We at ICLeaFTM (a product of InfoCareer Pvt. Ltd.) are committed to protecting the privacy and personal data of individuals who use our platform. This Privacy Policy explains how we collect, use, store, and protect personal data, and how we align with the principles of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
Although ICLeaFTM is based in India, we have implemented GDPR aligned practices targeted for EU residents as well, to ensure a high standard of data protection and future readiness.
Our Role Under GDPR
ICLeaFTM acts as:
- Data Processor, when processing personal data on behalf of customer organizations using the ICLeaFTM platform.
- Data Controller, for limited data related to our own business operations (such as customer communications).
In most learner and employee upskilling scenarios, our customers act as the Data Controllers, and ICLeaFTM processes data strictly based on their instructions.
Personal Data We Process
ICLeaFTM may process the following categories of personal data:
- Name
- Email address
- Phone number
- Job title / role information
- Skills and competency data
- Ensure compliance with enterprise and regulatory requirements.
We do not process any special categories of personal data (such as health, biometric, or sensitive personal information).
Purpose of Data Processing
Personal data is processed only for legitimate business and learning purposes, including:
- Learning delivery and learner enablement
- Skills intelligence and role based learning paths
- Learner progress tracking and course completion
- Leaderboards and performance insights
- Assessments and analytics
- Platform operations, security, and support
Data is never processed in a manner incompatible with these purposes.
Lawful Basis for Processing
ICLeaFTM processes personal data based on one or more of the following lawful bases:
- Performance of a contract with our customers
- Compliance with legal obligations
- Legitimate interests related to platform delivery, security, and improvement
- Consent, where required and applicable
Data Storage & Location
ICLeaFTM infrastructure can be configured and hosted anywhere around the world based on client requirements.
Security & Protection Measures
ICLeaFTM implements appropriate technical and organizational measures to protect personal data, including:
- Encryption of data in transit
- Role based access controls
- Secure authentication mechanisms
- System logging and monitoring
- Physical and logical access safeguards
We also maintain an incident response and breach management process designed to promptly assess, contain, and respond to any security incidents, in alignment with GDPR Article 32 principles.
Data Subject Rights
In line with GDPR principles, individuals have the right to:
- Request access to their personal data
- Request correction of inaccurate or incomplete data
- Request deletion of their personal data (“Right to be Forgotten”)
- Request restriction or objection to certain processing activities
ICLeaFTM handles data subject requests directly and responds in a timely and transparent manner.
Data Deletion & Retention
When a valid deletion request is received and approved:
- Personal data is fully and permanently erased from ICLeaFTM systems
- Deleted data cannot be recovered
ICLeaFTM retains personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by law or contractual obligations.
Sub Processors & Third Party Vendors
ICLeaFTM may engage trusted third party vendors (such as cloud infrastructure or support services) that may process personal data on our behalf.
We ensure that:
- Appropriate due diligence is conducted before engaging vendors
- Data protection obligations are contractually enforced
- Sub processors maintain security and privacy standards at least equivalent to ours
Transparency & Accountability
ICLeaFTM is committed to transparency, fairness, and accountability in all data processing activities. We maintain internal documentation and governance practices that support responsible data handling and continuous improvement of our privacy framework.
Contact Us
If you have any questions, concerns, or requests related to privacy or data protection, please contact us at:
Email: icleafsupport@infocareerindia.com
Note: This Privacy Policy is intended to demonstrate ICLeaFTM ’s alignment with GDPR principles and global data protection best practices.
Email: icleafsupport@infocareerindia.com
Note: This Privacy Policy is intended to demonstrate ICLeaFTM ’s alignment with GDPR principles and global data protection best practices.