This Cookie Policy (“Policy”) describes the use of cookies and similar tracking technologies by Dott Connect Private Limited, together with its affiliates and group companies (collectively, “Dott”, “DCPL”, “we”, “us”, or “our”), in connection with the websites, applications, and platforms operated by DCPL (collectively, the “Platform”).

This Policy applies to all users who access or use:

• Dott 360 – 360° Feedback Platform
• Dott Sense -Engagement & Experience Survey Platform
• Elyevate Learning Platform (ELA)

This Policy should be read in conjunction with the Privacy Policy and Terms of Service.

1. Definition of Cookies and Similar Technologies

“Cookies” are small text files that are stored on a user’s device when accessing a website or digital platform. Cookies enable recognition of the device and facilitate the storage of certain information related to user preferences, session activity, and interactions.

For the purposes of this Policy, the term “Cookies” includes similar technologies such as:

• web beacons
• pixels
• tags
• local storage objects
• software development kits (SDKs)
• and other tracking mechanisms

2. Purpose of Use

DCPL uses Cookies for legitimate business purposes, including but not limited to:

2.1 Essential Functionality

To enable the operation of the Platform, including:

• authentication and secure login
• session management
• system administration
• prevention of unauthorized access

Such Cookies are strictly necessary for the functioning of the Platform.

2.2 Performance and Analytics

To analyse usage of the Platform and improve performance, including:

• understanding user interactions and navigation patterns
• identifying errors and system inefficiencies
• improving product features and usability

Such data is typically aggregated and does not directly identify individual users.

2.3 Platform Enhancement

To improve user experience and optimize Platform functionality, including:

• enhancing workflows and navigation
• improving reporting and analytics outputs
• refining learning pathways within ELA

2.4 Security and Integrity

To:

• detect and prevent fraud, misuse, or unauthorized access
• maintain system integrity and stability
• support monitoring and incident response mechanisms

2.5 Communications and Service Delivery

To support:

• session continuity
• troubleshooting and user support
• reliable delivery of Platform services

2.6 Advertising and Marketing (Where Applicable)

Where permitted by applicable law, Cookies may be used to:

• measure effectiveness of marketing campaigns
• deliver relevant communications or content

DCPL does not use Cookies to associate identifiers with sensitive categories of Personal Information.

3. Categories of Cookies

DCPL may use the following categories of Cookies:

3.1 Strictly Necessary Cookies

Required for operation of the Platform. These cannot be disabled without impairing functionality.

3.2 Performance and Analytics Cookies

Used to collect aggregated information about Platform usage to improve services.

3.3 Functional Cookies

Enable customization of user experience and retention of user preferences.

3.4 Security Cookies

Used for authentication, fraud prevention, and protection of user data and Platform integrity.

3.5 Advertising Cookies (Limited Use)

Used, where applicable, to support marketing activities and measure campaign performance.

DCPL does not sell Personal Information collected through Cookies.

4. Information Collected Through Cookies

Cookies may collect or process information such as:

• Internet Protocol (IP) address
• device identifiers
• browser type and version
• operating system
• pages visited and time spent
• clickstream data and navigation behaviour
• session identifiers
• approximate geographic location (derived from IP address)

Where feasible, such data is aggregated, anonymised, or pseudonymised.

5. Third-Party Cookies

DCPL may permit third-party service providers to place Cookies on the Platform for purposes including:

• analytics and performance monitoring
• infrastructure and hosting services
• communication and messaging services

Such third parties process data in accordance with their own privacy policies and applicable contractual obligations.

DCPL does not control third-party Cookie practices and disclaims responsibility for their independent processing activities.

6. Cross-Border Data Processing

As DCPL operates internationally and serves clients across multiple jurisdictions, including India, Southeast Asia, the Middle East, and the United States, data collected through Cookies may be processed in jurisdictions outside the user’s country of residence.

DCPL implements appropriate safeguards to ensure that such processing complies with applicable data protection laws.

7. User Controls and Consent

7.1 Browser Controls

Users may manage Cookie preferences through their browser settings, including:

• blocking or deleting Cookies
• restricting certain categories of Cookies
• receiving notifications when Cookies are placed

7.2 Consent Requirements

Where required under applicable law:

• DCPL shall obtain user consent prior to placing non-essential Cookies
• users may withdraw consent at any time

7.3 Impact of Disabling Cookies

Disabling Cookies may result in:

• limited functionality of the Platform
• inability to access secure areas
• disruption of user sessions and preferences

8. Data Protection and Security

DCPL implements appropriate technical and organizational measures to protect information collected through Cookies, including:

• encryption and secure data transmission
• access control mechanisms
• monitoring and security protocols

While reasonable safeguards are implemented, no system can be guaranteed to be fully secure.

9. Updates to This Policy

DCPL reserves the right to amend or update this Policy at any time.

Any changes shall become effective upon publication on the Platform, unless otherwise required by applicable law.

Continued use of the Platform following such changes shall constitute acknowledgment and acceptance of the revised Policy, to the extent permitted by applicable law.

10. Contact Information

For any questions regarding this Policy or the use of Cookies, please contact:

Dott Connect Private Limited
E: privacy@dottinc.com