Effective Date: May 25, 2018
1. About this document
- If you have questions or concerns regarding this statement, you should contact our staff firstname.lastname@example.org.
2. MicroMentor’s Privacy Principles
- MicroMentor operates as a non-profit, social impact organization. We are powered by volunteer mentors who care deeply, a community based on mutual trust, and the belief that a better world is possible.
- We will never sell or rent your data to third parties.
- Your profile information is public.
- Other information that you provide to MicroMentor is confidential.
- Your conversations with others in the MicroMentor community are confidential. It is also your responsibility to help us keep it that way.
- General information about your activity on the site helps us to do our job.
- We only share data with trusted partners in order to: improve our service, to measure our impact, and identify misuse, and to respond to your requests.
- If you join MicroMentor through your employer or other organization, some information about your activity will be shared with them.
- You can control how we communicate with you.
- You have rights to the information that we request or have collected about you.
- You can ask to be removed from the community.
- We are based in the United States, and data is transferred and held securely within US-based data centers. When our global operations require us to transfer information to other countries we utilize appropriate safeguards
- You can contact us at any time at email@example.com
3. About Us
- MicroMentor is an initiative of Mercy Corps, a non-profit, humanitarian agency ("MicroMentor"). MicroMentor's mission is to help small businesses grow faster and employ more people by making it easy to be a mentor, find a mentor, and build a business.
- Our contact information is as follows:Mercy Corps - MicroMentor
PO Box 2669
Portland, OR 97208-2669
- If you have joined MicroMentor through your employer or other organization, you may be subject to their policies and procedures regarding privacy and acceptable use of this website. Please contact your program administrator for more details.
4. Information we collect about you
Information you provide to us
- When you register with MicroMentor and create a user profile to participate in MicroMentor's programs, you provide us with certain personal and business information, such as your name, your email address, your telephone number, your postal code, your group or company affiliations, and your password.
Information we receive from other sources
Other users - Messages, endorsements and feedback
- MicroMentor may collect or request information about you from other users you have interacted with. This may include messages they exchanged with you, feedback on your conversations, ratings, or endorsements. We also collect negative feedback such as when there may be evidence of spam, solicitation, or fraud.
- MicroMentor occasionally asks participants to submit references to us before being accepted into the program. MicroMentor stores this information for the sole purpose of conducting reference checks. The reference may contact MicroMentor at firstname.lastname@example.org to request the removal of this information from our database.
Information we collect automatically when you use our service
Device and web browsing data
- When you access the Website, we collect your IP address, browser type, internet service provider (ISP), referring/exit pages, platform and device type, date/time stamp, and number of clicks. This information is gathered for all Website users.
- We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience.
- How much of this information we collect depends on the type and settings of the device you use to access the Services.
5. How we use information we collect
To provide services and personalize your experience
- To match you with either a mentor or a mentee. Once a match is made or you connect with another user, your name and the URL of your public MicroMentor profile and associated content will be supplied to the person you have been matched with.
For research and development
To improve our services
- To evaluate and improve the MicroMentor services and the Website and offer personalized features.
For Impact measurement
- We will also use non-identifiable, aggregate information to guide our program efforts and report to funders, stakeholders and external partners.
To communicate with you about the service
- To communicate with you regarding our services, the mentoring process, and upcoming MicroMentor events or initiatives.
- MicroMentor may send you service-related announcements from time to time through the general operation of the service. For instance, if you receive a mentoring request or an offer for mentoring advice, you may receive an email or other message alerting you to that fact.
To market and promote the service
- With your explicit permission, we may use your personal details to promote MicroMentor. You will be contacted before any release of such information for MicroMentor's promotional purposes, and you may withdraw any permission that you may grant at any time.
For customer support
- We communicate with users to provide requested services and in regards to issues relating to their account. We reply via email, regular mail or phone, depending on the nature of the communication.
For safety and security
- We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
With your consent
- We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote MicroMentor, or display photographs of you from a MicroMentor event, with your permission. In such instances, terms and conditions for the collection and use of information will be stated separately and made explicit to respondents in advance of data collection.
Legal bases for processing (EEA users)
- If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
- If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
6. How we share information we collect
Sharing with other MicroMentor users
Your public profile and business information
- If you choose to create a profile on MicroMentor, certain profile information will be collected and displayed publicly on the Website. This will include your name, the city and state where you live, and your membership with a group or company.
- If you choose to create an entrepreneur profile on MicroMentor, certain profile information will be collected and displayed publicly on the Website. This may include your name, city of residence, membership with a group or company, a photograph you provide, business name, industry, business website, start date of business, general business description, and additional information you provide when you register with MicroMentor.
- If you choose to create a mentor profile on MicroMentor, certain profile information will be collected and displayed publicly on the Website. This may include your name, city of residence, a photograph you provide, your position or title, company name, industry, areas of expertise, a description of business expertise, years of ownership experience, years of management experience, and additional information you provide when you register with MicroMentor.
Sharing with third parties
To provide services
- MicroMentor may provide information to certain third party companies which we may contract to perform services to you on our behalf. These services may include postal and e-mail delivery, customer relationship management, customer service, development and research, data analysis, fraud protection, and payment processing (e.g., through PayPal or a similar service which collects and processes donations on our behalf). The third parties we contract with for the provision of these services will be permitted to obtain only such personal information as they require to deliver the services and only use such information for their provision of the applicable services to us.
- Also, profile information you submit to MicroMentor may be made available to third party search engines. This is primarily so potential mentors or mentees can find you and send a mentor request or an offer for mentoring advice. People who see your name in searches will be able to access your profile information by clicking on your name or profile picture thumbnail.
- MicroMentor may provide information in your profile without identifying you as an individual to third parties. We may do this for purposes such as personalizing advertisements and promotions.
- Though we may use an intermediary to conduct user surveys, they may not use users' personally identifiable information for any secondary purposes.
Sharing with affiliated companies
- MicroMentor is a program of Mercy Corps and Mercy Corps Europe.
7. How we store and secure information we collect
Information storage and security
How long we keep information
- How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
8. How to access and control your information
- You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. Where the Services are administered for you by an administrator (see "Notice to End Users" below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
- Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
Access and update your information
Our Services and related documentation give you the ability to access and update certain information about you from within the Service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
Deactivate your account
- To deactivate your account on the Website, send an email to email@example.com with "Deactivate" in the subject line.
Delete your information
Our Services and related documentation give you the ability to delete certain information about you from within the Service. For example you can remove certain profile information within your profile settings. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
- Request that we stop using your information
- In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable).
- Opt out of communications
- Users will occasionally receive information on MicroMentor services, messages regarding participation in MicroMentor, and newsletters. Users cannot opt out of certain communications that are necessary for them to receive in order to participate in MicroMentor. Users who have deactivated their accounts can opt-out of these mailings.
- By registering or otherwise agreeing, users agree to receiving communications from MicroMentor. Users may 'opt-out' of receiving further marketing communications by replying to firstname.lastname@example.org with "Unsubscribe" in the subject line. There may be up to a seven-day delay in manually processed requests.
- Opt out of cookies and related technologies
- Many browsers include their own management tools for removing HTML5 local storage objects. To manage "flash cookies" please click here.
- You will not be able to opt-out of any cookies or other technologies that are “strictly necessary” for the services.
- Data portability
- If you require data from your account in a machine-readable format, you may send your request to email@example.com. When you make such requests, we may need time to investigate and facilitate your request.
9. How we transfer information we collect internationally
International transfers of information we collect
- By using MicroMentor, you are consenting to have your personal data transferred to and processed in the United States. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the services. Whenever we transfer your information, we take steps to protect it.
International transfers within Mercy Corps offices
- To facilitate our global operations, we transfer information to the United States and allow access to that information from countries in which the Mercy Corps has operations for the purposes described in this policy.
International transfers to third parties
10. Other important privacy information
Notice to end users
- Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the accounts and/or sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization's policies. We are not responsible for the privacy or security practices of an administrator's organization, which may be different than this policy.
- Administrators are able to:
- require you to reset your account password;
- restrict, suspend or terminate your access to the Services;
- access information in and about your account;
- access or retain information stored as part of your account;
- In some cases, administrators can also:
- restrict, suspend or terminate your account access;
- change the email address associated with your account;
- change your information, including profile information;
- restrict your ability to edit, restrict, modify or delete information
- Even if the Services are not currently administered to you by an organization, if you use an email address provided by an organization (such as your work email address) to access the Services, then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date.
- If you do not want an administrator to be able to assert control over your account or use of the Services, use your personal email address to register for or access the Services. If an administrator has not already asserted control over your account or access to the Services, you can update the email address associated with your account through your account settings in your profile. Once an administrator asserts control over your account or use of the Services, you will no longer be able to change the email address associated with your account without administrator approval.
- Please contact your organization or refer to your administrator’s organizational policies for more information.
Your privacy and confidentiality obligations
Links to third party sites
- This Website contains links to other sites. Please be aware that MicroMentor is not responsible for the privacy or other practices of such other sites. We encourage our users to be aware when they leave our Website and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this Website.
Our policy towards children
- The services are not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact firstname.lastname@example.org.
- If, however, we are going to use users' personally identifiable information (i.e. name) in a manner different from that stated at the time of collection, we will notify users via email. Users will have a choice as to whether or not we use their personal information in this different manner. However, if users have opted out of all communications, or deleted/deactivated their account, then they will not be contacted, nor will their personal information be used in this new manner.
Our contact information is as follows:
Mercy Corps - MicroMentor
PO Box 2669
Portland, OR 97208-2669