the meanings given to them under the DPDP Law where applicable. A Degree Above will provide a clear, plain-language notice identifying, in an itemised manner, the personal data processed and the specified purpose for such processing, and will provide a readily accessible mechanism through which you may withdraw consent, exercise your rights, and raise grievances.

A Degree Above may also process personal information of individuals located outside India, including in the European Economic Area, the United Kingdom, the United States and other jurisdictions. Where such other data protection laws apply to you, Altius will comply with the requirements of those laws to the extent they apply, in addition to the DPDP Law.

3. Personal information we collect

a) Information collected automatically: Each time you visit the Sites, we may automatically collect certain types of information. Some examples of automatic information we may collect are as follows:

i. We may record your internet service provider’s address, your internet protocol or IP address, your MAC address, your operating system, the web page from which you came, your web browser software, the type of handheld or mobile device used to link to the web page, and the language and time zone settings on your web browser.

ii. We may collect a record of your activity or your “clickstream” while visiting the Sites.

iii. We may use “cookies” of different types to recognize your computer. A cookie is a small text file that a website, online application, or the e-mail may save to your internet browser and/or your computer’s hard drive for use in subsequent visits to the Sites or other sites.

iv. We may use web beacons, match scripts, pixel tags, or similar technologies that allow us to know if a particular web page was visited, an e-mail opened, links in the email utilized, or if the advertisements on the Sites or other sites were effective. In some instances, these technologies may allow us to match activities with particular users. We also may collect geo-location information, including from the GPS function on your device. We may use this information to improve our Services. You can opt-out of sharing your geolocation information by changing the settings on your device.

v. We collect the content of your conversations, prompts, queries and other inputs that you provide to our AI-powered Services, together with the AI-generated responses to such inputs (“Conversation Data”). Conversation Data may include business, commercial or other information that you choose to share during your use of the Services.

vi. We may collect information about your professional role, job title, employer or organisation name, industry, seniority and business contact details, to the extent you provide this to us or it is inferred from your use of the Services.

b) Information you provide:

i. We may collect any information, such as your first and last name, email address, postal address, and telephone number that you provide when you interact with Altius (including through our contact forms or inquiries).

ii. If you communicate with us, such as by email, by our webpages, or on social media sites, we may collect personal information that you submit to us, including your name, username, email address, any other information you voluntarily choose to provide us, and the contents of messages you send.

iii. We may collect information that is publicly available on the internet to improve our Services. While we do not intentionally seek out personal information, we understand that there is personal information incidentally included in these datasets.

iv. After a simulation, we may collect optional post-simulation reflection and review responses that you choose to submit through the Services, including mood or usefulness ratings, multiple-choice self-check answers, a short written commitment on how you intend to apply your learning, and, where you choose to provide one, a free-text review, comment or quote about your experience with the Services, together with your name and/or your organisation’s name (“Review Content”). Where you choose to provide your name and/or organisation’s name together with your Review Content, we may publish this information, together with your Review Content, on our Websites or in our marketing and promotional materials, on the basis of the consent you provide under this Policy. Submitting a quote does not, by itself, mean we will publish it.

c) Combined information: Information you provide directly to Altius through our Site or while availing our Service, are collected automatically. The information you provide to Altius may also be combined with demographic and other information that is available from other sources in order to allow Altius to better communicate with you and enhance our customer experience and make relevant offers to you.

d) Other Sources: We may receive your personal information from other parties. From time to time, we may receive personal information about you from third-party sources (including third-party websites, data brokers, or credit reference agencies), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. We use the information we receive from these third parties to help us market our Service to you, or otherwise develop and improve our Service.

e) Information from your Organisation: Where you access the Services through an account linked to your employer or another sponsoring organisation, we may receive personal information about you from that organisation, including your name and email address, and, where the organisation chooses to share it, information such as your tenure, date of joining, and hierarchy or reporting information.

f) Information from Sign-in and Identity Providers: If you sign in using Microsoft identity, Google identity, or other third-party identity or single sign-on providers, we receive information from such providers as permitted by your account settings with them, including your name, email address and related account identifiers.

g) Session and Usage Data: We automatically generate and collect information about your sessions on the Services, including the scenario selected, session status, turn count, and timestamps.

h) AI-Generated Data: Through your use of the AI-powered Services, we generate and collect Conversation Data, coaching prose, scores, and abuse and safety-related data.

4. Cookies and similar technologies

a) We and our service providers use cookies and other similar technologies to operate and improve our Services. Cookies help us to recognize you, customize or personalize your experience, analyse the use of our Services to make it safer and more useful to you.

b) It is usually possible to stop your browser from accepting cookies, or to stop it from accepting cookies from a specific website. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the ‘options’ or ‘preferences’ menu of your browser. To understand these settings, you can use the ‘Help’ option in your browser for more details. It is solely your responsibility to stop cookies in your browser. If you block the use of cookies, then this will limit the service that we are able to provide to you.

For detailed information on the cookies we use, their purposes and how to manage your preferences, including withdrawal of consent, please refer to our separate Cookies Policy. Non-essential cookies and similar technologies will be used only after obtaining the consent required under applicable law.

5. How may we use personal information?

We may use your personal information for a variety of purposes. Below, you will find information regarding how we may use your personal information.

a) To create and operate your account, authenticate you, and provide, analyse and maintain the Services.

b) To run AI roleplay simulations, generate coaching feedback, evaluation outputs and scores.

c) To detect abuse, apply lockouts or usage restrictions, and ensure the security and integrity of the Services.

d) To provide support and assistance, and to respond to incident or support requests.

e) To deliver organisation-sponsored access and fulfil learner access requests.

f) To enable review by authorised organisation administrators, A Degree Above specialists, and (where configured) client-assigned trainers.

g) To develop, train, test and improve our AI models and the Services, including by using Conversation Data for machine learning purposes, subject to your applicable consent and any opt-out rights made available to you.

h) To personalise and improve the relevance, quality and safety of AI-generated responses.

i) To conduct aggregated data analysis and research.

j) For providing and documenting training and qualifications.

k) For legal, regulatory or internal compliance purposes.

l) We process personal information about our alliance partners, sub-contractors and consortium partners when we engage with them either jointly or through separate contractual arrangements while offering our services to our clients.

m) We process personal information about our suppliers in order to onboard and manage our relationship and contract, and to receive services from our suppliers.

n) To publish your Review Content, together with your name and organisation’s name, on our Websites or in our marketing and promotional materials, where you have chosen to provide your name and/or organisation’s name for this purpose.

We process your personal information only after obtaining your consent where required.

6. How we may disclose personal information to third parties

Personal information collected by us will be used in accordance with this Policy and may be shared with our business partners, including third parties, for use in accordance with this Policy. A Degree Above does not sell your personal information to any third party.

We may disclose your personal information to others. Below, you will find information regarding how we may disclose your personal information.

a) To our contracted service providers: We may share your personal information with companies that provide support services to us, including services of hosting, cloud, analytics, content delivery, support and safety monitoring, payment and transaction, marketing and advertising and other technology services.

We take reasonable steps to select service providers that implement appropriate organisational and technical safeguards for personal information. Where we engage service providers to process personal information on our behalf, we require them, where appropriate, to process such information only for authorised purposes and in accordance with our instructions and applicable contractual obligations, and not to use such information for their own independent purposes except where otherwise permitted by law.

b) To AI and cloud infrastructure providers: We may share your Conversation Data and other personal information with third-party artificial intelligence model providers, cloud hosting providers, and infrastructure service providers who process such information on our behalf in order to deliver, operate, and improve the Services.

c) To regulatory authority: We may disclose personal information to the regulatory authority to:

i. Comply with laws or to respond to lawful requests and legal process;

ii. protect the rights and property of Altius and our agents, customers, and others, including to enforce our agreements, policies, and terms of service;

iii. to protect against legal liability;

iv. to protect the personal safety of Altius, its customers, or any person.

d) To our related companies: To our related companies to the extent such sharing is necessary to fulfil a request you have submitted via our Service or for customer management, customer support, technical operations, or the purposes described above.

e) To your sponsoring organisation: Where you access the Services through an account sponsored by your employer or another organisation, we may make your identity and organisation affiliation, operational account and session information, and simulation transcripts and evaluation outputs available to authorised administrators of that organisation, as configured for your account.

f) To marketing and publication partners: Where you have provided your name and/or organisation’s name together with your Review Content for publication, we may disclose your Review Content, name and organisation’s name to website hosting providers, social media or marketing platforms, and design or marketing agencies engaged to prepare or display such materials.

7. Retention of personal information

We retain your personal information, including Conversation Data, where we have an ongoing legitimate business need to do so. In certain circumstances, we will retain your information for legal reasons after our contractual relationship has ended. The specific retention periods depend on the nature of the information and why it is collected and processed, and the nature of the legal requirement. We delete or anonymize your personal information once it is no longer necessary for the purposes for which it was collected, except where longer retention is required or permitted by applicable law or where retained in de-identified or aggregated form for AI model training and improvement purposes. Where the DPDP Law applies, we will erase your personal information once you withdraw your consent or the specified purpose for which it was collected is no longer being served, unless retention is necessary for us to comply with any law for the time being in force. Where processing is based on consent, upon withdrawal of consent we will, within a reasonable time, cease and cause our Data Processors to cease such processing, unless continued processing is required or authorised under the DPDP Law or any other law for the time being in force in India.

The period for which we retain personal information also depends on factors including the nature and type of personal information, the purposes for which it was collected and processed, our business and operational requirements, and applicable legal, regulatory or contractual requirements.

Where you have provided your name and/or organisation’s name together with Review Content for publication, we retain and continue to display this content until you request that we stop, and will remove it within a reasonable time of such request, subject to the practical limitations on recalling already-distributed materials described in our Terms of Service.

8. Legal basis of processing information

The legal basis for processing depends on the applicable law. Where the DPDP Law applies, Altius processes personal data only on the basis of consent or a “certain legitimate use” recognised under the DPDP Act, 2023. Where other data protection laws apply, Altius may rely on the lawful bases available under those laws, as described below:

a) The processing is necessary for compliance with a legal obligation we have such as keeping records or providing information to a public body or law enforcement agency;

b) The processing is necessary for the purposes of a legitimate interest pursued by us or a third party (and are not outweighed by your privacy interests), such as the effective delivery of our Website and Service offered to you; the effective and lawful operation of our Website; to prevent fraud or criminal activity or to safeguard our technology systems and/or data security; to support or protect our business interests; to ensure that complaints are investigated; to evaluate, develop or improve our Service;

c) The processing is necessary to enter into a contract with you and/or in relation to the performance of a contract with you;

d) You have consented to us processing your information for a specific reason, consent that you can always withdraw. Where consent is the basis for processing under the DPDP Law, you may withdraw that consent at any time through a mechanism that is as easy to use as the mechanism through which consent was given, including through the applicable preference centre, account settings or by contacting us at [email protected]. You may specify the consent or processing purpose affected. Withdrawing consent will not affect the lawfulness of processing carried out before withdrawal, nor will it affect processing that we are otherwise authorised or required to undertake under applicable law.

i. You have given us your explicit consent to process that data;

ii. We are required by law to process that data;

iii. The processing is necessary in relation to assertion of our lawful rights, defense of legal claims, or in relation to disputes or contentious matters; or

iv. you have made the data manifestly public.

e) Note that in certain circumstances it may still be lawful for us to continue processing your information for separate purposes even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

f) Where the DPDP Law applies to the processing of your personal information, Altius processes such personal information only on the basis of your consent, or in reliance on the “certain legitimate uses” recognised under the DPDP Act, 2023, such as personal information voluntarily provided by you for a specified purpose, compliance with law, or for performing a contract with you.

9. Security of your information

a) We implement security measures we believe are reasonable to protect your information. It is important that you protect and maintain the security of your account and you need to immediately notify us of any unauthorized use of your account. Remember, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot and do not guarantee its absolute security.

b) To help protect the confidentiality of personal information, including the confidentiality of your Conversation Data given the sensitivity of business information shared through the Services, Altius employs security safeguards appropriate to the sensitivity of the information and in accordance with this Policy. These safeguards include reasonable administrative, technical and physical measures to safeguard the confidentiality and security of personal information against anticipated threats and unauthorized access to personal information. No transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

c) Your information, including personal information, may be transferred to, and maintained on, computers, servers or other data storage located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you reside outside India and choose to provide information to Altius, please note that we transfer the data, including personal information, to India and process it there. Your consent to this Policy followed by your submission of such information represents your agreement to that transfer. Given our use of third-party artificial intelligence and cloud infrastructure providers, your Conversation Data may also be transferred to and processed in other jurisdictions where such providers operate, subject to appropriate contractual and technical safeguards. Altius may transfer your personal information outside India except to countries or territories restricted by the Central Government by notification.

10. Grievance Officer and Grievance Redressal

In accordance with the DPDP Law, Altius has appointed a Grievance Officer to address your grievances relating to the processing of your personal information. You may contact the Grievance Officer as follows:

Name: Pranesh Nagarajan

Email: [email protected]

Address: VO 859, WeWork, DLF Forum, Raghavendra Marg, DLF Phase 3, Haryana 122002

A Degree Above will acknowledge and endeavour to resolve your grievance within a reasonable period, and in any event not exceeding ninety (90) days from the date of receipt, in accordance with the DPDP Rules, 2025. If you are not satisfied with our response, or do not receive a response within this period, you may approach the Data Protection Board of India, provided you have first exhausted the grievance redressal mechanism described in this Policy.

11. Children’s privacy

The Services are intended solely for use by business professionals acting in a professional capacity and are not directed at, marketed to, or intended for use by individuals under the age of 18. We do not knowingly solicit or collect personally identifiable information online from children under the age of 18 and do not knowingly permit any such individual to use the Services. If Altius learns that a child under the age of 18 has submitted personally identifiable information online without parental consent, it will take all reasonable measures to delete such information from its databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). In accordance with the DPDP Act, 2023, Altius does not undertake tracking or behavioural monitoring of children, or targeted advertising directed at children, and does not process the personal data of a child except with verifiable parental consent, where such processing is otherwise permitted by law.

12. Privacy rights and choices

a) Your rights: You may have the following rights in relation to your personal information, subject to applicable law and verification of your identity:

i. You may have the right to request to access, correct, update or delete your personal information, subject to certain applicable legal exceptions and/or our obligations towards third party.

ii. If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time by sending an email to [email protected] clearly specifying the consent you wish to withdraw and the purposes affected. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on other lawful grounds.

iii. The right to submit certain privacy requests through an authorized agent.

iv. The right to be free from discrimination for exercising the rights afforded to you under applicable privacy laws.

v. In order to protect your personal information, your ability to exercise some of the rights detailed in this Policy may be subject to your ability to verify that you are the person about whom your request pertains.

Please note that where processing of personal information is necessary to provide certain features or functionality of the Services, exercising certain privacy rights, including deletion or withdrawal of consent, may affect our ability to continue providing those features or Services.

vi. To exercise your rights using an authorized agent (as defined under applicable law), you must provide your authorized agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your authorized agent when they make a request on your behalf. We reserve the right to deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

b) Your duties: You have duties in relation to your personal information, including but not limited to:

i. You shall at all times provide complete, accurate and verifiable information to ensure integrity of the personal information.

ii. Comply with the provisions of all applicable local data protection laws including any updates, subsequent revisions/ amendments in such applicable laws.

iii. Ensure you do not impersonate another person while providing your personal information for a specified purpose.

iv. Ensure you do not suppress any material information while providing your personal information.

13. Do not track

a) “Do Not Track” is a preference you can set in your web browser to let websites and applications you visit know that you do not want them collecting information about you.

b) Please note that because the effect of “Do Not Track” signals remains unclear, and because there continues to be no consistent industry understanding of how to respond to such a signal, we do not alter our privacy practices when we detect a “Do Not Track” signal from your browser.

14. Changes to Privacy Policy

We may update our Privacy Policy from time to time. When we do, we will publish an updated version and effective date on this page, unless another type of notice is required by applicable law. If you use the Service after any changes to the Privacy Policy have been posted, all of the changes made will apply to your use of the Service.

15. Contact Us

If you have questions or concerns about this Privacy Policy, or to exercise any of your rights, please feel free to contact us at [email protected] or [email protected]