MENTORBUDDIES, LLC

PRIVACY POLICY

EFFECTIVE SEPTEMBER 15, 2018

The purpose of this privacy policy (this “Policy”) is to provide individuals with a description of the types of personal information we at MentorBuddies, LLC (“we”, “us” or the “Company”), collect about individual persons through our services (the “Services”) and through our website www.mentorbuddies.com (the “Site”).

This Policy does not describe technical or other information collected or stored (such as product descriptions or specifications) which is not related to individual persons.  In addition to the provisions of this Privacy Policy, information we collect is also governed by the terms of the website terms of use and/or service agreement to which you agreed regarding your use of the Site and Services. This Site is intended to be used by mentors who will be providing lessons (“Mentors”), parents or guardians of students (“Students”) who will be receiving lessons (“Student Parents”), and others.

INFORMATION WE COLLECT

We collect personal information about you in various ways when you use our Site and Services.

• Information You Provide
  When creating an account, whether as a Mentor or as a Student Parent, or when requesting or receiving content, we may expressly ask you to provide us certain personal information.  For example:
  • We may collect personal information from you, such as your first and last name, email, address, phone number and gender, and your password when you create an account. If you are a Mentor (or prospective Mentor), we may also collect information about your age, skills, biographic information, the name and email address of your parent or guardian, and photos and videos of you (that you submit). If you are a Student Parent (or prospective Student Parent), we may also collect information about the names, genders and ages of your children. We may collect other information from time to time as well.
  • When you book lessons on our Site, if you are a Student Parent, we will collect all information necessary to complete the transaction, including your credit card information and billing information.
  • If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
  • We may also collect personal information at other points on our Site that state that personal information is being collected.
  • If you are a Mentor (or prospective Mentor), we may post on the Site certain of the information you provided in creating your profile, such as your first name, last initial, city or town and state of residence, skills, biographic information and any photos or videos you have uploaded in connection with your profile.
• Information Collected Via Technology
  We collect certain information automatically via various technological means.  For example:
  • Passive collection: information which is automatically collected, without your knowledge, while navigating through and interacting with the content on our Site and the content on each of our Site pages, as well as information on your device or computer (such as cookies).
    Our Site uses cookies to collect non-personal information including standard internet log information and details of your behavioral patterns upon visiting our Site pages. We do this to provide you with a better experience, identify preferences, diagnose technical problems, analyze trends and improve our Site.
    Cookies are small data files transferred onto computers or devices by websites for record-keeping purposes and to enhance functionality on the website.  We may also use cookies to record login details on your device or computer. This helps to determine whether a particular device previously visited our Site so that the login details would not have to be re-entered each time you visit our Site.
    Most browsers allow you to choose whether to accept cookies or not. If you do not wish to have cookies placed on your computer, please set your browser preferences to reject all cookies, before accessing the Site. Please note that by doing so some features of the Site you visit may be unavailable.
    To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
    The purpose of passively collecting your information is to improve your experience when using our clients' sites and web services. Through the tracking code, the information collected includes:
    The following information may be collected through your device and browser: your device's IP address (collected and stored in an anonymized format); device screen size; device type (unique device identifiers) and browser information; geographic location (country only); and preferred language used to display the webpage.
  • Log data
    Our servers automatically record information which is created upon using our Services or Site. Data includes: referring domain; pages visited; geographic location (country only); preferred language used to display the webpage; and date and time when Site pages were accessed;
  • Third Party Services
    We may use a variety of services which may be hosted by third parties, such as Google Analytics. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP request. For information on how Google Analytics collects and uses your information, please refer to its privacy policy. By using the Services, you consent to the processing of data by these third parties in accordance with their privacy policies.
• Do Not Track Signals
  Some web browsers may transmit “do not track” signals to our Site and the Services with which your web browser communicates. There is no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise our policy on responding to these signals.

USE OF PERSONAL INFORMATION

• General Use.
  In general, the personal information you submit to us is used either to respond to requests that you make, or to aid us in serving you better.  We use your personal information in the following ways:
  • Facilitate the creation of and secure your account for the purchase or provision of lessons;
  • Identify you as a user in our system, either as a Mentor or Student Parent;
  • If you are a Mentor under the age of 18, we may use the parent or guardian contact information you provide in order to obtain consent from your parent or guardian to your receipt of Services from the Company.
  • When you create an account, you may receive an email from us to verify ownership of the email address provided when your account was created;
  • We may use your email address information to provide you with administrative email notifications, such as booking status information and updates;
  • Provide introductions to Mentors or Student Parents;
  • Provide improved administration of our Site and Services;
  • Make payments to Mentors of brokerage fees owed;
  • Respond to your inquires and other requests;
  • Solicit feedback or reviews from Student Parents of Mentors;
  • For fraud protection and/or to verify your identity; and
  • Send newsletters, surveys, offers and other promotional materials related to our Services and for other marketing purposes.
• User Testimonials. We may receive ratings, testimonials or comments from users who have had positive experiences with a Mentor.  We may publish such content.  When we publish this content, we may identify the providers of such feedback by their first and last name and may also indicate their home city.  We obtain the feedback provider’s consent prior to posting his or her name along with the testimonial.
• Creation of Anonymous Data.  We may create anonymous information records from your specifications and any personal information we collect by excluding information (such as your name) that makes the information personally identifiable to you.  We may use this anonymous information to analyze request and usage patterns so that we may enhance the content of our Site and improve our Services, including our pricing algorithms. We reserve the right to use anonymous information for any purpose and disclose anonymous information to third parties at our sole discretion.

DISCLOSURE OF INFORMATION

We disclose your personal information as described below and as described elsewhere in this Privacy Policy.

• Third Party Service Providers.  We may share your personal information with third party service providers to: provide you with the Services; to conduct quality assurance testing; to facilitate the creation of accounts; to provide technical support; and/or to provide other services to you.
• Authorize.net.  Payment processing services for our Services are provided by Authorize.net and are subject to the Authorize.net terms of service and privacy terms.  You authorize us to share with Authorize.net transaction information related to your use of the payment processing services provided by Authorize.net.

We do not otherwise share personally identifiable information to third parties who are not affiliates or service providers of the Company, except as described here. We may disclose personally identifiable information to appropriate affiliates of the Company, including strategic alliance affiliates and third party service providers, to respond to a request for service or to provide information about available products or services. We are not limited in our use of non-personal information that does not permit direct association with any specific individual, or non-identifiable aggregate information about our users (such as the number of users of our Services, the geographic distribution of our Mentors or Students, etc.).

We disclose information that we, in good faith, believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our service agreement or terms of services for our Site. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity’s contact information to victims who request it. In addition, we reserve the right to disclose aggregate information and personally identifiable information to third parties as required or permitted by law and when we believe that disclosure is necessary to protect our rights.

We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process (“Legal Request”), including Legal Requests from private parties in a civil action, and in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If the Legal Request seeks information about an identified user or limited group of users, we’ll make reasonable business efforts to contact the user(s) before providing information to the party that requests it. We cannot guarantee that we will be able to contact the user(s) in all cases, whether because of a time limit, court order, inability to effectively contact a user, or for any other reason. We may disclose information to an individual’s agent or legal representative (such as the holder of a power of attorney that an individual grants, or a guardian appointed for an individual). 

We share information with companies that provide public relations and marketing services for us. Such information will only be shared by us to customize, measure and improve our products, services and advertising; it will not be shared with third parties for their marketing purposes. These third parties are obligated to protect information under equivalent terms to this Policy and are prohibited from using personally identifiable information for any other purpose.

As with any other business, it is possible that in the future we could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by us, including customer account information, but would continue to be bound by this Policy unless and until it is amended.

We may share information with any parent, subsidiaries and joint ventures to help coordinate the Services we provide, enforce our terms and conditions, and promote trust and safety. We may share aggregate truly anonymized (non-personally identifiable) information with certain third parties such as advertisers, national industry organizations, and prospective affiliates.

DATA SECURITY 

We follow commercially accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. While we strive to use commercially acceptable means to protect personal information, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee its absolute security. In the event of an inadvertent disclosure of personal information we will take all commercially reasonable steps to limit and remedy the disclosure as required by the applicable law. If individuals have any questions about security regarding our Service, they can contact us at info@mentorbuddies.com.

COMMUNICATIONS WITH YOU; RIGHT OF OPT-OUT, ACCESS AND CORRECTION

We may periodically send you free newsletters and emails that directly promote the use of our Site or Services.  We also may, from time to time, contact you on behalf of third-party businesses about a particular offering that may be of interest to you.  In those cases, we do not transfer your unique personal information to the third party. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information below). Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our service agreement, terms of use or Privacy Policy.

You can correct or update your personally identifiable information by re-registering or by contacting us by email at info@mentorbuddies.com. 

CALIFORNIA PRIVACY RIGHTS. 

California Civil Code Section 1798.83 permits customers who are California residents and who have provided the Company with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident with questions regarding this, please contact us at info@mentorbuddies.com.

PRIVACY AND THIRD-PARTY LINKS

This Privacy Policy applies solely to information collected by our Site and Services.  In an attempt to provide you with increased value, we may include third-party links on our Site.  These linked sites have separate and independent privacy policies, and we do not have control over and do not review these linked sites.  We therefore have no responsibility or liability for the content and activities of these linked sites.  Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these linked sites (including if a specific link does not work).

GOVERNING LAW

This Policy is governed by the laws of the Commonwealth of Massachusetts, U.S.A. without giving effect to any principles of conflict of law.

AGE LIMITATION 

The Site is intended to be used for introductions between Mentors who are at least 14 years of age to parents or guardians of younger Students. Persons under the age of 18 are not permitted to be Mentors for the Company unless their parent or guardian has provided written consent. Persons under the age of 18 are not permitted to register to contact a Mentor or receive lessons, and all lessons must be coordinated through the parent or guardian of the student who has registered with the Site. If you become aware that a person under the age of 18 has provided us with personal information without the written consent of their parent or guardian, please contact us at info@mentorbuddies.com. If we become aware that a person under 18 has provided us with personal information without the written consent of their parent or guardian, we take steps to remove such information and terminate the person’s account.

EFFECTIVE DATE; POLICY CHANGES 

This Policy is subject to occasional revision, and if we make any material changes in the way we use your personal data, we may notify you by sending you an email to the last email address you provided to us and/or by prominently posting notice of the changes on our Site. 

If you have registered as an account holder, or order products or services through us, we may (as a part of any transaction relating to your account or order) require you to explicitly accept the material changes as a condition to the continued provision of the Services to you. 

Please note that at all times you are responsible for updating your personal data to provide us with your most current email address.  In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our email to you containing such notice will nonetheless constitute effective notice of the changes described in the notice.  If you do not wish to permit changes in our use of your personal data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us.  Continued use of our Site or Services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

CONTACT US

To contact us with your questions or comments regarding this Policy or the information collection and dissemination practices of the Services, please email us at info@mentorbuddies.com. All trademarks, service marks, and other proprietary materials herein are the property of the Company or its affiliates. All rights reserved.