MentoringComplete by Engagedly product, is committed to protect the privacy of our customers. This Privacy Policy outlines the information collected as well as how it may be used and is applicable to MentoringComplete services/platforms/applications.
For our client data privacy policy, please see our MentoringComplete App Privacy Policy.
MentoringComplete is the most comprehensive mentoring solution on the market today. MentoringComplete’s system uses focus areas, personal characteristics, mentoring roles, and other criteria to make sure that a match is “right” for the mentee and the mentor.
1. When you register with MentoringComplete, information is needed such as your name, company name, email address, address, phone number, and other information about yourself or your business.
2. While you don’t need to provide any information to explore our websites, we do collect navigational information. We do sometimes request you to provide personal information when you are seeking certain things from us (like our downloadable white papers).
Navigational information refers to information about your computer and your visits to this website, such as your IP address, geographical location, browser type, referral source, length of visit, and pages viewed.
Personal Information refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, email address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into via the Websites, and information about you that is publicly available on the Internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.
3. MentoringComplete uses collected information for processing your order, billing and service improvement. we may use your Personal Information to improve your browsing experience by personalizing the Websites and to improve the Subscription Services with more targeted content.
4. MentoringComplete will not sell, rent, exchange or share your Personal Information with any third parties without your permission. Having said that, if we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy, or otherwise, that company would receive all information gathered by our Websites and the Subscription Services.
5. MentoringComplete may share the collected information in order to (i) respond to investigations, court orders or legal process, (ii) to investigate, prevent or take action regarding illegal activities, suspected fraud, potential threats to the physical safety of any person, (iii) violations of MentoringComplete’s terms of service, or (iv) as otherwise required by law. Note that we may be required to share personal data of EU and/or Swiss individuals in response to lawful requests by public authorities including to meet national security and law enforcement requirements.
5.1. Data Retention We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will delete this information from the servers at an earlier date if you so request, as described in the opting out and unsubscribing sections (Section 16) below.
5.2. Accessing and Modifying Your Information We acknowledge the right or EU and Swiss individuals to access their personal data held by us. Individuals wishing to view, update, delete, or supplement their personal data may do so by filling out a web form via our Data Subject Access Request (DSAR) Portal. You can also email us at privacy@engagedly.com if you are unable to submit your request through our DSAR Portal.
5.3. All of your data remains private and confidential. With that said, our employees have access to your personal information. We also employ other companies and people to provide services (such as website development, for example) and they have access to your information, as well. These people understand that your Personal Information is confidential and can only be used in accordance with this privacy policy.
On rare occasions, a trusted third party might ask us about the demographic makeup of our contact database. In these instances, we might provide statistical information about our database in aggregate, but never any information that could be used to identify any individual user.
6. How We Protect Your Information We strive to maintain commercially reasonable; physical, electronic, and procedural safeguards to secure the Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. Please keep in mind, however, that there is no way to make the transmission of electronic data entirely hack-proof.
7. MentoringComplete will send you a welcome email, as well as emails regarding relevant notifications. Administrators (Someone on the client side who manages all user management activities of their organization in MentoringComplete) will at times receive MentoringComplete service related announcements. All emails can be disabled by the recipient in their settings page. At that point, we won’t email you any further communications unless at some point you change your mind and you decide to provide your expressed consent.
8. As is true of most web sites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We link this automatically collected data to other information we collect about you.
The MentoringComplete website uses HubSpot to collect information about its visitors. HubSpot’s agreement with Engagedly prohibits us from using the Subscription Service to collect, manage, or process Sensitive Information. “Sensitive Information” refers to credit or debit card numbers, personal financial account information, Social Security numbers, Social Insurance numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other financial or health information. HubSpot is not responsible for the information we collect.
Technologies such as: cookies, beacons, tags and scripts are used by MentoringComplete and our marketing partners, analytics providers, and customer support systems. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use cookies for marketing and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited MentoringComplete uses a technology called “cookies” to store session information. A cookie is a small amount of data, which includes an anonymous unique identifier that is sent to your browser from our website’s computers and stored on your computer’s hard drive. MentoringComplete will set and access MentoringComplete cookies on your computer. Cookies are required to use the MentoringComplete service.
To learn more and for a detailed cookie notice, the User may consult the Cookie Policy
9. We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control such as an email service provider to send emails on our behalf, mapping service providers, and customer support providers (our “Agents”). We may need to share Personal Information with our Agents in order to provide Services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents. We are liable for the appropriate onward transfer of EU and Swiss personal data to third parties acting as our agents unless we can prove we were not a party giving rise to the damages.
10. We collect statistical information about how both users and administrators collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you or your web browser.
11. MentoringComplete may update this Privacy Policy and will notify customers of significant changes in the way we treat any personal information by sending a notice to the primary email address specified in your MentoringComplete account. We will also place a prominent notice on our website.
12. Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share This button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.
13. Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us by filling out our Data Subject Access Request (DSAR) web form. You can also email us at privacy@engagedly.com if you are unable to submit your request through our DSAR Portal. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
14. At times, you may be able to access other Third Party Services through the Services. This Privacy Policy does not apply to any third party applications or technology that integrate with the Services (MentoringComplete Application), or any other third party products, services, or businesses (“Third Party Services”). While using the Services, you may be directed to a third party website via links or other references, which may take you to that third party website (“Third Party Websites”). This Privacy Policy does not apply to you or any other data collected from or provided by you to Third Party Websites. You should review such Third Party Services’ or Third Party Websites’ privacy policy (and such other terms and conditions) to determine how your data will be used before sharing any Personal Data.
15. As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to promotions we are offering through the Services. You may opt-out or unsubscribe to receiving such communications by following the instructions included with such emails, or by by filling out our Data Subject Access Request (DSAR) web form.
16. Our Websites and Subscription Services are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us so that we may delete the information.
17. MENTORING COMPLETE AND THE CALIFORNIA CONSUMER PRIVACY ACT
Background: The new ‘California Consumer Protection Act’ (CCPA) came into effect in on January 1, 2020. The state law grants California consumer residents new rights over their personal information. These rights are, the right to know (or access), the right to delete, and the right to opt-out of sale of personal information that a company may collect, retain, or disclose about a consumer. Additionally, the CCPA prohibits businesses from discrimination against consumers in terms of access to services if they choose to exercise their rights under the CCPA.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category | Examples | Collected |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | Yes Email address, full name, IP address, unique employee identifier. |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | Yes Name, address, telephone number and employment details like titleand history. |
C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Yes Age, Ethnicity, Gender |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | No |
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No |
F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | No |
G. Geolocation data. | Physical location or movements. | No |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | No |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | Yes Job History, Title |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | No |
K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | No |
Security
Mentoring Complete has stringent state of the art security controls designed to protect your data. Specifically, cybersecurity risks are taken very seriously at Mentoring Complete and are managed daily by our CISO. All employees are required to review and agree to Mentoring Complete’s strict IT Security Policies, which are annually reviewed to incorporate periodic updates. Mentoring Complete is also annually audited by 3rd party auditors for SSAE 18 SOC2 Type 2 compliance as well as annually audited by 3rd party auditors for penetration and vulnerability testing. All data transacted by Mentoring Complete is encrypted when in transit and at rest.