Privacy Policy

INTRODUCTION


This privacy policy (“Privacy Policy”) describes the information collection practices that The Mentor Method, Inc. (“Company,” “we,” “us,” or “our,” if not explicitly referring to one company) follow when handling Personal Information (defined below) that we collect or receive in conducting our business, including through our products, services, content, websites, and user applications (the “Sites”), as further explained below.

 

THIS SITE IS NOT INTENDED FOR USE BY RESIDENTS OF THE EUROPEAN UNION.

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information. If you do not agree to this Privacy Policy, your choice is to not use our Sites.

Throughout this Privacy Policy, we use the term “Personal Information” to mean any information relating to an identified individual, or to an individual who can be identified, directly or indirectly, by reference to such information. For clarity, information that is anonymized in such a way that the data subject is not or is no longer identifiable is not Personal Information.

INFORMATION WE COLLECT FROM OR ABOUT YOU

 

Personal Information You Provide To Us. We collect Personal Information that you provide to us through our Sites, and in connection with other business dealings we may have with you. Such information may include:

  • First and last name

  • Email address

  • IP address

  • Login user name and password

  • Telephone number

  •  Location

Usage Information We Collect.

 

In addition to Personal Information that you choose to submit to us, whenever you visit or interact with our Sites, we may collect or store information about your interaction with our Sites and Services (“Usage Information”). This Usage Information may include:

  • your IP address or any other unique identifier assigned to the device that you use to access our Sites

  • your username

  • browser window titles

  • the functionality and characteristics of your device, including type of browser, operating system and hardware, mobile network information, and in some cases location information

  • the URL that referred you to our Sites, if any

  • your activities on our Sites, such as which web pages you visit, what terms you searched within our Sites, and which links within our Sites that you click on

  • the time of day that you visited our Sites and how long your visit lasted

 

Information We Receive From Third Parties.

 

We may receive Personal Information about you from third parties who recommend or suggest that we contact you for business purposes. This includes basic contact information about you, such as your name, company name, title, address, phone number, fax number, and email address. It may also include information on the content, products, or services you have shown interest in or may be interested in purchasing from us, as well as information on other companies or individuals with whom you do business. We may also obtain Personal Information about you from third parties in connection with business transactions you initiate with us, such as through credit verification or other processes related to the transaction. Finally, if you interact with a third party service when using our Sites, such as if you use a third party service to log-in to our Sites (e.g., Facebook Connect, Google Sign-In, or Twitter OAuth), or if you share content from our Sites through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. All Personal Information received from third parties will be treated in accordance with this Privacy Policy.

  • ANALYTIC TECHNOLOGIES

    We use certain common methods and technologies to collect and store Usage Information about your interaction with our Sites (“Analytic Technologies”). These Analytic Technologies may be downloaded to the personal computer, laptop, tablet, or mobile phone that you use to access the Sites (“Your Device”). The specific Analytic Technologies that we use are as follows:

     

    • Cookies. A cookie is a data file placed on Your Device when you visit our Sites. We use cookies only to facilitate the use and navigation of our Sites and to remember you and your preferences in case you revisit our Sites in the future and to conduct range measurement. Many browsers allow blocking of cookies in their entirety, removal of existing cookies, or warning to prevent the placing of a cookie. Please note that blocking of cookies might impede your use of our Sites.

       

    • Web Beacons. A web beacon, including tracking pixels, is a small graphic image or other web programming code, also known as “1×1 GIF” or “clear GIF.” We may download web beacons to Your Device when you access our Sites or through email messages that we send to you. Web beacons are used to improve your experience on our Sites. Web beacons also help us to understand whether users read email messages and click on the links contained within those messages so that we can deliver relevant content and messages. Our web beacons may collect certain of your contact information (e.g., the email address associated with an email message that contains a web beacon).

      Embedded Scripts. An embedded script is a programming code that is designed to collect information about your interactions with our Sites, such as which links within our Sites you click on, which type of browser or device you use (e.g. mobile or desktop version). We use such information to enhance the user experience. This code is downloaded onto Your Device when you access our Sites and is deactivated or deleted when you leave our Sites. Identification of the user does not take place.

       

    • Analytics. We may use analytics applications, such as “Google Analytics”, to collect information about use of our Sites. These applications collect information such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to coming to a website.

 

We use the information obtained from these applications only to improve our Sites and our product and service offerings. The information generated about your use of our Sites will be transferred and saved to the vendor’s server in the United States. Google’s ability to use and share information collected by Google Analytics about your visits to the Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can opt-out of Google Analytics tracking by visiting https://tools.google.com/dlpage/gaoptout/.

 

Do Not Track Policy.

 

Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Sites. Just like any other Usage Information we collect, this information allows us to improve the Sites and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Sites do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Sites and after you leave our Sites.

 

 

HOW WE USE YOUR INFORMATION

Business Use.

 

We use your Personal Information primarily to facilitate our ongoing and proposed business dealings with you (“Business Use”). This includes to: (1) process business transactions with us that you initiate, including without limitation orders of products and services and the creation of user profiles; (2) establish and maintain customer accounts so that we may provide products or services of ours requested by you or your company; (3) register you as a user of these services so that you may access them through our Sites or otherwise; (4) communicate with you about updates, maintenance, outages, or other technical matters concerning these products or services; (5) notify you about changes to any of the policies and procedures for use of these products or services; (6) verify the accuracy of account and technical contact information we have on file for you and your company in relation to these products or services; (7) respond to questions or inquiries that you or your company may have about our products or services. We also may use your Personal Information as required for us to comply with laws and regulations relating to the products or services that we provide in any of the jurisdictions in which we or our affiliated companies operate, including the United States; and (10) we may use Usage Information internally within The Mentor Method, Inc. to help us improve our services, or to develop new services.

We may also use your Personal Information to personalize the content of the Sites and communications based on your preferences, and to comply with our legal or contractual obligations and to resolve disputes. Additionally, we may use your Personal Information to protect against or deter fraudulent, illegal, or harmful actions and to enforce our terms and conditions of use (depending on which product or service you are using).

Marketing Purposes. With your consent or as otherwise permitted by applicable law, we may use your Personal Information for purposes relating to the marketing of our content, products, and services, or those of our business partners (“Marketing Purposes”).

 

This includes to: (1) send you newsletters, press releases, event announcements, and other similar communications regarding the products or services that we offer; (2) market or promote our services to you, including by offering you trial or limited access to certain of our services; (3) either directly or through third-party services, solicit input from you regarding improvement of our services, including but not limited to, beta programs, product ratings and reviews, and interviews; (4) inform you of third-party offerings that we think you or your company may be interested in which relate to our products or services; (5) send you announcements or requests on behalf of other customers of ours who believe you would benefit from use of our products or services; and (6) other purposes that we disclose to you at the time we obtain your consent.

Referrals.

 

From time to time, we may receive Personal Information about you from third parties who recommend or suggest that we contact you for business purposes. We receive such Personal Information because you have consented towards the third party that they might share your Personal Information. If we use that information to contact you, it will only be to see if you are interested in our products or services, or those of our business partners. We will not use this information for other purposes without your consent. In addition, if you inform us that you are not interested in these products or services, we will stop using the information to contact you.

Data Integrity.

 

You are responsible for the accuracy of all Personal Information that you provide to us. We will use reasonable efforts to maintain the accuracy and integrity of your Personal Information, and to update that information as appropriate. We will take reasonable steps to ensure that the Personal Information we collect from you is relevant to its intended use, and that it is used only in ways that are compatible with the purposes for which it was collected or otherwise authorized by you.

Automated Decision Making.

 

We do not use any personal data provided by you for the purpose of automated decision-making.

 

 

RETENTION OF PERSONAL INFORMATION

 

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).


When we have no ongoing legitimate business need to retain your Personal Information, we will either delete or anonymize it 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.

 

 

WITH WHOM WE MAY SHARE INFORMATION

 

Within COMPANY.

 

The Mentor Method, Inc. is a company that transacts business across national borders. Accordingly, from time-to-time and subject to the provisions of this Privacy Policy governing “CHOICE AND UPDATING YOUR INFORMATION AND PREFERENCES” (see below), we may share your Personal Information within the Company (i.e., between and among The Mentor Method, Inc. and its subsidiaries). Such information may be used by each Company entity for internal business and operational purposes, as well as for purposes consistent with the purpose for which the information was originally collected or subsequently authorized by you.

Outside of Company.

 

We may share your Personal Information with “Data Processors” as described below, and with other third parties for purposes disclosed to you at the time you provided the information, or as subsequently authorized by you. From time to time, we also may offer you the option of sharing your Personal Information with third parties in order to receive information and/or marketing offers from them or other persons. If you consent to the sharing of your Personal Information for these purposes, it will be subject to the privacy policies and business practices of those third parties. If you

later decide that you no longer want us to share Personal Information with such third parties, please contact us as indicated below under the section “CHOICE AND UPDATING YOUR INFORMATION AND PREFERENCES.” We will process your request in a reasonable period of time. Note, however, that if you no longer wish to receive communications from a third party which has already received your Personal Information from us, you will need to contact that third party directly to inform them of this.

Data Processors.

 

We may, from time to time, employ Data Processors to perform services on our behalf, such as: (1) hosting our Sites, products, and other applications; (2) designing and/or operating certain features available through our Sites; (3) sending emails and other communications relating to our products or services; (4) fulfilling and processing orders for our products or services; (5) assisting with promotions and conferences relating to our products or services, or those of our business partners; (6) providing analytic services, such as in relation to the tracking of usage of our Sites; or (7) performing other administrative services for us. We may provide these Data Processors with access to your Personal Information in order for them to complete a requested transaction or otherwise perform services for us or for you on our behalf. To the extent permitted under applicable law, prior to allowing our Data Processors to access your Personal Information, we will enter into a data protection agreement or addendum (“DPA”) with them to ensure that they handle and process the information in accordance with this Privacy Policy and applicable law as instructed by us.

Site Hosting.

 

Our Sites and the servers on which they are hosted may be operated in various countries around the world in which we conduct our business. Thus, your Personal Information associated with our Sites may be transferred to and/or processed in a country other than that from which it was collected. The data protection laws in those countries may differ from those of the country in which you are located. The servers may be operated by third party hosted service providers. If you are a resident of the EU, any such transfers will be made in accordance with applicable laws.

Links to Other Websites and Applications.

 

The Sites may contain various links to, as well as plug-ins or widgets from, social media and other third-party websites or applications, which may provide additional information, goods, services, and/or promotions. These third-party websites or applications are owned and operated independently of the Company, and may have their own separate privacy and data collection practices. We are not responsible for the privacy practices of any third party; therefore, you should review their privacy policies and practices prior to interacting with their websites or applications, using any of their tools, or sharing any of your Personal Information with them.

Community Forums.

 

Our Sites may offer message boards, chat rooms, blogs, and other public areas (“Community Forums”) where you can interact with our employees, other customers, post images, data, requests, questions, comments, suggestions, or other content, including your Personal Information (“User Submissions”). To participate in Community Forums, you may be asked to select a user name and password and/or provide us with your email-address, and to agree to the terms of participation for those Community Forums. We use this information to identify you and to contact you, if needed, for the provision of those Community Forums. You are able to change your email preferences or discontinue your participation in the Community Forums at any time. Your password and your email-address will not be visible to other users or shared with third parties. You should be aware that any User Submissions you post to a Community Forum, as well as your user name, may be viewed by other members of that forum. If you choose to voluntarily post User Submissions to a Community Forum, be aware that such information is viewable by anyone else on that Community Forum. Think carefully before you post and use caution before disclosing any Personal Information in a Community Forum.

 

We are not responsible for the accuracy, use, or misuse of any User Submission that you disclose or receive through a Community Forum. We might also delete User Submissions without further notice if they include harmful or inappropriate content (e.g., pornographic material, content encouraging vandalism, crime, terrorism, racism, violence, or cruelty), or infringe any third party’s rights or applicable law.

Promotions.

 

We may offer various promotions (“Promotions”) through the Sites or elsewhere that may require registration with your Personal Information. If you choose to enter or otherwise participate in a Promotion, your Personal Information may be disclosed to third parties in connection with administration of the Promotion, such as in connection with winner selection, prize fulfillment, and as otherwise required by law. By entering into a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice, and/or likeness in advertising or marketing materials. These rules will be displayed to you during the registration process, and you will be asked for your consent to the respective data processing at that time.

Affiliates and Business Transfers.

 

We may share your Personal Information with our affiliates. Additionally, the Company or any part of its business, including our Sites, may be sold at some point in the future. Should this occur, your Personal Information may be transferred to a subsequent owner, co- owner, or operator of the business unit or Sites. We also may disclose and transfer your Personal Information in connection with a corporate merger, consolidation, restructuring, the sale of stock or assets, or other corporate change, including, without limitation, during the course of any due diligence process. In all such cases, this Privacy Policy will continue to govern the use and disclosure of such information.

Legal Protections and Law Enforcement.

 

We may access, use, preserve, transfer, and disclose to third parties your Personal Information to: (1) satisfy any applicable law, regulation, subpoena, governmental request, or legal process if, in our good faith opinion, such is required or permitted by law; (2) protect and/or defend this Privacy Policy or other policies or terms of use applicable to our Sites, including investigations of potential violations thereof; (3) protect the safety, rights, property, or security of the Company or any third party; and/or (4) detect, prevent, or otherwise address fraud, security issues or breaches, or technical issues. This may include allowing third parties, such as copyright owners, Internet service providers, wireless service providers, and/or law enforcement agencies, to access and use your Usage Information in order to identify you. We may take any of these steps without notice to you to the extent permitted by law.

CHOICE AND UPDATING YOUR INFORMATION AND PREFERENCES


We reserve the right to take reasonable steps to authenticate the identity of any individual seeking access to Personal Information. We may provide web pages or other mechanisms on our Sites through which you can update subscription preferences. You can also contact us to update your Personal Information or change your preferences. Our contact information for these purposes is by email at marketing@thementormethod.com. If you receive a marketing communication from us by email, you may also opt out of receiving future email marketing communications by following the opt-out instructions provided in that email. Please note that we reserve the right to send you certain communications relating to transactions you initiate, your customer account, your use of our Sites, or other business matters, and that these communications may be unaffected if you choose to opt-out from marketing communications.

In accordance with our routine record keeping and applicable law, we may delete certain records that contain your Personal Information. We are under no obligation to store such information indefinitely, and we disclaim any liability arising out of, or related to, the destruction of that information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. Also, if you have posted any User Submissions to a Community Forum, these communications cannot generally be removed.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at marketing@thementormethod.com.

INFORMATION SECURITY


We will take reasonable precautions to protect your Personal Information in our possession from loss, misuse, and unauthorized access, disclosure, alteration or destruction. We will make reasonable efforts to keep your Personal Information reliable for its intended use, accurate, current and complete. As necessary, we will take additional precautions regarding the security of particularly sensitive information, such as credit card information. While we strive to secure your Personal Information, we cannot warrant or guarantee that this information will be protected under all circumstances, including those beyond our reasonable control.

ENFORCEMENT


We encourage you to raise any questions or concerns that you may have about the way we process your Personal Information by contacting us at the address set forth below.


We commit to resolve questions and complaints about your privacy and our collection or processing of Personal Information about you. If you believe that we are not complying with the terms of this Privacy Policy or other legal requirements, you should first contact us by email
at marketing@thementormethod.com. We will investigate and will do our best to internally resolve any complaints and disputes you bring to our attention regarding the use and disclosure of your Personal Information.

CHILDREN


The Sites are intended for business use. We do not knowingly collect or solicit Personal Information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Sites or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us Personal Information, please contact us at marketing@thementormethod.com.

CALIFORNIA RESIDENTS RIGHTS

California enacted the CCPA in 2018, and it is effective as of January 1, 2020. The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information” (as defined under the CCPA). If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.

   

Terms used in this section have the meaning ascribed to them in the CCPA. ADD COMPANY is a “business.” For purposes of California residents only, Personal Information includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or a household. It does not include de-identified information, aggregate consumer information, or publicly available information, as those terms are defined in the CCPA.

Our Collection and Use of Personal Information. In the preceding 12 months, we may have collected from or about you all of the categories of Personal Information listed in “INFORMATION WE COLLECT ABOUT YOU”. We may collect Personal Information from all or some of the categories of sources listed in “INFORMATION WE COLLECT ABOUT YOU”. We may collect or use Personal Information for the business or commercial purposes listed above in “HOW WE USE YOUR INFORMATION”.

Our Disclosure and Sharing of Personal Information. We may disclose your Personal Information to our service providers or other entities that have agreed to limitations on the use of your Personal Information or that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA or other applicable laws.

We also sell Personal Information within the meaning of the CCPA, including the Personal Information of minors under 16 years of age.

California Residents’ Rights Under the CCPA If your Personal Information is subject to the CCPA, you may have certain rights with regard to such Personal Information, including the right to:

  • Right to Notice. Be informed, at or before the point of collection, of the categories of Personal Information to be collected and the purposes for which the categories of Personal Information shall be used.

  • Right to Request to Delete. Request that we delete any Personal Information about you that we have collected or maintained, subject to certain exceptions. We reserve the right to retain, and not to delete, certain Personal Information after receipt of a Request to Delete from you where permitted by the CCPA or where another law or regulation is applicable. We may retain your Personal Information if doing so is necessary for us or our service providers to, for example:

    • Comply with a legal obligation.

    • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

    • Complete a transaction for which we collect the Personal Information, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.

    • Use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the Personal Information.

  • Right to Request to Know. Request that we, as a business that collects Personal Information about you and that sells and discloses for a business purpose Personal Information, disclose to you:

    • The categories of Personal Information we have collected about you.

    • The categories of sources from which we collected the Personal Information.

    • The business or commercial purpose for collecting or selling the Personal Information.

    • The categories of third parties with whom we share Personal Information.

    • The specific pieces of Personal Information we have collected about you.

    • The categories of Personal Information about you we have sold or disclosed for a business purpose.

  • Right Not to Be Discriminated Against. Not be discriminated against because you exercised any of your rights under the CCPA.

  •  Right to Request Opt-Out of Sale. Request that we, as a business that sells Personal Information, not sell your Personal Information. The Company does not Sell your Personal Information under CCPA.

 

The CCPA does not restrict the Company’s ability to do certain things like comply with other laws or comply with regulatory investigations. The Company also reserves the right to retain, and not to delete, certain Personal Information after receipt of a request to delete where permitted by the CCPA.

 

How to Submit a Request to Know or to Delete Under the CCPA. If your Personal Information is subject to the CCPA, you may submit a Request to Know and/or a Request to Delete, as described above, by calling the following telephone number +1 971-206-4703, or by sending an email to marketing@thementormethod.com.

 

The Company is required to provide certain information or to delete Personal information only in response to verifiable requests made by a California Resident or their legally authorized agent. We may need to request specific information from you or your agent to help us confirm your identify or your agent’s authorization to act on your behalf and ensure your right to access the requested information. Any information gathered as part of the verification process will be used for verification purposes only.

 

If an authorized agent seeks to submit a Request to Know or a Request to Delete on behalf of a California Resident, the authorized agent may do so by the aforementioned methods, however, they must provide: (i) signed authorization from the California Resident authorizing them to act on the California Resident’s behalf, unless they can provide proof that the California Resident has granted them power of attorney pursuant to California Probate Code sections 4000 to 4465; and (ii) proof of their registration with the California Secretary of State to conduct business in California. We also require that the California Resident directly verify their own identity with us and directly confirm with us that they provided the authorized agent permission to submit the request.

We will deliver responses to verifiable consumer requests free of charge either through your online account with us, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election.

 

 

NEVADA RESIDENT RIGHTS

Nevada law gives Nevada residents the right to opt-out of the “sale” of certain Personal Information, provided certain requirements are met. Terms used in this section shall have the meaning ascribed to them in the Nevada Privacy Law. For purposes of this section only and with regard to Nevada residents only:

  • Personal Information means any one or more of the following items of personally identifiable information about a consumer collected by an operator through an Internet website or online service and maintained by the operator in an accessible form: (i) first and last name; (ii) home or other physical address which includes the name of a street and the name of a city or town; (iii) electronic mail address; (iv) telephone number; (v) social security number; (vi) identifier that allows a specific person to be contacted either physically or online; or (vii) any other information concerning a person collected from the person through the Internet website or online service of ADD COMPANY and maintained by ADD COMPANY in combination with an identifier in a form that makes the information personally identifiable.

  • “Sale” means the exchange of covered information for monetary consideration by the operator to a person for the person to license or sell the covered information to additional persons.

The Company does not sell Personal Information of Nevada Residents under the Nevada Privacy Law.

CHANGES TO THE PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time, without prior notice to you, to the extent permitted by applicable law. Any changes that we make to this Privacy Policy will be effective immediately upon our posting the revised Privacy Policy on the Sites.

Last updated on November 16, 2021.