Privacy Policy

ICH — Human Behaviour Index (individual creator, sole trader, France).

Contact for privacy requests: see the footer of this page.

Account: your name, email, and profile picture supplied by Google when you sign in through Emergent-managed Google Auth. Legal basis: performance of the service (Art. 6(1)(b) GDPR).

Professional profile: fields you choose to add (profession, industry, country). Legal basis: consent (Art. 6(1)(a) GDPR) — you can leave them blank.

Assessment responses and computed scores: legal basis: performance of the service.

Missions and reflections: what you completed, when, and the reflection text you wrote. Legal basis: performance of the service.

Coach messages: your prompts and the AI replies, so conversations remain continuous. Legal basis: performance of the service.

Share analytics: hashed viewer signatures (IP + coarse browser family), referrers, timestamps — used only to power your reach analytics. We never store raw IPs against your Passport. Legal basis: legitimate interest (product analytics on aggregated, pseudonymous data).

Session cookies: strictly necessary to keep you signed in.

Strictly-necessary cookies: session_token (HTTP-only) to keep you signed in.

We do not use advertising cookies. We do not sell your data. We do not embed third-party tracking pixels.

You can choose to accept or decline non-essential cookies in the cookie banner. Your choice is stored locally in your browser.

Emergent (identity & LLM gateway) — sign-in, and the AI Coach. Emergent routes Coach messages to Anthropic (Claude Sonnet 4.6).

Anthropic — processes the text of your Coach messages to generate replies. Anthropic does not train its models on API traffic by default.

MongoDB Atlas or equivalent hosted MongoDB — encrypted storage for the data described above.

None of the above are permitted to use your data beyond delivering their part of the service.

Some processors (LLM inference, hosting) may operate outside the EU. Transfers rely on Standard Contractual Clauses and additional safeguards where applicable.

Account data: kept while your account is active, deleted within 30 days of a deletion request.

Assessment responses & scores: kept until you request deletion.

Coach messages: kept for continuity; you may clear them at any time by deleting the account, or (on request) individual sessions.

Share analytics: rolled up to daily counters; raw view rows kept 90 days maximum.

Backups: overwritten within 30 days.

Access — you can request a copy of the data we hold about you.

Rectification — correct any inaccuracy.

Erasure — request deletion of your account and data.

Portability — receive a machine-readable copy of your data.

Objection & restriction — where processing is based on legitimate interest.

Withdraw consent — for anything processed on the basis of consent.

To exercise any right, write to the address in the footer. We respond within 30 days.

You may also lodge a complaint with the CNIL (France) or your local data-protection authority.

HTTPS everywhere. Session cookies are HTTP-only and Secure. Passwords are not stored (Google Auth). Rate limits and per-user caps on the Coach protect against abuse.

No system is unbreakable; if we ever suffer a personal-data breach, we will notify affected users and the relevant authority within 72 hours where required.

ICH is not for children under 16.

We will publish updates here with a new effective date. Material changes will also trigger an in-app notice the next time you sign in.