Privacy Policy

Last updated: January 18, 2026

1. Introduction

ICQ Global ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our GameChangers Assessment tool. We comply with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

2. Data Controller

ICQ Global is the data controller responsible for your personal data. If you have questions about this policy or your data, please contact us at help@ICQ.global.

3. Information We Collect

We collect the following personal data:

Email address: Required to identify your assessment results

Assessment responses: Your answers to the assessment questions

Assessment scores: Calculated scores based on your responses

Completion timestamp: When you completed the assessment

4. Legal Basis for Processing

We process your personal data based on:

Consent: You provide explicit consent before starting the assessment

Legitimate interest: To provide you with personalised leadership development insights

5. How We Use Your Information

Your data is used to:

Generate your personalised GameChangers Profile report

Allow you to download your results as a PDF

Enable administrators to review assessment completions

Improve our assessment tool and services

6. Data Retention

We retain your assessment data for as long as necessary to fulfil the purposes outlined in this policy, or until you request deletion. You may request deletion of your data at any time through our "Manage Your Data" page.

7. Your Rights Under GDPR

You have the following rights:

Right to access: Request a copy of your personal data

Right to rectification: Request correction of inaccurate data

Right to erasure: Request deletion of your data ("right to be forgotten")

Right to restrict processing: Request limitation of data processing

Right to data portability: Receive your data in a portable format

Right to object: Object to processing of your data

Right to withdraw consent: Withdraw consent at any time

To exercise these rights, visit our Manage Your Data page or contact us directly.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data:

Encryption in transit: All data transmitted between your browser and our servers is encrypted using TLS 1.2 or higher

Encryption at rest: All stored data is encrypted using AES-256 encryption

Access controls: Row-level security policies ensure users can only access their own data

Authentication: Passwords are hashed using bcrypt with secure salting

Infrastructure security: Our hosting provider maintains SOC 2 Type II compliance

9. Data Location & International Transfers

Your data is currently processed and stored on servers located in the United States. For transfers of personal data from the European Economic Area (EEA) to countries outside the EEA, we rely on:

Standard Contractual Clauses (SCCs): EU-approved contractual terms that ensure adequate data protection

Data Processing Agreements: Binding agreements with our service providers that meet GDPR requirements

Our infrastructure provider (Supabase) maintains GDPR compliance and has implemented appropriate safeguards for international data transfers. You may request information about specific safeguards by contacting us.

10. Third-Party Services

We use the following third-party services to operate our platform:

Supabase: Database and authentication services (GDPR-compliant, SOC 2 Type II certified)

Resend: Email delivery services for notifications (GDPR-compliant)

We do not sell or share your personal data with third parties for marketing purposes. All third-party processors are bound by data processing agreements.

11. Cookies

We use the following types of cookies:

Essential cookies: Required for basic website functionality (session management, security)

Preference cookies: Store your consent choices and display preferences

We do not use tracking or advertising cookies. You can manage your cookie preferences through your browser settings or by using our cookie consent banner.

12. Data Breach Notification

In the event of a personal data breach that poses a high risk to your rights and freedoms, we will notify you without undue delay and within 72 hours of becoming aware of the breach, as required by GDPR Article 33 and 34.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. For significant changes, we may also notify you via email.

14. Supervisory Authority

If you are located in the European Economic Area and believe we have not adequately addressed your data protection concerns, you have the right to lodge a complaint with your local data protection supervisory authority.

15. Contact Us

If you have questions about this Privacy Policy, wish to exercise your rights, or want to make a complaint, please contact us at:

ICQ Global Data Protection Contact: help@ICQ.global