Last updated: May 28, 2021
Supportive Accountability Hub, Inc (“us”, “we”, or “our”) is the company that owns and operates the MentorHub mobile application (the “App”). The App is a mobile on-line application designed and offered to assist entities that provide mentoring relationships to children and adolescents.
We are a corporation, organized under the laws of Connecticut. You may contact us at email@example.com.
We respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit or use the Services or the App, and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On this Application.
- In email, text, and other electronic messages between you and this App.
It does not apply to information collected by:
- Use offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
- Any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from (or on) the App
Children Under the Age of 13
Children under the age of 13 are allowed to use the App only with prior, verifiable written approval by a parent or legal guardian in accordance with the Children’s Online Privacy Protection Act. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see your California Privacy Rights for more information.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our App, including information:
- By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or birthdate (“personal information”);
- That is about you but individually does not identify you, such as anecdotal information that you may share with us and that may identify you; and/or
- About your internet connection, the equipment you use to access our App, and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, the App’s third-party content providers.
Information You Provide to Us
The information we collect on or through our App may include:
- Information that you provide by filling in forms on our App. This includes information provided at the time of registering to use our App. We may also ask you for information when you report a problem with our App.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes or for purposes of promoting the efficacy of your mentor/mentee relationship.
- Your search queries on the App.
- Your picture used in the App profile
You also may provide information (such as chats) to be transmitted to other users of the App (your mentor or mentee, our App Administrator, and the program administrator provided by the entity sponsoring your mentor/mentee relationship) or to others (including and affiliated or independent third-party researchers). Such transmissions, together with any survey responses that you provide, are collectively referred to as “User Contributions”. Your User Contributions are transmitted at your own risk. Although we limit access to your User Contributions, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the App with whom you may choose to share your User Contributions. We do not select, approve, or control any Mentors; nor do we authorize participation by individual Mentees. The entity sponsoring each mentor/mentee relationship is responsible for the selection, approval, and control of Mentors and for authorizing participation by individual Mentees. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the App.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
- Information about when and to what extent you access, through the App, the content of our third-party content providers.
The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our App’s ability to enhance the effectiveness of mentoring relationships.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our App may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our App. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of our the App [and our e-mails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
The Mood Ring is a highly recommended feature of MentorHub that helps mentees to see their moods over time and help mentors better connect with mentees. Although this feature is highly recommended, mentees can opt-out by skipping this feature when presented in the application.
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
Third-Party Data Gathering
Our App uses proprietary analytics tools to track users on our platform and to analyze and gain knowledge from the usage data that is collected. The App may use third-party analytics providers, such as Google Analytics, to understand how our App is used.
Where the App provides access to third-party applications and websites, data regarding your access to and use of that third-party content are collected and sent to us automatically through partner API’s, thus enabling mentors and program and the App administrators to monitor the mentee’s use of the third-party content. This information allows the App and the third-party partners to learn how the App and third-party partner content are being used in order to monitor performance, develop enhancements, and for other purposes that support the App and the third-party partner websites and applications. De-identified, aggregated data may be shared with third-party partner app developers and with affiliated or independent researchers.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our App and its contents to you.
- To enhance the effectiveness of the mentoring relationships utilizing the App;
- To further develop the App by making it more effective and easier to use and navigate; and
- To contribute to the data available for research into the development and mentoring of youth.
- For any other purpose with your consent.
- We do not sell or use your information for marketing to you, either by us or by third-parties.
The MentorHub assessment is designed to help the program administrators better match mentors with mentees. An Anonymized version of this data may be used in the future to improve the app and for research purposes.
The MentorHub allows an easy and convenient way for mentors and mentees to chat inside the app and on the website. The chats will only be visible to the mentors, mentees, and program administrators. The program administrator can review chats that are flagged for further review if it is deemed to be harmful to either the mentor or mentee. Chats that are not flagged for further review will be deleted after 12 months.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- To the mentor or mentee with whom you are in a mentoring relationship, and to the program and MentorHub administrators with responsibility for oversight of that relationship;
- To affiliated and independent third-party researchers who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our App users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms and Conditions of Use and other agreements.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us or others.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Accessing and Correcting Your Information
You can review and change your personal information by logging into the App and visiting your account profile page.
You may also send us an email at email@example.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other App users. Proper access and use of information provided on the App, including User Contributions, is governed by our Terms and Conditions of Use.
California residents may have additional personal information rights and choices.
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information is protected through token-based authentication and all requests are validated against user roles. A user must provide credentials to get a token (which is a unique encrypted string to identify the user). Once issued, the token is required to authorize any information access. All information access requests are monitored and protected against common web attacks using firewalls. The firewall rules address OWASP vulnerabilities. IP Whitelisting & rate limiting giving additional protection. The data is stored in MongoDB provided by MongoDB Atlas cloud services (a product of Mongo, Inc.), by which basic information is encrypted and database access is restricted through authentication. Network communication is through encrypted channels. Chat-based information is kept in Firebase Realtime Database and protected with authentication and rules-based access validation. All communication through networks are encrypted using SSL.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards. The information you share in public areas may be viewed by any user of the App.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App.
Please contact us by email at firstname.lastname@example.org. We may be required to ask for further information and/or evidence of identity. We will endeavor to respond fully to all requests within one month of receipt of your request, however, if we are unable to do so, we will contact you with reasons for the delay. Please note that exceptions apply to a number of these rights, and not all rights will be applicable to you in all circumstances.
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