Effective: April 7, 2018
This Privacy Policy describes how Mentornity collects, uses and discloses information, and what choices you have with respect to the information.
We have worked to make the Privacy Policy clearer and more understandable by:
When we refer to “Mentornity”, we mean the Mentornity entity that acts as the controller or processor of your information, as explained in more detail in the “Data Protection Regulations” section below.
Welcome to Mentornity. We are a mentoring, coaching and consultancy program management platform dedicated to unite the program organisers and participants. Through our platform, mobile apps and services, we enable people to create, discover and participate mentoring programs all over the world. Users can communicate with each other, set meetings or events and share experience through the services we provide.
Mentornity's products, features and offerings are available (a) online through various Mentornity properties including without limitation, Mentornity ("Site(s)"); (b) off platform, including without limitation, entry management, sponsorship and marketing or distribution services; and (c) through mobile applications, webpages, application programming interfaces, and subdomains ("Applications"). (a), (b) and (c) are collectively referred to as "Mentornity Properties" or our "Services".
When this Privacy Policy uses the term "Organiser" we mean mentoring, coaching and consultancy program ("Organisation") creator who uses our Services to consume information about programs and program participants, or for any other reason. The term "Member" indicates the participant of the Organisations created by Organiser, who may join to the Organisation via invitation, application or any other way. Organisers, Members and third parties using the Services are all referred to in these Terms collectively as "Users", "Customers", "you" and "your".
Mentornity A.Ş. is an İstanbul corporation with its principal place of business at Reşitpaşa Mah, Katar Cad. İTÜ Teknokent, Arı 3, B2, 34467 İstanbul, Türkiye. ("Mentornity", "us", "we", or "our"). If you are resident in the US, EEA, Switzerland or Turkey, Mentornity A.Ş. is the responsible party with respect to Personal Data (defined below) collected through our Services.
If you have any questions or concerns at any time, please do not hesitate to contact us at the address above or by contacting us at privacy@mentornity.com.
This Privacy Policy sets forth our policy with respect to information that can be associated with or which relates to a person and/or could be used to identify a person ("Personal Data") that is collected from Users on or through the Services.
"Non-Personal Data" as used in this Privacy Policy is therefore any information that does not relate to a person and/or cannot be used to identify a person. When you interact with the Services, we may collect Non-Personal Data. The limitations and requirements in this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Data do not apply to Non-Personal Data.
This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Mentornity platform (“Third Party Services”), or any other third party products, services or businesses.
If you do not agree with the terms, do not access or use the Services, Site(s), Applications or any other aspect of Mentornity’s business.
When you use or interact with us through the Services, we may collect Personal Data. Sometimes this will be on our own behalf and other times this will be on behalf of an Organiser using our Services. This is an important distinction for EU and Turkey data protection law purposes and is explained in more detail in Section Data Protection Regulations.
Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to the Services, such as when you register for access to the Services, contact us with inquiries, respond to one of our surveys or browse or use certain parts of the Services. The Personal Data we may collect includes without limitation your name, address, email address and other information that enables Users to be personally identified.
As an Organiser, we will collect additional Personal Data from you.
Information you provide to us:
In addition to information you provide to us, Customers that purchase a paid version of the Services provide Mentornity (or its payment processors) with billing details such as credit card information, banking information and/or a billing address. If you use our payment processing services, we will collect financial information from you (e.g., your bank account information or an address to send checks) as necessary to facilitate payments and information required for tax purposes (e.g., your taxpayer identification number).
Information we obtain from other sources:
We may also collect or receive Personal Data from third party sources, such as third party websites, your bank, our payment processing partners and credit reporting agencies.
As a Member we will collect additional Personal Data from you, sometimes for our own purposes and other times on behalf of an Organiser (see Section Data Protection Regulations for more information).
Information you provide via Mentornity Properties or Applications:
If you register a paid event or meeting, you will provide financial information (e.g., your credit card number and expiration date, billing address, etc.) some of which may constitute Personal Data.
In addition, Organisers can set up organisation application forms for letting users apply to Organisations, feedback forms to get information from you before and after the meetings or events, or surveys to collect virtually any information from Members. Organisers may also collect additional Personal Data about Members. Mentornity does not control an Organiser's application/registration process nor the Personal Data that they additionally collect. Personal Data collected on behalf of Organisers is provided to the Organiser in accordance with How We Disclose and Transfer Your Personal Data.
If, as a Member, you use our payment processing services, (e.g., organising paid events or meetings) we will collect financial information from you (e.g., your bank account information or an address to send checks) as necessary to facilitate payments and information required for tax purposes (e.g., your taxpayer identification number).
Information we obtain from other sources:
We may also collect or receive Personal Data from third party sources, such as Organisers, other Customers, social media or other third party integrations, your credit card issuing bank, our payment processing partners or other third parties.
Mentornity also collects, generates and/or receives Other Information:
To create and update an Organisation, or to join an Organisation, you or Organisers supply Mentornity with first name, last name, email address, phone number, password, domain and/or similar account details.
Mentornity uses cookies and similar technologies in our Applications and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Applications and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie Policy.
User can choose to permit or restrict Third Party Services. Typically, Third Party Services are software that integrate with our Services, and User can enable and disable these integrations. Once enabled, the provider of a Third Party Service may share certain information with Mentornity. For example, if a cloud storage application is enabled to permit files to be imported, we may receive user name and email address of User, along with additional information that the application has elected to make available to Mentornity to facilitate the integration. Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to Mentornity. When a Third Party Service is enabled, Mentornity is authorized to connect and access Other Information made available to Mentornity in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services.
Mentornity may receive data about Organisations, Application visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
We receive Other Information when submitted to our Applications or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Mentornity.
Generally, no one is under a statutory or contractual obligation to provide any Personal Data. However, certain Personal Data is collected automatically and, if some Personal Data, such as Organisation setup details, is not provided, we may be unable to provide the Services.
We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy. We may use the Personal Data as follows:
If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyze your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.
We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business.
Where it is in accordance with your marketing preferences, we may use your Personal Data to contact you in the future for our marketing and advertising purposes, including without limitation, to inform you about services or events we believe might be of interest to you, to develop promotional or marketing materials and provide those materials to you, and to display content and advertising on or off the Services that we believe might be of interest to you.
The System sends emails to the Users to notify them about an action that relates them. You can enable or disable these emails and notifications in Notification Settings
We allow Organisers to use our email tools to contact or send announcement to Members, so you may receive emails from our system that originate with such Organisers and that we send on their behalf. If you participated to an Organisation on the Services, your email address is available to that Organiser. The Organiser and not Mentornity is responsible for sending these emails. You can enable or disable these emails and notifications in Notification Settings
We may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
We may need to use Personal Data to investigate and prevent security issues and abuse.
To serve our Users better, we often conduct research on our customer demographics, interests and behavior based on Personal Data and other information that we collect. This research is typically conducted on an aggregate basis only that does not identify you. Once Personal Data is in an aggregated form, for purposes of this Privacy Policy, it becomes Non-Personal Data.
We will not sell your Personal Data to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth below.
Mentornity will share and disclose Personal Data in accordance with a Customer's instructions in compliance with applicable law and legal process.
When you become Member and join to Organisation, or to participate any event or meeting at Organisation, we provide the Personal Data you entered to the Organiser. Organiser may, but need not, allow Organisation Members to view other Members' Personal Data.
When a User submits Personal Data, it may be displayed to other Users, or anonymous users. For example, User’s Personal Data may be shared anonymously when Organisation sets visibility of its Members public.
### 5.4 Collaborating With Members.
The Services provide different ways for Users collaborate, send/receive messages, set meetings. Personal Data, such as a User’s profile Information, may be shared, subject to the policies and practices of the other Organisations.
We may share your Personal Data with our contractors and service providers who process Personal Data on behalf of Mentornity to perform certain business-related functions. These companies include database service providers, backup and disaster recovery service providers, email service providers, logging service providers and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions.
You can connect your Mentornity account to your accounts on third party services like Facebook, Google, Twitter, LinkedIn and on services that Mentornity partners to provide Single Sign On (SSO). Mentornity retrieve and store your ids on the connected platforms, first name, last name email and image url. In addition to these, we may collect some other information based on the third party service. For example, if you connect with LinkedIn, we store your contact list and skills.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of Mentornity (or its assets) will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy.
We may also share your Personal Data with our parent companies, subsidiaries and/or affiliates for purposes consistent with this Privacy Policy. Our parent companies, subsidiaries and affiliates will be bound to maintain that Personal Data in accordance with this Privacy Policy.
We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to comply with a legal obligation, protect or defend our rights, interests or property or that of third parties, prevent or investigate possible wrongdoing in connection with the Services, act in urgent circumstances to protect the personal safety of Users of the Services or the public, or protect against legal liability.
We may store Personal Data itself or such information may be stored by third parties to whom we have transferred it in accordance with this Privacy Policy. We take what we believe to be reasonable steps to protect the Personal Data collected via the Services from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration and destruction. However, no network, server, database or Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any Personal Data.
We may retain your Personal Data as long as you are registered to use the Services. You may close your account by contacting us. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
To the extent prohibited by applicable law, Mentornity does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.
Mentornity may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. In certain circumstances Mentornity may, but need not, provide you with additional notice of such changes, such as via email or with in-Service notifications.
Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was updated on the date indicated above. Your continued use of the Services following the effectiveness of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing and otherwise using the Services.
Mentornity may transfer your Personal Data to countries other than the one in which you live, to distribute our Services and make the Service fast and available at any location globally. We deploy the General Data Protection Regulation (GDPR) for European Union and Switzerland, Kişisel Verilerin Korunması Kanunu (KVKK) for Turkey if Mentornity transfers Personal Data originating from these countries to other countries not deemed adequate under applicable data protection law.
EEA, Switzerland and UK Only
The EU General Data Protection Regulation (GDPR)
In May 2018, a new data privacy law known as the EU General Data Protection Regulation (or the "GDPR") becomes effective. The GDPR requires Mentornity and Organisers using the Service to provide Users with more information about the processing of their Personal Data.
Turkey Only
The Kişisel Verilerin Korunması Kanunu (KVKK)
In April 2018, a new data privacy law known as the Kişisel Verilerin Korunması Kanunu (or the "KVKK") becomes effective. The KVKK requires Mentornity and Organisers using the Service to provide Users with more information about the processing of their Personal Data.
Here is what you need to know for GDPR and KVKK:
Legal grounds for processing your Personal Data
The GDPR and KVKK requires us to tell you about the legal ground we're relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out in Section How We Use Your Personal Data above will typically be because:
Transfers of Personal Data
As Mentornity is a global company, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the EEA, Switzerland, the UK and Turkey which have no data protection laws or laws that are less strict compared with those in Europe and Turkey.
Whenever we transfer Personal Data outside of the EEA, Switzerland, the UK or Turkey, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data.
Personal Data retention
We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.
If you have an account with us, we will typically retain your Personal Data for a period of 90 days after you have requested that your account is closed or if it's been inactive for 7 years.
Your rights
Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications.
For the most part, you can exercise these rights by logging in and visiting the Account Settings page or changing the "cookie settings" in your browser (see our Cookie Statement for more information). If you can't find what you're looking for in the Account Settings page, please contact us using the contact information set out in Section Dispute Resolution and Contact. Please note that requests to exercise data protection rights will be assessed by us on a case-by-case basis. There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation.
If you have a complaint about how we handle your Personal Data, please get in touch with us as set forth in Section Dispute Resolution and Contact to explain. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.
Mentornity as a data controller and a data processor
EU and Turkey data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as "data controllers") and organizations that process personal data on behalf of other organizations (known as "data processors"). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.
Mentornity may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances.
For example, if you create an account with us to organize your mentoring/coaching/consultancy program, Mentornity will be a data controller in respect of the Personal Data that you provide as part of your account. We will also be a data controller of the Personal Data that we have obtained about the use of the Applications or Mentornity Properties, which could relate to Organisers or Customers. We use this to conduct research and analysis to help better understand and serve Users of the Services as well as to improve our platform and provide you with more targeted recommendations about events we think may be of interest to you.
However, if you register for an Organisation as a Member, we will process your Personal Data to help administer that Organisation on behalf of the Organiser (for example, sending confirmation, notification and feedback emails, processing payments, etc.) and to help the Organiser target, and understand the success of, their program (for example, providing event/meeting reports, using analytics to gain insights into the effectiveness of various marketing channels, etc.). In these circumstances, Mentornity merely provides the "tools" for Organisers; Mentornity does not decide what Personal Data to request on registration forms, nor is it responsible for the continued accuracy any Personal Data provided. Any questions that you may have relating to your Personal Data and your rights under data protection law should therefore be directed to the Organiser as the data controller, not to Mentornity.
To communicate with our Data Protection Officer, please email to dpo@mentornity.com.
If you have a complaint about Mentornity's privacy practices you should write to us at:
Mentornity A.Ş. Attn: Privacy Officer, Reşitpaşa Mah, Katar Cad. İTÜ Teknokent, Arı 3, B2, 34467 İstanbul, Türkiye or by email. We will take reasonable steps to work with you to attempt to resolve your complaint.