MENTOR RESOURCES, INC.

Privacy Policy

Effective: June, 2013

Updated: August, 2015

Updated: March, 2019

 

Introduction.

MENTOR RESOURCES, INC. PRIVACY POLICY

Mentor Resources (“we” or “us” or “our”) is committed to protecting your personal information while using and interacting with our websites: Web site, Program Web Sites, mobile sites and applications or our social media pages (hereinafter each a “Site” or collectively our “Sites”)”. We created this Privacy Policy to explain how we collect, use, disclose, transfer and store your information that you submit to us as a user or a visitor (collectively “user” or “you” or “your”) to our Sites. This Privacy Policy also describes how you can control the use and disclosure of your information.

This Privacy Policy does not apply to any information you may provide to us offline or through any means other than our Sites. For example, this Privacy Policy does not apply to information that you provide to us at a live meeting or event, or when you respond by telephone or any other instances in which we may collect information from you offline. This Privacy Policy also does not cover any information collected through any other site or application even if the other site or application is linked to our Sites (see the Section below entitled “How We Obtain the Information we get from your use of our Sites” and the subtitle “Links”)

Please take a moment to carefully read and familiarize yourself with our privacy practices. Your continued use of and/or participation on our Sites indicates your acceptance of this Privacy Policy and how we collect, use, disclose, transfer and store your information as a user of our Sites. You also under- stand and agree that any dispute regarding our privacy practices is governed by this Privacy Policy and our Terms of Use based on the laws and jurisdiction of San Francisco County of the State of California. Based on the foregoing, please note that we do not represent or warrant that the Sites are appropriate for use in any other jurisdiction. Those who choose to access our Sites do so at their own initiative and are responsible for complying with all local laws, rules and regulations. Further by using and participating in our Sites or providing us with your information, you consent to the collection, transfer, storage, access and processing of your information in and/or outside of the state and jurisdiction in which you reside.

1. Data Collection Overview.

We collect information in two ways: 1. Information you give us both personal and non-personal; and 2. Information we get from your access and use of our Sites. All of this information is volun- tarily provided by you.

1.1. Your Personal Information: We collect this Personal Information as well as non-person-

al information discussed below in a number of different ways. For example: If you choose to request information about our products and services described on our Website Site, you will need to complete our online request forms. The online forms provide you with an opportunity to request product downloads and demos, free trial requests, view our white papers, register for our free online webinars, and enroll for various services. These forms require specific personal information including but not limited to, your name, company name, e-mail address, company address, phone number (collectively “Personal Information”) as well as other non- personal information to help us determine and respond to your needs related to the products and/or services requested. All information provided by you is voluntary. We use this informa- tion to send email messages to users who opt-in to receive updates about us and our products and services; and to contact you to process your inquiries, respond to your requests and improve our services.

We also use the demographic information you provide on these forms in connection with stud- ies and reports regarding our Website Site, such as usage patterns, in order to better under- stand your needs. We will not, however, associate any personally identifiable information which you provide with the information in these studies and reports.

1.2 Information we share Unless otherwise specified in this Privacy Policy, we do not share Personal Information with companies’ organizations and individuals outside of our orga- nization unless one of the following circumstances apply:

With your consent:

We will share personal information with companies’ organizations and individuals out- side of our organization when we have your consent to do so. We require opt-in con- sent for the sharing of any sensitive personal information.

For legal reasons:

We will share personal information with companies, organizations or individual outside of our organization if we have a good faith belief that access, use, preservation or dis- closure of the information is reasonably necessary to:

  • Meet any applicable law regulation legal process or enforceable governmental request
  • Enforce our Privacy Policy and Terms of Use including investigation of potential violations
  • Detect prevent or otherwise address fraud, security or technical issues
  • Protect against harm to the rights, property or safety of our users or the public as required or permitted by law

If we are involved in a merger or acquisition we will continue to ensure the confidentiality of any Personal Information and give affected users notice before Personal Information is transferred or becomes subject to a different privacy policy.

Non-Personal Information:

We also collect non-personal information – data in a form that does not permit direct association with any specific individual. We may collect, use or transfer and disclose non-personal information for any purpose. For example: We may col- lect information such as occupation, language, zip code, area code, unique device identifier location; geo-location and the time zone where our Sites are accessed and used so that we can better understand user behavior and improve our products and services.

If we do combine non-personal information with Personal Information the combined information will be treated as Personal Information for so long as it remains combined.

2. How we use the Information we collect.

We use the information we collect from our Sites to provide, maintain, and improve our Sites and to enforce the legal terms of use for our Sites and for any other purpose for which you provided the information. If you chose to submit content for publication (e.g. on our blog), we may publish your photo, your screen name and/or other information you have provided

We use your personal information to provide you with personalized service; to send e- mail alerts to you; to answer your requests; to process your access and use of our SaaS service; etc.

We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

We may also use your information to track visitors to our Sites. This lets us see which of our features are the most popular so we can better serve our users' needs. It also lets us provide aggregate data about our traffic (not identifying you personally, but showing how many visitors used which features, for example) to outside parties

Meet any applicable law regulation legal process or enforceable governmental request

Enforce our Privacy Policy and Terms of Use including investigation of potential violations

Detect prevent or otherwise address fraud, security or technical issues

Protect against harm to the rights, property or safety of our users or the public as required or permitted by law

Non-Personal Information. We also collect non-personal information – data in a form that does not permit direct association with any specific individual. We may collect, use or transfer and disclose non-personal information for any purpose. For example: We may col- lect information such as occupation, language, zip code, area code, unique device identifier location; geo-location and the time zone where our Sites are accessed and used so that we can better understand user behavior and improve our products and services.

You may choose to opt out at any time as described in Section 3.2 below entitled: “Transparency and Choice”.

3.

Information we do not collect

We do not knowingly collect personal information from children under the age of 14. If we learn that we have collected the personal information of a child under the age of 14 without first

receiving verifiable parental consent we will take steps to delete the information as soon as possible.

How We obtain the Information we get from your use of our Sites.

3.1 Log and Device Information: Our servers automatically record information that your browser sends whenever you use or visit our Sites. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language and ver- sion, dial up domain, computer operating system; the date and time of your request and one or more cookies that may uniquely identify your browser. Internet Protocol addresses will in some cases by linked to Personal Information. We use this tracked information only to help diagnose problems with our server and to administer the Website Site and Program Website Sites.

2. Cookies: We send one or more cookies - a small file containing a string of characters - to your computer that uniquely identifies your browser to our server(s) whenever you access the Internet to use or visit our Sites as well as other sites and/or applications you visited before and after visiting our Sites, including but not limited to web pages and advertisements you view and links you click on our Sites, including mobile device identification numbers, that can identify the physical location of such devices in accordance with applicable law. We use cookies to personal- ize your experience, provide support to you if you are one of our SaaS customers, record visitor preferences, provide personalized and specialized content, record session information, track user trends related to the information you submit, and customize site content based on your browser type, operating system, and preferences. By gathering such information to supplement our records, we learn things like what pages are most attractive to our user(s), and which of our products most interest you, and what kinds of offers you would like to see.

Transparency and Choice

People have different privacy concerns. Our goal is to be clear about what in- formation we collect so that you can make meaningful choices about how it is used. You may always opt-out of receiving communications from us by changing your priva- cy preferences. For example:

You may set your browser to block all cookies. Most browsers are initially set up to accept cookies, however, if you prefer to reject these cookies you can opt-out by resetting your browser to refuse all cookies from us , including cookies associated with the Website Site and our products and services, or to indicate when a cookie is being set by us. However, it is important to remember that if you disable your cookie(s), you may still visit our Sites but you may not be able to access certain areas within our Sites and/or some features of our Sites may not function properly

3.3 Links: We may present links in a format that enables us to keep track of whether these links have been followed. We control how that data may and may not be used. However, we do not exercise control over links to our service providers; advertisers; partners or from within our various services, or other third party sites that may place their own cookies or other files on your computer, smart phone or similar devices or apps in order to collect data or solicit personal information directly from you. Therefore we cannot be responsible to you at law or otherwise for how the information, inclusive of your Personal Information, you submit to such third parties is used, collected and disclosed. We encourage you to review the policies of all third parties such as described herein in order to understand their processes for the collection, use and disclosure of information.

4. Social Networking

You can engage with our content such as video, applications and other offerings, on or through third party social networking sites such as Facebook, LinkedIn and other third-party social media plug-ins and applications. When you engage with our content on or through third party social networking sites, plug-ins and applications, you may allow us to have access to certain information from your social media profile (e.g. name, email address, photo, gender, birthday, location, your list of friends, people you follow and/or who follow you, the posts or the “likes” you make) to deliver the content or as part of the operation of the application. We may also obtain non-person- al identifiable information (e.g. content viewed) from your interaction with our content.

When you provide information from your social media account, it can help enable us to do things like: Personalize your online experience with us within and outside our Sites;

When you provide us with information via social networks, you consent to the use of this in- formation in accordance with our Privacy Policy.

When you provide Personal Information to us through an application on our Sites or on social networking sites, it may be publicly viewed by other members of these sites and/or applications and we cannot prevent or be responsible at law or otherwise for further use of such in- formation by third parties inclusive of such information becoming public.

However, through some social networking sites’ privacy settings, you can control what data you share. For more information about how social networking sites handle your Personal In- formation, please refer to and read their privacy policies and terms of use/service, including those of our service providers, partners and sponsors through whom you may access and use our Sites.

5.Privacy Shield: In addition to those privacy obligations as described in this Privacy Policy, Mentor Resources shall comply with the terms and conditions of the US-EU Privacy Shield framework as set forth by the U.S. Department of Commerce, consistent with its commitment to protect personal privacy to the extent necessary or appropriate in its role as a Data Processor on behalf of its customers and not for any other purpose under U.S Federal or state law with respect to the personal Information transferred by the Customer as the applicable Data Controller/Exporter/Importer accessing and using the Mentor Resources Service as such term is defined under the applicable privacy and data protection laws including the General Data Protection Regulation (EU) 2016/679) and any applicable national implementing laws, regulations and secondary legislation in England and Wales relating to the processing of personal data and the privacy of electronic communications, as amended, replaced or updated from time to time, including the Privacy and Electronic Communications Directive (2002/) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426). If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

6. California Residents’ Privacy Rights

Our Commitment to Data Security: To prevent unauthorized access, maintain data ac-

curacy, and ensure the correct use of your information, including your Personal Information, we have put in place reasonable physical, electronic, and managerial procedures in an effort to safeguard and secure the Information we collect online in compliance with cur California’s Privacy Laws. However, in the event we are the source of a security breach that exposed or may have exposed your Personal Information, and you are a resident of the State of California, then, as required by California Law we will provide you with immediate written notification of the security breach or potential security breach.

Deletion Requirement Law (also known as the “Eraser Button”): If you are a California resident under or at the age of 18, and a registered user of our Sites where the Privacy Policy is posted, you may request and potentially obtain removal of content or Personal Information you have publicly posted.

To make such a request please send an email to: kwise@mentorr.com.

All requests must provide: (a) a detailed description of the specific content or Personal Information you want removed; (b) information reasonably sufficient to permit us to locate the content or Personal Information, including but not limited to the name and URL (if applicable) of the Site where such information is located and (c) your registered username and contact information reasonably sufficient to contact you if we have questions. We shall not accept requests via postal mail, telephone, or facsimile. We are not responsible for requests that are not properly sent and may not be able to respond or take appropriate action if you do not provide complete information. Please note that requests for removal do not ensure removal of the content or Personal Information you have posted and there may be circumstances in which the law does not require or allow for removal even if requested.

7. Accessing and updating your personal information.

As a user of our Sites, we make good faith efforts to provide you with access to your Personal Information so you can request that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for other legitimate business purposes.

We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort jeopardize the privacy of others or are extremely impractical (for instance, requests concerning information residing on backup tapes).

8. Summary

Our Privacy Policy applies only to our Sites and the products and services owned or licensed by us. Our Privacy Policy does not apply to products and services offered by other companies or individuals, including other sites linked from our Sites. Once you leave our Sites via a third party link to its site and/or application, you should check the appropriate privacy policy of such third parties site or application to determine how they will handle any information that they collect from you as it may be different from how we handle your information under this Privacy Policy. You under- stand and agree that the links (as described in Section 3 above) are provided solely as a convenience to you and not as an endorsement by us. We are NOT responsible for the privacy practices or the content on any of these other sites or applications, including any sites or applications that may indicate a special relationship or “partnership” or “sponsorship” with us.

Our Privacy Policy does not apply to information you chose to disclose to other parties whether through chat rooms, forums, or interactive areas of our Sites that allow you to submit or post your own content or the like. We cannot prevent such information from being used in a manner that may violate this Privacy Policy, the law, or your personal privacy and safety. Therefore, we are not responsible or liable at law or otherwise to you or any third party for information you disclose on message boards, in chat rooms and forums, through content you provide or in any other way that can be viewed, collected and/or used by others.

9. Changes/Notification to Privacy Policy

If we decide to change our privacy policy, we will post those changes to this privacy statement, our Sites as applicable and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected.

 

If, however, we are going to use users' Personal, Information in a manner different from that stated at the time of collection we will notify users via email. Users will have a choice as to whether or not we use their information in this different manner. However, if users have opted out of all communication with our Sites, or deleted/deactivated their account, then they will not be contacted, nor will their Personal Information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on the applicable Sites notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.

Your use of the Mentor Resources Sites following notice of such change will be deemed acceptance of the revised Privacy Policy.

Contacting Us

If you have any questions or concerns about this Privacy Policy or the practices of any of our Sites, please contact us directly via email as follows: privacy@mentorresouces.com