Last updated: June 2026 XCalibrate Global Solutions Inc. (referred as Company or “we” or “us” or “our“) is the owner of
the website domain at https://sherlockperformance.com/, mobile application
“SherlockSuperCoach.AITM” available at Google Play Store/Apple App Store; (referred as
“Platform”), and related services available through web and mobile channels (referred as
“Platform”); and any service availed by Users (hereinafter referred to as “you”, “your” or “User”)
through the Platform is conditioned upon your acceptance of the terms and conditions
contained in Terms of Service as available on Platform and this privacy policy (“Privacy Policy”).
THIS PRIVACY POLICY IS AN ELECTRONIC RECORD IN THE FORM OF AN ELECTRONIC
CONTRACT FORMED UNDER ANY RELEVANT STATUTE OR REGULATION UNDER ANY
APPLICABLE JURISDICTION. THIS PRIVACY POLICY DOES NOT REQUIRE ANY PHYSICAL,
ELECTRONIC OR DIGITAL SIGNATURE.
The purpose of this Privacy Policy is to ensure that there is an intact charter to collect, use and
protect any personal and/or sensitive data collected by us. This Policy defines our procedure for
collection, usage, processing, disclosure and protection of any information obtained by us
through the Platform. Capitalized terms that are not defined in this Privacy Policy shall have the
same meaning as ascribed to them in our Terms of Service. Any reference made to Privacy policy
in this document shall mean and refer to the latest version of the Privacy Policy
1. CONSENT
THIS PRIVACY POLICY IS A LEGALLY BINDING DOCUMENT BETWEEN YOU AND THE
COMPANY. THE TERMS OF THIS PRIVACY POLICY WILL BE EFFECTIVE UPON YOUR
ACCEPTANCE OF THE SAME OR BY YOUR USE OF OUR SERVICES AND WILL GOVERN THE
RELATIONSHIP BETWEEN COMPANY AND YOU FOR YOUR USE OF THE PLATFORM AND OUR
SERVICES
PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT AFFECTS YOUR RIGHTS AND
LIABILITIES UNDER LAW. BY USING THIS PLATFORM AND AVAILING OUR SERVICES, YOU
INDICATE THAT YOU UNDERSTAND, AGREE AND CONSENT TO THIS PRIVACY POLICY. IF YOU
DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THIS
WEBSITE OR AVAIL OUR SERVICES.
Please be advised that any Information procured by us, shall be:
(a) processed fairly and lawfully for rendering the Services;
(b) obtained only for specified and lawful purposes;
(c) adequate, relevant and not excessive in relation to the purpose for which it is required;
(d) able to be reviewed by the User, from time to time and updated-if need arises;
(e) not kept longer than for the time which it is required or the purpose for which it is required
or as required by the applicable law
f you do not agree with this Privacy Policy, you may refuse or withdraw your consent any time,
or alternatively choose to not provide us with any Personal Information, you understand that
under such circumstance, we may be unable to render Services. Any such intimation to
withdraw your consent can be sent to sherlocksupport@sherlocksupercoach.ai.
WE SHALL NOT BE LIABLE FOR ANY LOSS OR DAMAGE SUSTAINED BY REASON OF ANY
DISCLOSURE (INADVERTENT OR OTHERWISE) OF ANY DATA, IF THE SAME IS EITHER (A)
REQUIRED FOR SHARING YOUR INFORMATION FOR LEGITIMATE PURPOSES; OR (B) WAS
CAUSED THROUGH NO FAULT, ACT, OR OMISSION OF THE COMPANY
If you are using the Services as an employee of the Company’s customer, you are considered an
enterprise user. As such, provisions in this section related to data sharing and data transfer may
be superseded by written agreements between the Company and your employer. Under no
circumstances does the Company use your Personal Data for any purpose other than as
necessary to provide the Services to you and your employer. Any questions about the provisions
contained in the written agreements between the Company and your employer may be directed
to your company administrator.
2. TYPES OF INFORMATION COLLECTED BY US
(a) “Personal Data”means and includes any Information that relates to a natural person through
which an individual is identified, such as the name, email address and country provided by a
User as a part of their on boarding process.
(b) “Technical Information”” means and includes any Information gathered through various
technologies that may employ cookies, web beacons, or similar technologies to automatically
record certain information from your device through which you use the Platform. This technical
information may include your Internet Protocol (IP) address, device or browser type, Internet
service provider (ISP), referring or exit pages, clickstream data, operating system, hardware
model, operating system version, unique device identifiers, and mobile network. This data
includes usage information and user statistics.
(c) “Non-Personal Information”
(i) “Information collected through use of our Service” means and includes generic and non-
identifying information which is shared with us to avail our Services including without
limitation various information shared by the User in different modules in their coaching
journey, thinking preferences, challenge/issues they have been facing, their plan of actions and
reflections.
(ii) “Non-Personal Information” means and includes any information that does not reveal your
specific identity, such as, browser information, information collected through Cookies (as
defined below), pixel tags and other technologies, demographic information, etc. As is true with
most websites, our Company gathers some information automatically when you visit the
Platform. When you use the Platform, we may collect certain information about your computer
or mobile to facilitate, evaluate and verify your use of the Platform. For example, we may store
environmental variables, such as browser type, operating system, speed of the central
processing unit (CPU), referring or exit web pages, click patterns. This information is generally
collected in aggregate form, without identifying any User individually. (The Personal Data,
Technical Information and Non-Personal Information are collectively referred to as
“Information”).
3.COLLECTION OF INFORMATION
3.1. Information may be collected in various ways including during the course of you registering
as a User on the Platform, or availing certain Services offered on the Platform.
(a) Directly from you. For example, from the forms you complete on our Service, preferences
and responses you express or provide through our Service, or from your purchases on our
Service.
(b) Indirectly from you. For example, from observing your activity on our Service.
(c) Automatically from you. For example, through cookies we or our service providers set on
your Device as you navigate through our Service
(d) From Service Providers. For example we may receive Information about you from third-
party platform, such as social media platforms, marketing and advertising firms, commercially
available sources and business partners to whom you have consented disclosure of such
Information.
3.2. Please do note that each category of Information may be treated differently as per this
Privacy Policy.
4. PURPOSE FOR COLLECTING OF INFORMATION
4.1. The Company collects, uses, stores and processes your Information for any purpose as may
be permissible under applicable laws (including where the applicable law provides for such
collection, usage, storage or processes in accordance with the consent of the User) and shall
include the following:
(a) to render Services and facilitate your use of the Platform;
(b) to respond to your inquiries or fulfil your requests for information about the various
Services offered on the Platform;
(c) to provide you with information about Services available on the Platform and to send you
information, materials, and offers;
(d) to send you important information regarding the Platform, changes in terms and conditions,
user agreements, and policies and/or other administrative information;
(e) to send you surveys and marketing communications;
(f) to improve user experience;
(g) to help you address your problems incurred on the Platform including addressing any
technical problems;
(h) to protect the integrity and for proper administering of the Platform;
(i) to conduct academic research, surveys, analytical studies on various aspects including user
behaviour, user preferences etc.;
(j) to respond to legal, judicial, quasi-judicial process and provide information to law
enforcement agencies or in connection with an investigation on matters related to public safety,
as permitted by law;
(k) to implement information security practices;
(l) to determine any security breaches, computer contaminant or computer virus;
(m) to investigate, prevent, or take action regarding illegal activities and suspected fraud,
(n) to enable a potential buyer or investor to evaluate the business of the Company.
(o) Business or Research Purposes: The Information saved and except Sensitive Personal
Information, is used for business or research purposes, including improving and customizing
the Platform for ease of use and the products and services offered by us. We may archive this
information to use it for future communications for providing updates and/or surveys.
(p) Aggregating Information / Anonymized data: We may aggregate Information and analyse it
in a manner to further accentuate the level of services that we offer to our customers. This
Information includes average number of Users of the Platform, the average clicks of the
services/, the features used, the response rate, etc. and other such statistics regarding groups or
individuals. In doing so, we shall not be making disclosures of any Sensitive Personal
Information as defined above.
[Individually and collectively referred to as (“Legitimate Purposes”)]
4.2 Use of Content : We may use the Content you provide to enhance, maintain, and improve our
services, ensure compliance with applicable laws, enforce our terms and policies, and safeguard
the security of our services.
Opt-Out : If your organization has provisioned access to XCalibrate Sherlock AI on your behalf,
all requests to access, correct, delete, or restrict the processing of your personal information
must be directed to your organization’s designated administrator. XCalibrate processes such
data solely on behalf of and under the instructions of the organization. Accordingly, we are not
authorized to respond to these requests directly.
For personal data directly collected and controlled by XCalibrate Sherlock AI(for functioning &
processing of AI tool), you may request to access, correct, delete, or restrict processing of your
information, and withdraw consent where applicable (e.g., marketing).To exercise these rights,
please contact your administrator or email us at sherlocksupport@sherlocksupercoach.ai. We
will respond in accordance with applicable laws and timeline
4.3 USE OF AI SERVICES AND CONTENT
We may process content, prompts, responses, coaching interactions, feedback, assessments,
reflections, action plans, and other information you provide through Sherlock SuperCoach AI,
Sherlock Acumen, and related services to deliver, maintain, support, secure, troubleshoot,
monitor, and improve our services. Where third-party service providers support AI-enabled
services, such providers will process information only under appropriate contractual,
confidentiality, and security obligations. We do not use personal information for purposes
inconsistent with this Privacy Policy or applicable agreements with our customers. Information
processed through our AI-enabled services may be used to detect misuse, improve service
quality, maintain system performance, and provide enhanced user experiences while applying
appropriate safeguards and contractual protections.
5.SHARING AND DISCLOSURE OF YOUR INFORMATION
5.1. We do not sell your personal information and only share information as described in this
policy. Any sharing is performed only for legitimate business, operational, legal, security, or
service-delivery purposes described herein. Any such disclosure, if made, shall be in accordance
to this Privacy Policy and as per the procedure prescribed by law and in compliance with our
legal obligations. We may share your Information in circumstances and for the purposes as
specified hereunder,
5.2. If you are using the Services as a part of the Corporate Plan, we may share certain
Information and insights with your employer. However, we will ensure that the data shared will
not include any information that can identify you
5.3. We shall share the information to the third-party service providers/ vendors, to provide you
with the Services.
5.4. We may disclose any Information provided by you on the Platform as may be deemed to be
necessary or appropriate:
(a) under applicable law, including laws outside your country of residence;
(b) to comply with legal process;
(c) to respond to requests from public and government authorities including public and
government authorities including public and government authorities outside your country of
residence;
(d) to protect our operations or those of any of our affiliates;
(e) to protect our rights, privacy, safety or property, and/that of our affiliates, you or others;
(f) to allow us to pursue available remedies or limit the damages that we may sustain; or
(g) to protect against legal liability;
(h) to protect the personal safety of Users of the Platform;
(i) to prevent or investigate possible wrongdoing in connection with the Platform.
5.5. Merger or Acquisition: We may share Information upon merger or acquisition of Company
with another company. We shall transmit and transfer the Information upon acquisition or
merger of Company with another company.
5.6. With our service providers: We may share Information with other service providers on a
need to know basis, subject to obligations of confidentiality for provision of Services. We hereby
clarify that we work with institutions, vendors, partners, advertisers, and other service
providers, including (but not limited) to those who provide products or services such as contact
Information verification, website hosting, data analysis, providing infrastructure, information
technology services, auditing services and other similar services, in different industries and
categories of business by virtue of lawful contracts instituted between such third parties and
Company to improve our product and services. Accordingly, we may share your Information
with such service provider in order to provide you with Services.
5.7. Employees /Agents of Company: We follow a strict confidentiality policy with regard to
disclosure of confidential information to our employees or other personnel. There may be
situations, where we may disclose the confidential information only to those of our employees
and other personnel on a need to know basis. Any breach of confidential information by the
employees, personnel within the Company is dealt with stringently by us.
5.8. Except for the Information disclosed pursuant to this section, Company may share
Information only if you authorize us to do so.
6. LINK TO OTHER WEBSITES AND THIRD-PARTY SERVICES
6.1. Our Platform may provide links to other sites. These links are provided for your convenience
only and the provision of these links does not mean that sites are related or associated with us.
Please note that these sites have their own terms of use and privacy policy. You should check
their privacy policy before you submit Your Personal Information or any other data with them.
We don’t guarantee the content and the security of those sites
6.2. We may have certain features on our Platform which may be hosted by third parties, your
interaction with such features shall be governed by the privacy policy of such third parties
6.3. We shall not be responsible for any loss, damage, claim or expense caused as a result of you
accessing these third-party sites and features.
6.4. We may use your Information to send you promotional Information about third parties
which, we think you may find interesting, if you tell us that you wish this to happen. We shall
not be responsible for any disclosure of Information due to unauthorized third-party access or
other acts of third parties or acts or omissions beyond our reasonable control and you agree that
you will not hold us responsible for any breach of security unless such breach has been caused
as a direct result of our negligence or wilful default.
6.5. We may use support services of third-party platforms and/or companies to direct you to
payment gateways if you opt to pay for our Services. Your financial information is collected,
stored and retained by such third-party platforms. We and such designated third-party
platforms undertake measures designed to provide a security level that is appropriate to the
risks of processing your personal information. However, you are requested to check and consent
to the “Privacy Policy” of such third-party platforms in order to accept how such third-party
platforms handle your Information.
7. CHILDREN’S PRIVACY
Our Services are not meant to be used by Children (as defined by applicable privacy laws for a particular jurisdiction). We do not knowingly collect Personal Information relating to children and if you think that your child has provided this kind of information on our Platform, we strongly encourage you to contact us immediately and we will take reasonable steps to promptly remove or destroy such information.
8. DATA PROTECTION RIGHTS
8.1. You have certain rights available to you when it comes to your Personal Information. Subject to any exemptions provided by the applicable laws, you have the following rights:
8.1.1. Rectifying, correcting, updating and removing your information: You can access, edit, modify and/or update your Personal Information by logging into your user profile or you can write to us via email in case you wish to exercise this right.
8.1.2. Accessing and updating or deleting your information: Our Services and related
documentation on our Platform provide you with the ability to access, update and delete certain
Personal Information from your Account, if any. We will provide you with information about
whether we hold any of your Personal Information upon request. We will respond to such
requests within a reasonable timeframe. Please note, however, that we may need to retain
certain information for record keeping purposes, to complete our Services and related
obligations to you or to comply with our legal obligations.
8.1.3. Object or restrict processing of your information: You have the right to: (i) object to our processing of your Personal Information; and/or (ii) request that we restrict the processing of your Personal Information.
8.1.4. Portability: You shall have the right to request us to transfer your Personal Information to another controller, or directly to you, in a structured, commonly used and machine-readable format.
We collect personal information about you from your organization to facilitate the services we
provide through our Platform. The personal information we collect may include, but is not
limited to, your name, email, job title, and other relevant employment information. By using our
services, you acknowledge and agree to this collection of information from your organization as
outlined in this Privacy Policy.
10. STORAGE AND TRANSFER OF INFORMATION
Your Information will primarily be stored in electronic form; provided, however, that certain data can also be stored in physical form. We may store, collect, process and use your data in countries other than the jurisdiction where it has been collected, but under compliance with applicable laws. We may enter into agreements with third parties to store or process your information or data. These third parties may have their own security standards to safeguard your information or data and we will on commercial reasonable basis require from such third parties to adopt reasonable security standards to safeguard your information / data.
11. COOKIES AND OTHER TRACKING TECHNOLOGIES
11.1. Our Platform may utilize “cookies” and other Technical Information. “Cookies” are a small
text file consisting of alphanumeric numbers used to collect the Information about Platform
activity. The Technical Information helps us analyse web traffic and helps you by customizing
the Platform to your preferences. Cookies in no way gives us access to your computer or mobile
device. In relation to Cookies, you can deny access to the installation of the Cookies by modifying
the settings on your web browser, however, this may prevent you from taking full advantage of
the Platform.
11.2. Our use of Cookies and Technical Information allows us to improve Platform and your
experience of Platform and Services. We may also analyse Technical Information that does not
contain Sensitive Personal Information for trends and statistics.
12. DATA RETENTION
We will retain your Information for as long as your Account is active or as needed to provide our
Services. We shall retain and use the Information collected by us as necessary to comply with
our legal obligations, resolve disputes or for other Legitimate Purposes. If you cancel/
deactivate/ unsubscribe your account with us, we are not under any obligation to retain your
Information. However, may retain the Information pertaining to the User for the maximum
period permitted under the law of the land from the date of deactivation of User’s Account
13. SECURITY MEASURES AND SAFEGUARDS
You agree and accept that your Information may be stored in third-party cloud service
infrastructure providers. While all reasonable attempts have been taken from our end to ensure
the safe and secure storage of your data, we shall not be liable for any data breach on the part of
the third-party cloud service infrastructure provider that was beyond our control. In addition to
the security measures put in place by the third-party cloud service infrastructure provider for
safe and secure storage of your Information, we use certain physical, managerial, technical or
operational safeguards as per industry standards and established best practices to protect the
Information we collect. We use reasonable security practices and procedures and use secure
servers as mandated under applicable laws for the protection of your Information. We review
our Information collection, storage, and processing practices, including physical security
measures to guard against unauthorized access to systems. However, as effective as these
measures are, no security system is impenetrable. We cannot guarantee the security of our
database, nor can we guarantee that the Information you supply will not be intercepted while
being transmitted to us over the internet. However, since the internet is not a 100% secure
environment, we on best effort basis ensures the security of any information the User transmits
to us and that the information may not be accessed, disclosed, altered, or destroyed by breach of
any of our physical, technical, or managerial safeguards. Please note that e-mails and other
communications the User sends to us through our Platform are not encrypted, and we strongly
advise the User not to communicate any confidential information through these means.
14. DO NOT SELL
We do not sell your Personal Data in the conventional sense (i.e., for money). However, like
many companies, we use services that collect information from you (to deliver advertisements
to you for example) and this may classify this use as a “sale” of your Personal Data, you can
request to opt-out out of this “sale”, if you direct us not to sell your Personal Information, we
will stop sharing your personal information if required by submit a written request to us via
email at sherlocksupport@sherlocksupercoach.ai. You must put the statement “Sale of
Information- Opt-out) in your request and include your name, street address, city, state, and ZIP
code. We are not responsible for notices that are not labelled or sent properly, or do not have
complete information.
15. UPDATES TO THIS PRIVACY POLICY
We may change the data privacy practices and update this Privacy Policy as and when the need
arises, and the same will be made available on the Platform. But our commitment to protect
your privacy will continue to remain. We suggest that you regularly check this Privacy Policy to
apprise yourself of any updates. Your continued use of Platform and Services or provision of
Information thereafter will imply your unconditional acceptance of such updates to this Privacy
Policy. Further, we retain the right at any time to deny or suspend access to all, or any part of,
the service to anyone who we reasonably believe has violated any provision of this Privacy
Policy
16. MISCELLANEOUS
ENFORCEABILITY OF THE REMAINDER OF THIS PRIVACY POLICY. THIS PRIVACY POLICY
DOES NOT APPLY TO ANY INFORMATION OTHER THAN THE INFORMATION COLLECTED BY
US THROUGH THE PLATFORM. THIS PRIVACY POLICY SHALL BE INAPPLICABLE TO ANY
UNSOLICITED INFORMATION YOU PROVIDE US THROUGH THE PLATFORM OR THROUGH
ANY OTHER MEANS. ALL UNSOLICITED INFORMATION SHALL BE DEEMED TO BE NON-
CONFIDENTIAL AND WE SHALL BE FREE TO USE AND/ OR DISCLOSE SUCH UNSOLICITED
INFORMATION WITHOUT ANY LIMITATIONS. THE RIGHTS AND REMEDIES AVAILABLE
UNDER THIS POLICY MAY BE EXERCISED AS OFTEN AS NECESSARY AND ARE CUMULATIVE
AND NOT EXCLUSIVE OF RIGHTS OR REMEDIES PROVIDED BY LAW. RIGHTS UNDER THIS
POLICY MAY BE WAIVED ONLY IN WRITING. DELAY IN EXERCISING OR NON-EXERCISE OF
ANY SUCH RIGHT OR REMEDY DOES NOT CONSTITUTE A WAIVER OF THAT RIGHT OR
REMEDY, OR ANY OTHER RIGHT OR REMEDY.
17. THE FOLLOWING SECTION IS APPLICABLE TO RESIDENTS OF CALIFORNIA
“Personal Information” has the meaning given in the California Consumer Privacy Act of 2018
(“CCPA”) but does not include information exempted from the scope of the CCPA.
California’s “Shine the Light” law (Civil Code section 1798.83) also permits California residents
once per calendar year to request and receive information about a business’ disclosure of certain
categories of Personal Information to other companies for direct marketing purposes. If you are
a California resident and would like a copy of this notice, please submit a written request to us
via email at sherlocksupport@sherlocksupercoach.ai. You must put the statement
“California Privacy Rights” in your request and include your name, street address, city, state,
and ZIP code. We are not responsible for notices that are not labelled or sent properly, or do not
have complete information.
19. DATA PROTECTION OFFICER
Name: Puja Mehra
Address: 96 Green Street, Northborough, MA 01532
Email: puja@sherlockperformance.com
The DPO at XCalibrate plays a pivotal role in ensuring comprehensive compliance with GDPR
regulations and SOC standards. This dual compliance approach strengthens data protection
governance, supports risk mitigation, and maintains stakeholder trust.
Please feel free to reach out to us by e-mail at sherlocksupport@sherlocksupercoach.ai in case of any concerns, grievances, or questions relating to our privacy or data related practices.
