Privacy Policy

Consent to installation of the Platform

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. It is important that you read this policy, which provides this information to you.

By installing our app or using our platform, you will be asked to indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this policy.

This privacy policy should be read in conjunction with our cookie policy, available on our website.

How you can withdraw consent

Once you provide consent to us using your personal data, you may change your mind and withdraw consent at any time by contacting us but that will not affect the lawfulness of any processing carried out before you withdraw your consent. By withdrawing your consent, we will no longer be able to provide our services to you.

Introduction

This policy applies to your use of:

The Mentor360 mobile application software and platform (together the Platform), through your mobile, tablet, laptop, computer or other device (Device).
Any of the services accessible through the Platform (Services).

In this policy, the following expressions shall have the following meanings:

data protection laws: means the EU law retained version of the General Data Protection Regulations (2016/679) (UK GDPR) and the Data Protection Act 2018;
personal data: means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by the data protection laws.

Our Platform is compliant with data protection laws. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The Platform is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Mentor360 Limited is the data controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this policy).

Our Data Protection Officer (DPO) is Richard Bassett:

Email address: Richard@mentor360.com
Telephone number: +447968719369

Contact details

Our full details are:

Full name of legal entity: Mentor360 Limited
Email address: info@mentor360.com
Address: 7 & 8 Church Street, Wimborne, Dorset, BH21 1JH

If you wish to contact the developer in respect of your rights under the data protection laws, you may contact us using the same details as above and we will endeavour to respond within 2 months.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It may change and, if it does, the new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Platform or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

This table sets out the personal data we collect, why we collect it, and the lawful basis we have for collecting it. Please note that under the principles of data minimisation under data protection laws, we will collect only the personal data we actually need, as follows:

Purpose/activity	Type of data	Lawful basis for processing	Can you opt out?
To install the Platform on your Device	First name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, billing address, email address, telephone number.	This data is collected when you install the Platform on your Device. Your consent and to perform a contract with you (i.e. provide you with access to the Platform).	You cannot opt out of these processing activities, otherwise we will be unable to provide the Services to you.
To log in to the Platform on your Device	First name, last name, email address, Facebook username and/or Google username and passwords	If you choose to login to our Platform using your Facebook or Google account, we will collect this data from you. Your consent and to perform a contract with you (i.e. provide you with access to the Platform).	You may opt out of these activities by refraining from logging in via your Facebook or Google account.
To use the Platform for its intended purpose	Responses to questionnaires, how you are progressing, information about your day, how you are feeling and other information you choose to add to the Platform.	This data is collected when you choose to input information into the Platform. Your consent and to perform a contract with you (i.e. to allow you to monitor progress through your use of the Platform).	You can opt out of these activities by refraining from responding to questions and requests for information asked via the Platform.
To make payments via the Platform	Payment details. Please note that we do not have access to such data; it is processed via our third party payment provider.	This data is collected when you choose to provide payment details in the Platform. To perform a contract with you (i.e. to allow you to make purchases on the Platform).	You cannot opt out of these processing activities, otherwise we will be unable to provide the Services to you.
To manage our relationship with you including notifying you of changes to the Platform or any Services	Name and contact email address.	This data is collected when you download the Platform. To perform a contract with you (i.e. to keep you updated on your use of the Platform), necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services), and necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)	You cannot opt out of these processing activities, otherwise we will be unable to provide the Services to you.
To administer and protect our business and the Platform including troubleshooting, data analysis and system testing	IP address and device information.	This data is collected when you access the Platform. This is necessary for our legitimate interest to ensure the Platform operates as it is meant to.	You cannot opt out of these processing activities, otherwise we will be unable to provide the Services to you.
To deliver content and advertisements to you. To make recommendations to you about goods or services which may interest you. To measure and analyse the effectiveness of the advertising we serve you. To monitor trends so we can improve the Platform and Services	Name and contact email address. This includes your preferences in receiving marketing from us.	This data is collected when you create an account on the Platform and/or sign up to our newsletter and alerts. It is then added to our email list, hosted on MailChimp. This information is necessary for our legitimate interest to present relevant content, products and services to you, including our newsletter, subscription updates and blog posts (only where you have provided your consent that we do so, by ‘opting in’). We will never market to you without your consent, and you may unsubscribe from such communications at any time.	You may opt out of these activities by unsubscribing from our newsletter at any time.

Should the purpose of any data collection method mentioned above change, you will be informed, and your consent will be re-obtained (if we have relied on consent as the lawful basis to process your data).

We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your “Usage Data” to calculate the percentage of users accessing a specific Platform feature and is collected when you use the Platform. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

There are different special categories of personal data (which includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). The data we process when you access the Platform which falls under the special categories is your mental and physical health, and as such we have a legal duty of confidentiality to protect this personal data. We don’t, however, collect any special categories of personal data such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data, nor do we collect any information about criminal convictions and offences.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us by using our contact details in this policy.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so. Alternatively, we may be required to obtain your consent again for use of the data, where we have relied on consent as a lawful basis.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the data protection laws and your legal rights.

Automated Processing

We do not make decisions by automated processing, including profiling. In the event that we do this, we will update this policy and inform you of your right to request that you are not subject to a decision based solely on automated processing, including profiling.

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table:

Service providers acting as processors who provide IT, payment and system administration services and analyse the use of the Services including Google Analytics, Firebase and UX Cam.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Our affiliates which includes any parent company of us and any of its subsidiaries.
When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by other users and may be publicly distributed outside.

International transfers

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, or
Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK, and we will undertake regular due diligence on these third parties.

Data security

We take the protection of your personal data seriously and all information you provide to us is stored on our secure servers. We use Google Firestore to host all personal data and this personal data is encrypted between your Device and any the external host storage. We understand that Google’s cloud services employ industry standard security, including encryption in transit and at rest and ISO/IEC27001/27017/27018/27701, SOC 1/2/3, PCI DSS, and FedRAMP certifications. For further information, please refer to the following link: https://cloud.google.com/security/

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Platform or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

Where any of the Services include social networking, chat room or forum features please ensure that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

By law we have to keep basic information about our customers for six years after they cease being customers for tax, legal or regulatory purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the Platform or Services for a period of time then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. At any given moment, you are able to delete your account and all your personal data that is connected with it. You can do this by following these steps. 1. Navigate to the account page. 2. Click the ‘Delete Account button. 3. When a pop-up appears asking you to confirm the action, click ‘Confirm’.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data’s accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Children’s data

Our Platform and Services do not address anyone under the age of 12. We do not knowingly collect personally identifiable information from anyone under the age of 12. If You are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 12 without verification of parental consent, we take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Notice to California residents

If you are a California resident, California law may provide you with additional rights regarding your personal data.

The California Consumer Privacy Act of 2020 (“CCPA”) gives you the following rights:

Right to know about the personal information we collect and share
The CCPA gives you the right to request that we disclose the specific pieces of personal information we have collected about you. Please see above for information on the data we collect on you, and how we process it. We do not sell your personal information.
Right of deletion. You have the right to request that we delete your personal information, subject to certain exceptions. If you wish to delete your personal data, please contact us at info@mentor360.com. Please note that we may require certain information from you in order to verify your identity before proceeding with your request.
Disclosures about your personal information. We collect the categories of personal information from you in connection with your use of our Website as described above.
Non-discrimination. We will not discriminate against you for exercising any of your CCPA rights.

COOKIE POLICY

Consent to installation of the Platform

Under data protection laws and cookie laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. It is important that you read this policy, which provides this information to you.

By installing our Platform, cookies will be saved onto your Device, as described in detail in this policy.

This cookie policy should be read in conjunction with our privacy policy, available on our website.

How you can withdraw consent

Once you provide consent to the use of cookies, you may change your mind and withdraw consent at any time by changing your preferences. By withdrawing your consent, we may not be able to provide you with the full experience our Platform offers.

Introduction

This policy applies to your use of:

The Mentor360 mobile application software and platform (together the Platform), through your mobile, tablet, laptop, computer or other device (Device).
Any of the services accessible through the Platform (Services).

In this policy, the following expressions shall have the following meanings:

cookie: means a small file placed on your computer or device by our Platform when you visit certain parts of the Platform and/or when you use certain features of our Platform;
cookie laws: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and, where applicable, the UK GDPR;
data protection laws: means the EU law retained version of the General Data Protection Regulations (2016/679) (UK GDPR) and the Data Protection Act 2018;
personal data: means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by the data protection laws.

Our Platform is compliant with data protection laws and cookie laws. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Our Platform is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Mentor360 Limited is the data controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this policy).

Contact details

Our full details are:

Full name of legal entity: Mentor360 Limited
Email address: info@mentor360.com
Address: 7 & 8 Church Street, Wimborne, Dorset, BH21 1JH

Changes to the cookie policy and your duty to inform us of changes

We keep our cookie policy under regular review. It may change and, if it does, the new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Platform or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the Platform, our app or the distribution platform (Appstore) and to remember your preferences. Cookies contain information that is transferred to your computer’s hard drive.

All cookies used by or on our Platform are used in accordance with current cookie law. We may use some or all of the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or use a shopping cart.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Third party cookies. Third party cookies are not placed by us and we have no control over these; instead, they are placed by third parties that provide services to us and/or to you. Third party cookies may be used by advertising services to serve up tailored advertising to you on our Platform, by third parties providing analytics services to us or by providers of external services like web traffic analysis services (these cookies will work in the same way as analytical or performance cookies described above). To deactivate the use of third party advertising cookies, you may visit your account to manage the use of these types of cookies.
Persistent cookies. Any of the above types of cookie may be a persistent cookie. Persistent cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit our Platform.
Session cookies. Any of the above types of cookie may be a session Cookie. Session cookies are temporary and only remain on your computer or device from the point at which you visit our Platform until you close your browser. Session cookies are deleted when you close your browser.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Consent and control

Before cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies (unless those cookies are strictly necessary); however certain features of our website may not function fully or as intended. You will be given the opportunity to allow and/or deny different categories of cookie that we use. You can return to your cookie preferences to review and/or change them at any time by updating the settings on your browser. We do not track cookies on the application version of the Platform.

In addition to the controls that we provide, you can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

Privacy Policy

COOKIE POLICY

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