Privacy Policy
Effective: May 15, 2024
1. INTRODUCTION
This Privacy Policy outlines the rules and procedures governing how Mentee Insight, LLC (the "Company," "we," "us," or "our") collects, uses, and discloses information pertaining to your access to and use of www.menteeinsight.com (the "Website"), our apps, software platforms, and products and services (collectively with the Website, the "Services").
By accessing or using the Website or our Services or otherwise interacting with us, you agree to our collection, use, and disclosure of information in accordance with this Privacy Policy and our Terms of Use, which is here incorporated by reference.
This Privacy Policy, the terms of which are subject to applicable laws, explains how we collect, use, share, disclose, store, and otherwise process your Personal Data when you use our Website and Services. It also explains your rights under applicable data protection laws (see sections 9 and 10). If you do not understand any aspects of our Privacy Policy, please contact us at support@menteeinsight.com and include in the subject line "Privacy Policy."
2. PERSONAL DATA COLLECTION AND USE
This Privacy Policy governs the Company's Processing of Personal Data that the Company gathers when you access and use the Services.
"Personal Data" means information that can be used to individually identify a person. Unless otherwise indicated by applicable law, Personal Data does not include publicly available information that is lawfully made available to the general public through federal, state, or local government records. You acknowledge that some combinations of data may individually identify a particular person and hence constitute Personal Data, even though no single piece of information in that combination, taken alone and by itself, would enable such individual identification to be made.
"Processing," "Process," or "Processed" means anything that is done with any Personal Data, whether or not by automated means, such as collection, use, storage, erasure, transmission, and disclosure.
When you use our Website or Services or otherwise interact with us, you provide Personal Data voluntarily. You understand that should you choose not to provide us with certain Personal Data, you may not have access to some features of the Website or Services. We disclaim any responsibility or liability for the Personal Data or information of others that you provide to us in the course of your use of our Services.
Personal Data Categories
Categories | Examples of Sources | Business Purpose | Examples of Recipients outside the Company |
Identifiers (such as real name, alias, postal address, email address, account name, online identifier, or other similar identifiers) | Information that you provide to us directly or when you interact with our Website or Services; information provided by Business Partners or by other third parties |
|
Service Providers; Advertising Partners; Business Partners |
Customer Records (such as name, telephone number, credit or debit card number, or financial account information) | Information that you provide to us directly or when you interact with our Website or Services; information provided by Business Partners or by other third parties |
|
Service Providers |
Professional, Employment-Related, and Education Data (such as resume or CV, education information, employment history, and other similar data that may be required for some of our Services) | Information that you provide to us directly or when you interact with our Website or Services; information provided by Business Partners or by other third parties |
|
Service Providers; Business Partners; Company Customers |
Internet or Other Electronic Network Activity (such as IP address, search history, browsing history, clickstream data, information regarding your interactions with our Services, or data associated with the utilization of Cookies or other tracking technologies for automated data collection, see section 7 below) | Information provided when you interact with our Website and Services |
|
Service Providers; Advertising Partners; Business Partners; Company Customers |
Geolocation Data | Information provided when you interact with our Website and Services |
|
Service Providers; Advertising Partners; Business Partners; Company Customers |
Inferences | Information that you provide to us directly or when you interact with our Website or Services; information provided by Business Partners, Company Customers, or other third parties |
|
Service Providers; Advertising Partners; Business Partners; Company Customers |
Marketing and Other Commercial Data (such as information relevant to goals and aspirations for our products and services, including marketing) | Information that you provide to us directly or when you interact with our Website or Services; information provided by Business Partners and Company Customers |
|
Service Providers; Advertising Partners; Business Partners; Company Customers |
Audio, Visual, Electronic, or Other Similar Data | Information that you provide to us directly or when you interact with our Website, Services, customers, or partners |
|
Service Providers; Business Partners; Company Customers |
Sensitive Personal Data
When you interact with our Website and Services, some Personal Data may be considered Sensitive Personal Data under applicable laws.
"Sensitive Personal Data" means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data processed solely to identify a human being, physical or mental health, sexual orientation or behavior, national identification number or other government-issued identifiers, precise geolocation, citizenship and immigration status, or any other information that may be deemed to be sensitive under applicable laws.
Subject to applicable laws, we may Process your Sensitive Personal Data in the ordinary course of our business for the following purposes constituting a legal basis:
- to perform Services requested by you;
- to perform Services on behalf of the Company;
- to Process your Sensitive Personal Data where we have obtained your express consent prior to Processing your Sensitive Personal Data;
- to prevent, detect, and investigate security incidents;
- to prevent, detect, investigate, and respond to malicious, deceptive, fraudulent, or illegal actions;
- to ensure the physical safety of natural persons;
- to establish, exercise, or defend legal rights;
- other activities as required or permitted by applicable laws.
3. DISCLOSURE TO OTHERS
The Company does not sell your Personal Data to third parties, and we have not sold the personal data we have collected in the preceding 12 months.
We may disclose Personal Data to third parties for business purposes identified in section 2 to facilitate providing the Services, as follows:
Service Providers
We may disclose your Personal Data to service providers who provide us with a range of services, including, but not limited to, hosting providers, financial transactions processors, operating systems and platforms, software platforms, email services providers, data linking platforms, data analytics providers, customer management systems, parties that need to operate the Website, cloud storage services, social media platforms, messaging platforms, content management systems, legal, auditing, and accounting professional services, and other service providers necessary to operate and improve our Website and Services, to fulfill requests you make, to perform identity verification, and otherwise to perform our Services. These service providers may access, store, or otherwise use Personal Data in the course of performing the services we have hired them to provide.
Business Partners
We may disclose your Personal Data to our business partners to offer you certain products, services, or promotions.
Advertising Partners
We may disclose certain limited Personal Data to advertising partners to show advertising that may be of interest to you. For more information, see the Cookie Policy.
Company Customers
You acknowledge that when you share Personal Data or otherwise interact with other users while using our Services (for example, by posting in a publicly available Company forum, messaging platforms, or on social media), such information may be viewed by all users of our Services and may be publicly distributed to other third parties. We disclaim any responsibility or liability for such information thus shared by you.
Other Disclosures
We may share or transfer your Personal Data in the following circumstances:
- through disclosure of Personal Data to third parties (for example, Business Partners, Service Providers, and law enforcement and government agencies) to secure our Website and Services and our rights and interests or those of our partners, customers, or others, including to prevent, detect, and investigate security incidents or violations of our Terms of Use, applicable laws, or other agreements, or in the context of legal proceedings;
- through disclosure of Personal Data to an acquirer, assignee, or other successor entity in connection with a sale, consolidation, merger, or reorganization of all or substantially all of our equity, business, or assets, including in the course of any due diligence process;
- at your direction (for example, if you choose to post in a publicly available Company forum, we will make the relevant Personal Data available to other users of the Website);
- when we disclose Personal Data as we deem necessary and appropriate under applicable laws, such as to comply with law enforcement or in response to legal requests by public, governmental, and regulatory authorities;
- to protect the rights, property, or safety of the Company, our customers, or others.
When we share your Personal Data with a third party, that third party will be contractually bound to adhere to all applicable laws and will be subject to binding contractual obligations (a) to prohibit that third party from selling that Personal Data, (b) to Process that Personal Data only in accordance with the specific purpose specified in the contract, and (c) to implement reasonable measures to protect the confidentiality and security of that Personal Data.
4. OUR STORAGE AND PROTECTION OF YOUR PERSONAL DATA
The Company employs reasonable and suitable procedures to safeguard your Personal Data, mitigating risks associated with Processing and providing protection against data loss, misuse, unauthorized access, disclosure, alteration, and destruction. Data from interacting with the Company's Website, including backup of that data in the cloud, is stored on servers located in the United States.
No guarantee as to the security of your Personal Data is made. There is always some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your Personal Data over the Internet will be compromised. We cannot guarantee the security of your data transmitted to us using the Internet – any such transmission is at your own risk, and you are responsible for ensuring that any Personal Data that you send to us is sent securely. It is also your responsibility to protect the security of your login information for your user account (when applicable). Please note that e-mail communications are typically not encrypted and should not be considered secure.
We retain your Personal Data for only as long as necessary to fulfill the purposes set forth in sections 2 and 3 and in accordance with applicable laws (for example, to resolve disputes and enforce our legal agreements and policies) or until you withdraw your consent (where applicable). To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Records of correspondence, such as product-related complaints, may be kept for a longer period sufficient to safeguard against legal claims.
5. DIRECT MARKETING
Direct marketing is the act of selling products or services directly to customers rather than through retailers. Subject to applicable laws, we may use your contact details (for example, email address, telephone, physical mail address, or other communication formats) that you have provided us for direct marketing purposes to provide you with information regarding Services that may interest you. You may unsubscribe for free from our marketing email communications list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of providing any Services you have requested.
6. ACCESS TO OTHER WEBSITES
Our Website or Services may contain links to other sites that are not operated by us. If you choose to follow a link to any of these sites, be aware that they operate under distinct privacy policies not governed by this Privacy Policy. Prior to submitting your Personal Data to such sites, please review their privacy policies. We have no control over and disclaim any responsibility or liability for the privacy policies, content, or practices of third-party sites or services.
7. COOKIE POLICY
The Website and other Services may use cookies and other tracking technologies (collectively, the "Cookies") for personalization and other purposes, including targeted advertising, enabling the Company to serve you better and more efficiently. We may utilize Cookies in order to track activity on the Website and to store certain information. At your discretion, you may alter a setting in your Internet browser to restrict the transmission of Cookies. However, enabling cookies may allow for a more personalized browsing experience and may be required for certain parts of the Website to work. For more information on our use of Cookies and related technology, see the Cookie Policy.
8. PROTECTING CHILDREN'S PRIVACY
Our Services are not intended for use by anyone under the age of 18. We do not knowingly collect or solicit Personal Data from anyone under 18. If we learn that we have collected Personal Data from anyone under 18, we will delete that information as quickly as possible. If you become aware that a child, as defined by the law of the relevant jurisdiction (for example, under the age of 18 in most states of the United States), has provided us with Personal Data on any individual, please notify us immediately at support@menteeinsight.com.
9. YOUR PRIVACY RIGHTS
Pursuant to applicable laws and subject to applicable exceptions, you may have certain rights in respect of your Personal Data, including:
- right to know what Personal Data we have collected and how we use and share or disclose it;
- right to request access to or copies of your Personal Data, together with information regarding the nature and Processing of such Personal Data;
- right not to provide your Personal Data to us (however, you may then not have access to some features of the Website or Services);
- right to request that inaccuracies in your Personal Data be corrected;
- right to limit the use and disclosure of Sensitive Personal Data collected about you;
- right to opt out of the sale of your Personal Data and right to opt out of the sharing of your Personal Data for cross-context behavioral advertising;
- right to delete Personal Data we have collected from you (subject to some exceptions);
- right to object to the Processing of your Personal Data by us or on our behalf for direct marketing purposes;
- right to non-discrimination for exercising your privacy rights;
- right to appeal a decision of ours in regard to your privacy rights request.
Nothing in this Privacy Policy affects any of your other statutory rights.
To exercise your rights described in this Policy or to ask a question about these rights, please email us at support@menteeinsight.com with details of the specific request you are making. As a first step in responding to your request, we may require confirmation of your identity. Once your identity has been confirmed, we will respond to your request in accordance with applicable law. If we cannot verify your identity, we will not provide or delete your Personal Data. To the extent permitted by applicable law and regulations, the Company reserves the right to charge a fee for its response to your request.
California residents and residents of some other U.S. states may also designate an authorized agent to exercise a privacy right on their behalf. To use an authorized agent, proof of the agent's authorization must be provided, including written permission from you and separate verification of your identity.
10. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA UNDER GDPR AND UK GDPR
Residents of the European Union, the European Economic Area (the "EEA"), and/or the United Kingdom (the "UK") may have additional rights with respect to their Personal Data under the General Data Protection Regulation (the "GDPR") or the UK GDPR in UK domestic law. With some differences, some other jurisdictions, including Brazil and Canada, have data protection laws providing protections similar to those of the GDPR.
Where the GDPR is applicable law, the following GDPR definitions apply (and supersede any definitions set forth above in this Privacy Policy):
- "personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- "processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- "controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
- "processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller (other than employees of the controller).
For purposes of the GDPR, the Company may be the controller of your personal data processed in connection with the provision of the Services. By reason of such processing, the Company may also be the processor of your personal data under the GDPR.
Where processing is governed by the GDPR, the legal basis for processing your personal data will be one or more of the following:
- your consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract;
- processing is necessary for compliance with a legal obligation to which the Company as data controller is subject;
- processing is necessary in order to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest;
- processing is necessary for the purposes of the legitimate interests pursued by the Company as data controller or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms.
Your personal data may also be transferred to, stored in, or otherwise processed in a country or jurisdiction where data protection laws are less stringent than the GDPR. By submitting your Personal Data to us, you agree to such transfer, storage, and other processing. We will take reasonable steps to ensure that your personal data is treated securely and in keeping with this Privacy Policy.
Subject to certain exceptions, under the GDPR you have the following rights with respect to your personal data:
- right of access (also known as a "data subject access request") (right to receive confirmation that we are processing your personal data and, if so, to receive a copy of the personal data we hold about you);
- right to rectification (right to have inaccurate personal data rectified or completed if it is incomplete);
- right to erasure (right for individuals to have personal data erased in certain circumstances, such as when the Company no longer needs it, or you withdraw your consent, where applicable, and there is no other legal basis for processing);
- right to restrict processing (right to restrict or "block" the processing of your personal data in certain circumstances, such as if you contest its accuracy or object to the Company processing it);
- right to data portability (right to obtain your personal data from the Company that you consented to give us, or that was provided to us as necessary in connection with our contract with you, in situations where processing is carried out by automated means);
- right to object (right to object to the processing of your personal data in certain circumstances, which includes the right to stop your personal data being used for direct marketing);
- right to withdraw consent (right to withdraw your consent, at any time, for the Company to process your personal data; but this withdrawal of consent will not affect any processing of your personal data that has already occurred);
- right to lodge a complaint with the relevant data protection authority.
These rights are subject to certain conditions and exemptions. For example, the Company may not be obligated to erase your personal data if retention is necessary for legal reasons.
To exercise these rights, please email us at support@menteeinsight.com with details of the specific request you are making. We try to answer every request as promptly as possible, within the time period stated by applicable law. When you email us with a request, the Company may ask you to supply us with confirmation of your identity. To the extent permitted by applicable law and regulations, the Company reserves the right to charge a fee for its response to your request.
11. CHANGES TO PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time. Any such changes will be posted on this Website and will be effective upon posting. If we make a material change to this Privacy Policy, we will notify you in accordance with applicable laws. You are advised to review this Privacy Policy periodically for any changes. In all cases, your continued use of the Services after such changes are published constitutes binding acceptance of the revised Private Policy.
12. CONTACT US
Should you have any questions or concerns about this Privacy Policy or our data practices, please email us with specifics at support@menteeinsight.com and include in the subject line "Privacy Policy."
Address:
Mentee Insight LLC
1280 Lexington Ave FRNT 2 #1042
New York, NY 10028
United States