Privacy Policy

Last Updated: July 21, 2023

This Privacy Policy describes the processing of personal information by MentorcliQ (“Company,” “our,” “we,” or “us”) that is collected, used, and disclosed via MentorcliQ’s online mentoring platform (the “Platform”), our mobile app, which is available via the App Store and Google Play as MentorcliQ (the “Mobile App”), and our website located at https://mentorcliq.com (the “Website”) (collectively, “the Services”), as well as our offline practices.

MentorcliQ acts as a controller with respect to the personal information we collect via the Website and offline, and a processor with respect to the personal information we collect via the Platform and Mobile App.

Personal Information We Collect

Website and Offline

The categories of personal information we may collect via the Website and offline include contact details (such as name, phone number, address, email addresses), social media information (such as information located on your LinkedIn profile), device identifiers (such as a MAC address, IDFA, or GAID), job title, job function and history, company, location, and any information you voluntarily contribute to the MentorcliQ Help Center forums, which may include professional interest or activities.

Platform and Mobile App

The categories of personal information we may collect via the Platform and Mobile App include contact details (such as name and work email address), Professional Information (such as job title and job function), your mentoring preferences, responses to a short personality questionnaire, profile picture, demographic data, and your progress in and satisfaction with the program(s) via responses to short surveys.

We may create inferences about you from the information we collect and collect information about your gender, race, ethnicity, and your progress in the program through your responses to optional progress, personality, and satisfaction surveys.

Sources of Personal Information

We collect personal information from the following sources:

• Directly from you when you provide information;
• Automatically when you access or use the Services;
• From your employer;
• From service providers who help us to run our business;
• From third parties such as social media websites;
• From public sources such as government databases; and
• Otherwise in the course of our business.

How We Use Information We Collect About You

Personal information we collect about you is used for the purposes set out in this Privacy Policy. It is not used or disclosed for any other purpose without your consent unless otherwise permitted by law. We do not sell your personal information and have not done so in the 12 months immediately preceding the effective date of this Privacy Policy. We strive to ensure that personal information is accurate, complete, and current. To aid in this process we encourage all MentorcliQ users to update their information whenever necessary by accessing the account settings or emailing us at privacy@MentorcliQ.com.

Website and Offline

MentorcliQ may use the personal information we collect about you via the Website and offline for several purposes including to:

• communicate with you;
• ensure the performance of our Website;
• oversee our vendor and customer relationships;
• transfer or sell any of our assets or operations to another party or for related due diligence;
• improve our Website, including determining your level of engagement with the Website;
• address or monitor security concerns, including the prevention, detection, mitigation, and investigation of fraud, security breaches, or other potentially prohibited or illegal activities and/or attempts to interfere with the Website or to harm others;
• comply with governmental regulations or to respond to a subpoena, court order, regulatory investigation, law enforcement request, or other valid legal process;
• monitor for violations of and enforce our Subscription Agreement, Terms of Use, this Privacy Policy, or other policies or applicable laws; or
• fulfill any other purpose permitted by applicable law and communicated to you at the time of personal information collection.

Platform and Mobile App

MentorcliQ may use the personal information we collect about you via the Platform and Mobile App for several purposes including to:

• allow you to participate in MentorcliQ mentoring;
• personalize your mentoring experience, including creating accounts and remembering preferences;
• track your feedback, progress, and satisfaction throughout the program;
• manage our business operations, including ensuring the performance of our Platform and Mobile App;
• oversee our vendor and customer relationships;
• transfer or sell any of our assets or operations to another party or for related due diligence;
• improve our Platform and Mobile App;
• address or monitor security concerns, including the prevention, detection, mitigation, and investigation of fraud, security breaches, or other potentially prohibited or illegal activities and/or attempts to interfere with the Platform and Mobile App or to harm others;
• comply with governmental regulations or to respond to a subpoena, court order, regulatory investigation, law enforcement request, or other valid legal process;
• monitor for violations of and enforce our Subscription Agreement, Terms of Use, this Privacy Policy, or other policies or applicable laws; or
• fulfill any other purpose permitted by applicable law and communicated to you at the time of personal information collection.

MentorcliQ may provide archival copies of information to its clients following the completion of a project. These archival copies may contain personal information about you, which was submitted to the Platform and Mobile App (either by you or by MentorcliQ’s client) during that project. Any use of that archival copy is subject to the client’s privacy practices and policies. MentorcliQ has no control over the client archival copy following completion of a client project.

How We Disclose Information We Collect About You

For users providing information via our Website, we may use your personal information to send you information about our products and services and those of related companies, which may be of interest to you.

We may also disclose information we collect about you as follows:

• any personal information supplied to MentorcliQ or any of its subsidiaries may be shared within the internal company group to facilitate our business activities and provision of services;
• with vendors who help us to run our business or perform business functions and services on our behalf, including in connection with the use or operation of the Platform and Mobile App (such functions may include hosting servers and providing legal, accounting, or other support services);
• as reasonably required by law, including in the prosecution or defense of legal proceedings;
• with another party in the context of a business transaction, such as an acquisition or sale or as part of the related due diligence process; and
• at your direction, with your consent (where legally required), or as otherwise permitted by law.

Where MentorcliQ makes personal information available to vendors who perform business functions and services on its behalf, the vendors will be under appropriate contractual obligations to protect the personal information.

Cookies and Tracking Technologies

We and our vendors may use cookies and other tracking technologies to collect and store information about your interactions with the Services. Information collected from these cookies and tracking technologies may include device identifier(s), IP address, pages visited and content selected, and the length and time of your use of the Services. We may link information we store within the Platform to personal information you submit within the Mobile App.

Cookies are small text files that a website stores on your device that can capture and recall certain information to enable the recognition of your device and your preferences. The information captured by cookies may be provided to us or our vendors. In general, we use cookies:

• to run and optimize the functionality of our Website;
• for analytics about our Services;
• for marketing and personalizing ads on our Website and elsewhere on the internet; and
• to determine if our email messages have been opened and acted upon.

If you do not want to have cookies placed on your device, you may be able to disable cookies and other tracking technologies using your browser settings. Please review your browser’s instructions, or visit www.allaboutcookies.org for general information.

Analytics. We use analytics tools, including Hotjar and Google Analytics, to understand how you interact with our Services. These tools may collect information such as your IP address, operating system, access time, duration of visit, and actions you take while navigating the Services. When you use our Mobile App we may also collect your device model and version, device identifier, OS version, and your MentorcliQ access credentials. You may opt-out of having your website activity made available to Google Analytics by installing the Google Analytics browser add-on, available here.

Session Monitoring. Some of the technologies used on our Website allow us and our vendors to monitor and analyze how visitors use our Website in order to better understand user behavior and improve our Website. When you interact with us online, information related to your browsing behavior may be collected by us and our vendors.

Online Advertising. Our website collects information about you in order to target advertisements to you when you browse the internet or use social media. The primary tool we use for this purpose is Google Ads, which is an advertising service provided by Google. Google uses cookies and other identifiers, in combination with their own data, to show you ads based on your usage of our Website. You can personalize the ads you receive or opt out of ads from Google by visiting the Google Ads Settings page. Additional options for opting out of interest-based advertising can be found here. We do not use data from your use of the Platform or the Mobile App for targeted advertising.

Do Not Track Signals. Our Website does not respond to “Do Not Track” signals sent by browsers, mobile devices, or other mechanisms.

Links to Other Sites

Our Services may provide links to other websites or online services for your convenience and information. These sites operate independently of MentorcliQ and have their own privacy practices.  MentorcliQ encourages you to review the policies available on any other website you visit. MentorcliQ is not responsible for the conduct of those businesses.

Children’s Privacy

Our Services are for a general audience and are not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and learn we have collected or received personal information from your child under 16 without your consent, please contact us at privacy@MentorcliQ.com to ask that we delete the information.

Security of Your Personal Information

We take reasonable technical, organizational, and administrative measures to protect personal information collected through the Services against unauthorized or unlawful processing and against accidental loss, destruction, or damage. However, because transmission via the Internet and online digital storage is not completely secure, we cannot guarantee the security of any information we may have collected from or about you through the Services.

For the purposes of accessing some areas of the MentorcliQ website and to use the Platform or Mobile App, you may be supplied with a user name and password.  You are responsible for the security and confidentiality of your password and login information.

How Long We Keep Personal Information?

The time period that MentorcliQ keeps personal information varies according to what the information is used for (for example, for the life of the engagement and until returned to the client). In general, we aim to keep your personal information for no longer than is necessary to achieve the purposes for which the personal information was collected, or as may otherwise be permitted or required under applicable law. To determine the appropriate retention period, we will consider the amount and sensitivity of the personal information; the potential risk of harm from unauthorized access to, use, or disclosure of the personal information; the purposes for which we process the personal information; whether we can achieve our purposes through other means; our business needs; your expectations; and applicable legal requirements.

California’s Shine the Light Law

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Privacy Office, or via email at privacy@MentorcliQ.com. We will respond to one request per California customer each year, and we do not respond to requests made by means other than as set forth above.

Notice to Our International Visitors

MentorcliQ is based in the United States. If you are using our Services outside the United States, please be aware that the personal information you provide to us is being sent to and otherwise processed in the United States, European Union, and/or other jurisdictions outside your own. By continuing to use our Services and providing your personal information, you acknowledge that your personal information may be transferred to and processed in jurisdictions other than your own. Please be aware that the data protection laws and regulations that may apply to your personal information transferred to the United States or other countries are likely different from the laws in your home country.

When MentorcliQ transfers your personal information to another party for processing, MentorcliQ will ensure that appropriate transfer mechanisms, such as the standard contractual clauses, are in place to safeguard your personal information when required. If you have any questions about the protections we use when transferring personal information, you may contact us by email at privacy@MentorcliQ.com.

Visitors from the European Economic Area and United Kingdom

We recognize the privacy rights of people from the European Economic Area and United Kingdom who use our services. In addition to the information we provide throughout this privacy policy, the following rights and supplemental disclosures are applicable to you.

Legal Basis and Processing Purposes

We rely on the following legal bases for processing the personal information of people from the European Economic Area and United Kingdom.

• Contractual Necessity – Processing personal information is necessary to provide you with the mentoring services you and/or your employer have requested and ensure they are satisfactory. We require certain personal information to be able to provide mentoring services to you.
• Our Legitimate Interests – We process personal information to achieve our legitimate interests of providing, improving, and personalizing the experiences of users of our Services. We also process personal information to help ensure the security and integrity of our Services. When we rely on our legitimate interests, we take into account the effects that these actions might have on you. If you have questions about our decisions regarding our legitimate interests, you may contact us by email at privacy@MentorcliQ.com.
• Our Legal Obligations – We may be required to process personal information to meet our legal or regulatory obligations.
• Your Consent – We may ask for your consent for certain personal information processing. For example, we may rely on consent to use non-essential cookies, to provide you with marketing communications, or if we need to collect sensitive personal information from you. When you consent, you may withdraw your consent at any time by contacting us by email at privacy@MentorcliQ.com.

Rights and Choices

People in the European Economic Area and United Kingdom have the right to access personal information maintained about them and to impose certain limits on the use and disclosure of such personal information. You may ask us to take the following actions in relation to your personal information that we maintain:

• provide you with information about our processing of your personal information and give you access to your personal information;
• update or correct inaccuracies in your personal information;
• delete your personal information;
• transfer a machine-readable copy of your personal information to you or a third party of your choice;
• restrict the processing of your personal information on our Website;
• object to our processing of your personal information for direct marketing purposes on our Website; and/or
• object to our reliance on our legitimate interests as the basis for processing of your personal information on our Website.

You can submit these requests by emailing privacy@MentorcliQ.com. We may request specific information from you to help us confirm your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

You also have the right to lodge a complaint with a supervisory authority. Learn more about how to contact your supervisory authority in the European Economic Area and in the United Kingdom.

Privacy Shield Notice for Visitors from the European Economic Area and Switzerland

MentorcliQ, Inc. complies with the EU-U.S. Data Privacy program Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy program Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  MentorcliQ, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework program Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.  MentorcliQ, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. Please note that we may be required to share personal information in response to lawful requests by public authorities including to meet national security and law enforcement requirements.

In compliance with the EU-US Data Privacy Framework Principles, MentorcliQ, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles.  Swiss individuals with DPF inquiries or complaints should first contact privacy@mentorcliq.com.

MentorcliQ, Inc. has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers  for more information and to file a complaint. This service is provided free of charge to you.

If your  DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

Policy Changes

MentorcliQ may modify or supplement this Privacy Policy from time to time, in which case we will post the updated Privacy Policy here and change the “last updated” date at the top of this page. MentorcliQ encourages you to review the MentorcliQ Privacy Policy periodically.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at privacy@MentorcliQ.com or write to us at:

Privacy Officer
MentorcliQ, Inc.
445 N High Street 3^rd Floor
Columbus, OH 43215
United States