Privacy Policy

Purpose

MentorcliQ (also referred to as the “Company”, “our”, “we”, or “us”) provides mentoring services to our clients and their employees through various software resources. We recognize the importance of privacy and are committed to protecting the privacy of registered users (“users”) of our online mentoring platform (“the Platform “), clients, shareholders, and suppliers. This Privacy Policy applies to all sources of Personal Information (defined below) and describes how we may use and disclose Personal Information that we may collect in the course of our business.

Please read this Privacy Policy carefully before using our website located at https://mentorcliq.com (the “Website”); our mobile app, which is available via the App Store and Google Play as MentorcliQ (the “Mobile App”); the Platform; or otherwise in the course of business (our Website, App, and Platform are collectively referring to in this Privacy Policy as our “Sites” for convenience) as this Privacy Policy governs your access to and use of our Sites. Our Sites are only available for your use on the condition that you agree to this Privacy Policy and our Subscription Agreement or Terms of Use. If you do not agree to this Privacy Policy and/or our Subscription Agreement or Terms of Use, do not access or use the Sites. By accessing or using any of the Sites, however, you and the entity you are representing signify your agreement and consent to be bound by this Privacy Policy and our Subscription Agreement or Terms of Use.

Personal Information collected by MentorcliQ will be stored through electronic systems located in various jurisdictions. Please note the jurisdictions to which Personal Information may be transferred may not provide the equivalent level of data protection to the laws in your home country. This does not however change MentorcliQ’s commitment to keeping Personal Information secure.

Contact Us

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

Privacy Officer
MentorcliQ, Inc.
595 S. Third St., 2nd Floor
Columbus, OH 43215

Information We Collect and How We Collect It

MentorcliQ collects Personal Information as permitted by applicable law through:

• the MentorcliQ Website;
• the Platform;
• the Mobile App; and
• otherwise in the course of its business.

Wherever possible, we collect information directly from the individual to whom the information relates. This includes, when you apply for a job, make an inquiry, arrange for a demonstration of our services, request a training or otherwise interact with the Sites. Personal Information may also be collected in the course of our business (such as from third parties or via HRIS integrations with our Clients).

The categories of Personal Information we may collect include contact details (such as name, phone number, address, email addresses), social media information (such as information located on your Linkedin profile), job title, job function and history, company, location, as well as any information contributed to the MentorcliQ Help Center forums which may include professional interest or activities. We may also collect, should you choose to provide it, information regarding your gender, race, or ethnicity, and your progress in the program via your responses to progress and satisfaction surveys.

MentorcliQ Website

If you want to apply for a job, make an inquiry, arrange a demonstration of our services, or to request training through our Website, you will provide us Personal Information in order to do so.

Our Website may at times be accessed anonymously. Many companies offer programs that help you to visit web sites anonymously; however, we will not be able to provide you with a personalized experience if we cannot recognize you, we want you to be aware that these programs are available.

The Platform and Mobile App

To register as a user on the Platform or Mobile App, you will be asked to provide us Personal Information, which may include your name and email address. Personal Information about you may also be entered on the Platform or Mobile App by your employer or prospective employer’s administrator, in order for you to use the Platform.

The MentorcliQ Mobile App may use mobile analytics software to allow us to better understand the functionality on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. In addition, when you use our Mobile App we may also collect your device model and version, device identifier (or “UDID”), OS version, and your MentorcliQ access credentials. MentorcliQ may occasionally send push notifications to provide you resources, reminders, etc. as part of the mentoring process.

We may link information we store within the Platform to Personal Information you submit within the Mobile App. We do this to improve services we offer you, including your experience, and to keep your mentoring profile up-to-date.

The legal basis for the associated processing of your data is Art. 6(1)(b) GDPR (performance of contract) respectively Art. 6(1)(a) GDPR (your consent).

Our Help Center Forums

If you want to contribute to the MentorcliQ Help Center forums, you may be required to register using an email address and username.

If you or your organization are required under the European Union’s General Data Protection Regulation (GDPR) to enter into a contract, or other binding legal act under EU or Member State law, with your data processors, our Data Processing Agreement is available here and upon request at privacy@MentorcliQ.com.

Cookies

The MentorcliQ Website and the Platform use MentorcliQ’s first party and third party cookies to track online activities in accordance with applicable law.

A cookie is a small file that is placed on the user’s hard drive during a visit to the Website or the Platform. This file allows the user to move quickly and easily around the Website and to enter the Platform. It is used to identify a user and tracks a user’s session, providing information that the system uses to efficiently manage your use of the website and the Platform.

Your web browser may be set to accept cookies automatically but can be changed to decline them. Please note that if you decline to accept cookies, this may mean you may not be able to take full advantage of the Website or the Platform.

MentorcliQ may also work with third party advertising and personalization partners that use cookies to help us display personalized content and web advertisements across the Internet based on someone’s past visits to the MentorcliQ website. Cookies placed by our third party partners also assist us with measuring the performance of our advertising campaigns. You can decide whether or not to accept cookies through your internet browser’s settings.

How We Use Information We Collect About You

Personal Information we collect about you is used only for the purposes set out in this Privacy Policy. It is not used or disclosed for any other purpose without consent or as otherwise authorized by law. We do not sell, rent, or lease your Personal Information and have not done so in the 12 months immediately proceeding the effective date of this Privacy Policy. We strive to ensure that this Personal Information is accurate, complete and current. To aid in this process we encourage users to update their information on our Website, the Platform and the Mobile App as frequently as necessary.

MentorcliQ uses your Personal Information for a variety of purposes including the following, to:

• Deliver our services
• Set up an account for your and/or your business/employer
• Comply with our internal record-keeping needs
• Process any application for employment you have made to MentorcliQ
• Provide the information, products or services you requested, and provide information concerning those products or services
• Provide you with information in connection with our other products or services or our related companies
• Identify your product and service preferences
• Customize our communications to you
• Share positive product testimonials with others
• Obtain information and/or place orders for products or services from suppliers
• Transfer or sale of any of the assets and/or operations of MentorcliQ to another party or in due diligence process in line with a potential transfer or sale
• Fulfill any other purpose for which you provide it or that was provided to us
• Personalize your experience in using our Sites
• Present the Sites and the contents of our Sites to you
• Communicate with you about your employment application, demonstration request, contract, inquiry, and any other reason you have chosen to engage with us via the Sites
• Determine your level of engagement with the Sites
• Improve our services
• Address or monitor security concerns including in the prevention, detection, mitigation, and investigation or fraud, security breaches, or other potentially prohibited or illegal activities and/or attempts to interfere with the Sites or to harm others
• Monitor and improve the information security of our Sites and services
• Comply with governmental regulations or to respond to a subpoena or other governmental, court, administrative, Member State, Supervisory Authority or other legal requirement
• Hire, train and/or manage our staff/employees
• Support the functions of our human resource management, including the coordination of third-party vendors that provide insurance and personal financial services such as retirement planning and savings and investments accounts
• Enforce our Subscription Agreement or Terms of Use, this Privacy Policy or other policies, and to monitor for violations of our policies or applicable laws
• Combine with information e receive from other sources for the purposes set out in this Privacy Policy
• Any other purpose communicated to you at the time of collecting the Personal Information and if required by law for which consent has been obtained

If you do not provide requested information, MentorcliQ may not be able to provide you with the service or information or process your request. Upon the completion of a client project, MentorcliQ may provide archival copies of information in connection with a project to that client, which may contain Personal Information relating to you, which has been submitted to the Platform and Mobile App (either by you or by MentorcliQ’s client). MentorcliQ bears no responsibility for any use by that client of the archival copy following MentorcliQ providing it upon completion of a client project.

How We Disclose Information We Collect About You

For users providing information via our Website, we may, from time to time, 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 contact you from time to time on an ongoing basis by email or other address or contact point, which we have collected or obtained in order to provide such information as allowed by applicable law. If you receive promotional information from MentorcliQ and do not wish to receive this information any longer, you may remove your name from our list by “Unsubscribing”, but following any other instructions provided in the communication or contacting MentorcliQ at privacy@MentorcliQ.com and asking to be removed from our mailing list or follow the instructions in any marketing communication you receive.

We do not market to users of our Platform or Mobile App and the above section applies only to users of our Website.

We may also share or otherwise disclosure information we collect about you as follows, to:

• Any Personal Information supplied to MentorcliQ or any of its subsidiaries may (as permitted by and in accordance with applicable law) may be shared within the internal company group to facilitate our business activities and provision of services.
• Third parties
• At your direction or with your consent;
• To 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, providing legal, accounting or other support services);
• As required or permitted by law, including in the prosecution or defense of legal proceedings;
• In the context of a business transaction, such as an acquisition or sale as part of the due diligence process; and
• Where MentorcliQ does make information or data available to certain third parties to perform business functions and services on behalf of MentorcliQ, all such parties will be under a contractual obligation to maintain the security and confidentiality of the Personal Information and to process the data in accordance with MentorcliQ’s instructions.

Also, users in the EU/EEA may object to processing for marketing purposes at any time. If an EEA user does object, we will stop processing Personal Information for marketing purposes, but will still process for other purposes, e.g., the performance of a contract or other legitimate interest unless otherwise properly objected to. For users in the EEA, if you have any questions or concerns about the our Privacy Policy for our services or their implementation, or if you would like to opt out from our sharing of your Personal Information with unaffiliated third parties for the third parties’ direct marketing purposes you may contact us at privacy@MentorcliQ.com and request that we opt you out of such sharing. We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.

California residents may have additional Personal Information rights and choices. Please see Your California Privacy Rights for more information.

We do not market to users of our Platform or Mobile App and the above section applies only to users of our Public Website.

Security of your information

MentorcliQ maintains physical, electronic and administrative safeguards to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Notwithstanding these security measures, we CANNOT AND DO NOT GUARANTEE THE SECURITY OR CONFIDENTIALITY OF THE INFORMATION COLLECTED. No transmission over the Internet can be 100% secure and although MentorcliQ will take all reasonable steps to protect information in storage, MentorcliQ cannot be responsible for the security of any information transmitted over the Internet.

Children’s Privacy

Our Sites and services are not intended for children under 13 (16 in the EEA). No one under age 13 (16 in the EEA) may provide any information to or on the Online Services. We do not knowingly collect Personal Information from children under 13 (16 in the EEA). If you are parent or guardian and learn we have collected or received Personal Information from a child under 13 (16 in the EEA) without verification of parental consent, please contact us at privacy@MentorcliQ.com and we will delete that information.

Platform and Mobile App

Please note that in using the Platform and Mobile App, users may be communicating with individuals and organizations outside of their home country. In that case, their use of Personal Information may not be covered by the law applicable in their home country or applicable privacy protection scheme.

Passwords

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.

Changing your information

You have the right to access the Personal Information we hold about you for the purposes of correcting, updating or deleting by making a request to MentorcliQ at privacy@MentorcliQ.com. We will provide you with access unless we are legally authorized not to do so.

If at any time you wish to change Personal Information that is inaccurate or out of date, please contact us by emailing to MentorcliQ at privacy@MentorcliQ.com. If you wish to have your Personal Information deleted, please let us know in the same manner.

Users of the Platform may, alternatively, click on the “Privacy” link within the Platform and request changes, a copy of, or deletion of your data.

We will take all reasonable steps to change or delete information in response to such a request. If there is a reason that we cannot make that change or deletion, we will inform you of that reason.

Links to other sites

MentorcliQ may provide links to other websites. These sites operate independently of MentorcliQ and have established their own privacy and security policies. MentorcliQ encourages you to review these policies at any site you visit. MentorcliQ is not responsible for the conduct of those businesses.

How long we keep personal information?

The time period for which MentorcliQ keeps information varies according to what the information is used for (e.g., for the life of the engagement and until returned to the client). In some cases there are legal requirements to keep information for a minimum period and, on the other hand, to delete information after a certain period of time. Unless there is a specific legal requirement for MentorcliQ to keep the information, MentorcliQ will keep for so long as it is necessary for the purpose for which it was collected or for such other purposes for which consent has been obtained or MentorcliQ is otherwise permitted or authorized by law to use the Personal Information.

EU/EEA Data Subject Rights – International Data Transfers

We operate the Sites, in whole or in part, in the United States. By using any of the Sites, you agree to have your Personal Information stored, processed, and transferred in the United States, and to allow us to use and collect your information in accordance with this Privacy Policy and pursuant to the laws and regulations that apply in the United States. To the extent we collect and use Personal Information about persons you are outside the United States, this is for the purpose of exercising our legitimate interests and does not represent an effort by us to monitor such person’s behavior, to contact such persons without their consent, or to create a permanent legal establishment of MentorcliQ outside the United States. MentorcliQ does not intend to send unauthorized commercial electronic messages to persons resident in Canada or other countries; if a Canadian or other non-U.S. resident receives a communication from MentorcliQ and considers it inappropriate on this basis, please contact so that we can stop any further communications.

To the extent the Personal Information is collected from EU/EEA residents, it may be transferred to, stored, and processed in the United States and other countries outside the European Economic Area (“EEA”) that do not have the same data protection laws as your jurisdiction. In making any such transfer of EU/EEA resident data outside the EU/EEA, we will only do so in compliance with EU law, such as by including data processing agreements based on the EU Standard Contractual Clauses and, in the case of transfers to the U.S., MentorcliQ’s self-certification to the EU-U.S., and Swiss-U.S. Privacy Shield. Such Personal Information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.

If you access the Online Services from the EEA you may be eligible for certain rights under the GDPR.

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, each to access information is available to those whose information is collected about them in the EEA, including:

• Finding out if we use your Personal Information, accessing your Personal Information and receiving copies of your Personal Information;
• Withdrawing any express consent that you have provided to the processing of your Personal Information at any time without penalty;
• Accessing your Personal Information and having it corrected or amended if it is inaccurate or incomplete;
• Obtaining a transferable copy of some of your Personal Information which can be transferred to another provider when the personal data was processed based on your consent;
• If you believe your Personal Information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Information, you also have the right to request that we restrict the processing of your Personal Information pending our investigation and/or verification of your claim;
• Request your Personal Information be deleted or restricted under certain circumstances. For example, if we are using your Personal Information on the basis of your consent and have no other legal basis to use such, you may request your Personal Information be deleted when you withdraw your consent.

If we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. When the processing of your Personal Information is for direct marketing purposes, you have the right to object to such processing though we may continue to process your Personal Information for other reasons where we have consent or a legitimate interest.

You have the right to withdraw your consent to our collection and/or processing of your Personal Information any time by contacting us. You may seek a copy, correct, amend, transfer, rectify or delete your Personal Information by us at any time for any purposes. Please contact us at privacy@MentorcliQ.com.

You have the right to complain to a data protection authority about our collection and use of your Personal Information.

To exercise any of your rights as described above, please contact us as indicated so that we may consider your request under applicable law. Please be aware that your request will not be accepted for review unless you provide the following:

• The name, user ID, pseudonym, email address, or other identifier that you have used to use our Online Service if you are not a registered user of the service, or have not otherwise previously interacted with us, your first and last name and an address where we can correspond with you;
• State, Country, Providence or jurisdiction that you are located;
• Clear description of the information or content you wish to receive or to be deleted or corrected, or the action you wish to be taken; and
• Sufficient information to allow us to locate the content or information to be deleted, removed or corrected.

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request.

We will try to comply with your request as soon as reasonably practicable. However, we reserve the right to refuse to act on a request that is manifestly unfounded or excessive (for example because it is repetitive).

California Privacy Rights

Shine the Light

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.

California Consumer Privacy Act (CCPA)

As of January 1, 2020, if you are a California resident, you may request a copy of your Information. You may also request that we delete or amend all or part of your Personal Information We do not sell, rent or lease your Personal Information so there is no right to do not sell. To submit a verified request, please contact us at privacy@MentorcliQ.com and title the subject of your email “California Privacy Rights Request”. In response, we will request information from you to verify your identity.

Your Right to Know About the Personal Information We Collect About You

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device, collectively, your Personal Information. The Section above titled “Information We Collect and How We Collect It” sets forth the categories of Personal Information that we collect and process about you, a description of each category, and the source of how we obtain each category.

Your Rights and Choices

Under California Laws, California residents can exercise three privacy rights (Disclosure and Access; Deletion; and “Do Not Sell My Personal Information”) (collectively, “Rights”); however, based on the information we gather, and the fact that we do not “sell” Personal Information as that term is defined in the CCPA, your rights are somewhat limited as these Rights are not absolute and are subject to certain exceptions. For instance, we are not required to respond to requests concerning employment/application data, B2B data, and cannot disclose or permit access to specific pieces of Personal Information if the disclosure or access would present a certain level of risk to the security of the Personal Information, your account with us, or the security of the business’s systems of networks. If you are a California consumer, we will process your request to exercise your Rights in accordance with California Laws.

A record concerning the requests may be maintained pursuant to our legal obligations. Further, we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.

Disclosure and Access Requests

You have the right to request that we disclose to you, for the 12-month period immediately preceding the date of your request, the categories of Personal Information and the specific pieces of Personal Information we collect about you. Please note additionally that we are only required to fulfil a Disclosure request from a consumer twice per every 12-month period. If you submit a request in excess, it may be denied or you may be charged for fulfilling your request.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Given the type of Personal Information we collect, for requests to delete Personal Information collected, we will have the requestor provide at least two pieces of information so that we may verify the requestor’s identity to a reasonable degree of certainty. We are required to retain the requests to delete for a period of 12 months as part of our record-keeping obligations.

If we are unable to verify a request, to the extent possible, that request will be treated as a request to opt-out and afforded rights associated with that request right as described in more detail below.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. A deletion request may be denied, in full or in part as allowed by law.

Exercising Disclosure and Deletion Rights

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Request Made Through Agents

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, verify the agent’s identity, and we may need you to verify your identity directly with us. (The verification requirement does not apply if the consumer has provided the authorized agent with legal power of attorney under California Probate Code Sections 400 to 4465.)

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Dispute Resolution

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to MentorcliQ’s Privacy Officer (privacy@MentorcliQ.com). MentorcliQ will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information by reference to the principles contained in this Policy.

MentorcliQ complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and Switzerland to the United States, respectively. MentorcliQ has certified that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit: https://www.privacyshield.gov.

In compliance with the EU-US Privacy Shield Principles, MentorcliQ commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact MentorcliQ at: privacy@MentorcliQ.com

MentorcliQ has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Under certain limited conditions an EU individual may invoke “last resort” binding arbitration before the Privacy Shield Panel. MentorcliQ may be required to disclose an individual’s in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. MentorcliQ has potential liability in cases of onward transfers of Privacy Shield data to third parties. The United States Federal Trade Commission (FTC) is the enforcement authority with jurisdiction over this compliance with the Privacy Shield.

Policy changes

If MentorcliQ’s information practices change, MentorcliQ will post these changes on the website – www.MentorcliQ.com. MentorcliQ encourages you to review the MentorcliQ Privacy Policy periodically.

If we change material terms of this Privacy Policy, we will provide notice of the revised policy for 30 days on the MentorcliQ website. We will also take other steps as necessary depending on the nature of the changes, including obtaining your consent where required by local data protection laws or providing you with the opportunity to delete your Personal Information.

This Privacy Policy is effective as of May 11th, 2018 and was last updated on September 5th, 2021.