app-privacy-policy

 

PRIVACY NOTICE 

Last updated January 1, 2023 

We have recently reviewed our privacy policy to ensure that it accurately reflects our current privacy practices and complies with the most up-to-date laws and regulations. We take our privacy obligations seriously and are committed to protecting the personal information of our users. As such, we have made sure that our privacy policy is up to date and reflects our commitment to privacy and data protection. 

This privacy notice for Supportive Accountability Hub, Inc. and Supportive Accountability Hub LLC (doing business as Mentorhub) (“Mentorhub,” “we,” “us,” or “our“) describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you: 

  • Visit our website at https://mentorhub.org, or any website of ours that links to this privacy notice 
  • Download and use our mobile application (Mentorhub), or any other application of ours that links to this privacy notice 
  • Engage with us in other related ways, including any sales, marketing, or events 

The purpose of this privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. 

Children Under the Age of 13  

Children under 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 (COPPA). This verifiable written approval will be obtained and stored with the organization that contracts with Mentorhub for this service. 

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 info@mentorhub.org. 

Children between the ages of 13 and 16 

Our organization will handle the personal information of a child who is a California resident that we know to be between ages 13 and 16 with affirmative authorization (“opt-in”) consent according to the California Consumer Privacy Act (CCPA).  

Please read this privacy notice carefully, as it will help you understand what we do with the information we collect. 

TABLE OF CONTENTS 

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
  6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  8. HOW LONG DO WE KEEP YOUR INFORMATION?
  9. HOW DO WE KEEP YOUR INFORMATION SAFE?
  10. WHAT ARE YOUR PRIVACY RIGHTS?
  11. CONTROLS FOR DO-NOT-TRACK FEATURES
  12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  13. DO WE MAKE UPDATES TO THIS NOTICE?
  14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

  1. WHAT INFORMATION DO WE COLLECT?

 

The personal information you disclose to us 

 

In Short: We collect the personal information you provide. 

 

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. 

 

Personal Information Provided by You. The personal information we collect depends on the context of your interactions with the Services and us, your choices, and the products and features you use. The personal information we collect may include the following: 

  • names 
  • phone numbers 
  • email addresses 
  • usernames 
  • passwords 
  • contact or authentication data 

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. 

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information that you provide voluntarily: 

  • information revealing race or ethnic origin 
  • data about a person’s sex life or sexual orientation 
  • student data 
  • health data 

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission: 

  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s calendar, camera, contacts, microphone, reminders, SMS messages, Bluetooth, sensors, notifications, and other features. If you wish to change our access or permissions, you may do so in your device’s settings. 
  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, system configuration information, device, and application identification numbers, browser type and version, hardware model, Internet service provider, and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed. 
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt-out of receiving these types of communications, you may turn them off in your device’s settings. 

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and our internal analytics and reporting purposes. 

 

Information automatically collected 

 

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services. 

 

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes. 

 

Like many businesses, we also collect information through cookies and similar technologies. 

 

The information we collect includes 

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages, and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings). 
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other devices you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information. 
  • Location Data. We collect location data, such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt-out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Services. 
  • User Contributions. 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 unauthorized persons will not view your User Contributions. 
  • The MentorHub Assessment. 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 flagged for further review if they are deemed harmful to either the mentor or mentee.  Chats not flagged for further review will be deleted after 12 months. 
  • Use of the “Mood Ring” or “Check-In” Feature. The “Mood Ring” or “Check-In” feature is a highly recommended feature of MentorHub that helps mentees to see their moods over time and helps mentors better connect with mentees. Although this feature is highly recommended, mentees have the option to choose not to use 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. The MentorHub App contains links or references to applications that third parties operate. This privacy policy does not apply to the practices of these other parties. We encourage you to read every app you download and its privacy policy. 
  1. HOW DO WE PROCESS YOUR INFORMATION?

 

In Short: We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent. 

 

We process your personal information for various reasons, depending on how you interact with our Services, including 

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. 
  • To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service. 
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. 
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information. 
  • To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services. 
  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user. 
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services. 
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. 
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them. 
  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm. 
  • The MentorHub Assessment. The MentorHub assessment is designed to help the program administrators better match mentors with mentees. 
  • Use of the “Mood Ring” or “Check-In” Feature. The “Mood Ring” or “Check-In” feature is a highly recommended feature of MentorHub that helps mentees to see their moods over time and helps mentors better connect with mentees. 

 

  1. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

 

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. 

 

If you are located in the EU or UK, this section applies to you. 

 

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information: 

  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. 
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you. 
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to: 
  • Analyze how our services are used so we can improve them to engage and retain users 
  • Diagnose problems and/or prevent fraudulent activities 
  • Understand how our users use our products and services so we can improve user experience 
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. 
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person. 

 

If you are located in Canada, this section applies to you. 

 

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. 

 

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: 

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way 
  • For investigations and fraud detection and prevention 
  • For business transactions provided certain conditions are met 
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim 
  • For identifying injured, ill, or deceased persons and communicating with next of kin 
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse 
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province 
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records 
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced 
  • If the collection is solely for journalistic, artistic, or literary purposes 
  • If the information is publicly available and is specified by the regulations 

 

  1. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

 

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties. 

 

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows: 

  • Cloud Computing Services 
  • Data Analytics Services 
  • Data Storage Service Providers 
  • Order Fulfillment Service Providers 
  • Product Engineering & Design Tools 
  • Performance Monitoring Tools 
  • Testing Tools 
  • User Account Registration & Authentication Services 
  • Website Hosting Service Providers 
  • Communication & Collaboration Tools 

 

We also may need to share your personal information in the following situations: 

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. 
  • Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data on our behalf about how you interact with our Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages, or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes. 
  • Mentors, Mentees, and Administrators. Information is shared between mentors or mentees with whom you are in a mentoring relationship and to the program and MentorHub administrators with responsibility for oversight of that relationship. 
  • Affiliated and independent third-party researchers. Information is shared with 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. 
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us. 
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions. 
  • Other Users. When you share personal information or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile. 
  • Terms and Conditions. We may share your information to enforce or apply our Terms and Conditions of Use and other agreements. 

 

  1. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

 

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services. 

 

Interaction with Third-Party Websites and Services. You can interact with third-party websites and services that you access through the MentorHub App. We will, from time to time, partner with third-party content providers as a part of the App. You may access a list of the current third-party content providers here. Third-party content will be accessed through the websites or applications maintained by third-party partners. We do not own or control these websites or services, and we assume no responsibility for the content, privacy policies, or practices of any third-party websites or services. We do not warrant the offerings of any of these third parties. Any information you provide to a third party when on its website or application or that is automatically collected by the third-party as a result of your use of its website or application is subject to the third party’s privacy policy. 

 

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. This privacy notice does not cover any data collected by third parties. We are not responsible for the content, privacy, security practices, or policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions. 

 

  1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

In Short: We may use cookies and other tracking technologies to collect and store your information. 

 

Cookies and similar technologies: We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services, visit http://www.aboutads.info/choices/. 

 

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example, to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may: 

  • Access your account settings and update your preferences. 

For more information on how we manage cookies. Please see our Cookie Policy.  Also, if you have questions or comments about your privacy rights, you may email us at info@mentorhub.org. 

 

 

  1. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

 

In Short: We may transfer, store, and process your information in countries other than your own. 

 

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in the United States, and other countries. 

 

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law. 

 

European Commission’s Standard Contractual Clauses: 

 

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request. 

 

  1. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. 

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us. 

 

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

 

  1. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In Short: We aim to protect your personal information through a system of organizational and technical security measures. 

 

We have implemented appropriate technical and organizational security 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 is 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. 

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App. 

 

  1. WHAT ARE YOUR PRIVACY RIGHTS?

 

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. 

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. 

  

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. 

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html. 

If you have questions or comments about your privacy rights, you may email us at info@mentorhub.org. 

 

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by emailing us at info@mentorhub.org or updating your account preferences. 

 

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. 

 

Account Information and Data Deletion Requests 

 

Mentohub accounts are created by the organizations who offer this tool to their users.  All accountis, including accounts used with the Menorhub mobile App are initiated and managed but the Program Administrator.  You can request data deletion at any time by contacting us by emailing us at info@mentorhub.org or updating your account preferences. 

 

If you would at any time like to review or change the information in your account or terminate your account, you can: 

  • Log in to your account settings and update your user account. 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. 

 

 

  1. CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice. 

 

  1. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

 

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. 

 

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. 

 

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.). 

 

CCPA Privacy Notice 

 

The California Code of Regulations defines a “resident” as: 

 

(1) every individual who is in the State of California for other than a temporary or transitory purpose and 

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose 

 

All other individuals are defined as “non-residents.” 

 

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information. 

 

What categories of personal information do we collect? 

 

We have collected the following categories of personal information in the past twelve (12) months: 

 

Category  Examples  Collected 
A. Identifiers  Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name   YES 

 

B. Personal information categories listed in the California Customer Records statute  Name, contact information, education, employment, employment history, and financial information   YES 

 

C. Protected classification characteristics under California or federal law  Gender and date of birth   YES 

 

D. Commercial information  Transaction information, purchase history, financial details, and payment information   NO 

 

E. Biometric information  Fingerprints and voiceprints   NO 

 

F. Internet or other similar network activity  Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements   NO 

 

G. Geolocation data  Device location   YES 

 

H. Audio, electronic, visual, thermal, olfactory, or similar information  Images and audio, video or call recordings created in connection with our business activities   NO 

 

I. Professional or employment-related information  Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us   NO 

 

J. Education Information  Student records and directory information   YES 

 

K. Inferences drawn from other personal information  Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics   NO 

 

 

We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of: 

  • Receiving help through our customer support channels; 
  • Participation in customer surveys or contests; and 
  • Facilitation in the delivery of our Services and to respond to your inquiries. 

How do we use and share your personal information? 

 

Supportive Accountability Hub, Inc. and Supportive Accountability Hub LLC collects and shares your personal information through: 

  • Targeting cookies/Marketing cookies 
  • Beacons/Pixels/Tags 

More information about our data collection, and sharing practices can be found in this privacy notice. 

 

You may contact us by email at  info@mentorhub.org or by referring to the contact details at the bottom of this document. 

 

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. 

 

Will your information be shared with anyone else? 

 

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf. 

 

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information. 

 

Supportive Accountability Hub, Inc. and Supportive Accountability Hub LLC have not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Supportive Accountability Hub, Inc. and Supportive Accountability Hub LLC have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months: 

  • Category A. Identifiers, such as contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name. 
  • Category B. Personal Information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information. 
  • Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth. 
  • Category J. Education information, such as student records and directory information. 

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”. 

 

Your rights with respect to your personal data 

 

Right to request deletion of the data — Request to delete 

 

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities. 

 

Right to be informed — Request to know 

 

Depending on the circumstances, you have a right to know: 

  • whether we collect and use your personal information; 
  • the categories of personal information that we collect; 
  • the purposes for which the collected personal information is used; 
  • whether we sell your personal information to third parties; 
  • the categories of personal information that we sold or disclosed for a business purpose; 
  • the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and 
  • the business or commercial purpose for collecting or selling personal information. 

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request. 

 

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights 

 

We will not discriminate against you if you exercise your privacy rights. 

 

Verification process 

 

Upon receiving your request, we will need to verify your identity to determine if you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. 

 

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you. 

 

Other privacy rights 

  • You may object to the processing of your personal information. 
  • You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information. 
  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA. 
  • You may request to opt-out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission. 

To exercise these rights, you can contact us by email at info@mentorhub.org or, by visiting https://mentorhub.org/contact-mentorhub/. If you have a complaint about how we handle your data, we would like to hear from you.  

 

  1. DO WE MAKE UPDATES TO THIS NOTICE?

 

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws. 

 

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to inform you how we protect your information. 

 

  1. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Debbie Reynolds, by email at dpo@debbiereynoldsconsulting.com. 

 

  1. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit https://mentorhub.org/contact-mentorhub/. 

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