Privacy Policy

Thanks for using MentorWorks. We take very seriously the respect and protection of your privacy and security. We are
committed to following and continuously evolving best practices to support this principle.

We – meaning MentorWorks Education Capital, Inc., doing business as MentorWorks (also “MentorWorks”,
“MentorWorks.com”, “our”, or “us”) – prepared this Privacy Policy to help you understand our practices with respect to
the collection, use, and disclosure of information we collect from you through MentorWork’s web or mobile applications
(the “MentorWorks Products”), our websites that link to this Privacy Policy, and any other services we provide to our
customers or end users (collectively with the MentorWorks Products, the “Services”).

By accessing or using the Services, you agree to this Privacy Policy and our Terms of Service.

What Information We Collect

What types of information we collect from you depends on how you use the Services, what Services you use, and what
information you choose to provide or make available to us for different types of services. We collect information from
you when you:

  • Create or register an account, and when you administer your account
  • Apply for ISA or Mentoring Services
  • Input information or data into any of our Services, or post or upload Content to our Services
  • Submit questions, requests, other communications to us via forms, email, or other communication media
  • Contact us for customer support or technical support
  • Visit any of our websites or download any of our apps
  • Participate in any promotions, demonstrations, contests, surveys, or other marketing events
  • Interact with other MentorWorks users and guests on our community forums
  • Integrate third-party products and services with your MentorWorks account

Customer Information

Information related to the creation of accounts or that otherwise identifies you as a customer or end user of
MentorWorks is what we call “Customer Information.” Customer Information may include certain “personally identifiable
information” or “PII”, such as your name, email address, gender, age, postal address and phone number. It also may
include payment information, such as payment method, credit card information, and any contact information (such as
name and postal address) associated with payment billing information. If you are an end user using the Services
through an account created on your behalf by a MentorWorks customer (such as an employer, organization of which you
are a member, or another individual), we may collect and process Customer Information about you on behalf of the
MentorWorks customer with whom your use of the Services is associated. In that case, we will provide you with notice
regarding the information we have been given about you.

When you create an account with MentorWorks, we may collect certain Customer Information directly from you or, if you
create your account using a third-party service (such as Google and LinkedIn or a single sign-on service such as
Okta), we may collect Customer Information about you from the third-party service (such as your username or user ID
associated with that third-party service). By choosing to create an account using a third-party service, you authorize
us to collect Customer Information necessary to authenticate your account with the third-party service provider, and
acknowledge that MentorWorks has no control over information maintained about you by such third-party service
provider.

You may also be asked to authorize MentorWorks to collect information from the third-party service provider on your
behalf. We will then collect information (such as your username or user ID associated with that third-party service)
from you and/or that third-party service provider as necessary to enable the Services to access your data and content
stored with that third-party service provider. Once the authentication is complete, we have the ability to access
information you provided to us or were otherwise collected by the third-party service in accordance with the privacy
practices of that third-party service. We will store the information and data we collect and associate it with your
MentorWorks account, and we will only use that information and data to enable the integration of the Services with the
third-party service provider and to perform actions requested or initiated by you, or that are reasonably necessary to
carry out instructions provided by you.

Content

One of the core aspects of the MentorWorks Products (and our related Services) is that you can upload any
information, data, content, material – anything. We call anything you upload through the MentorWorks Products
“Content.” You (and anyone who can interact with your use of the MentorWorks Products) ultimately control the nature
of the Content, and our collection, use, and disclosure practices with respect to Content are separate from those with
respect to other sorts of information we collect, including Customer Information. As explained in detail above, we may
also upload Content automatically with your authorization from third-party service providers (such as from your Google
Drive).

Information collected automatically through your use of the Services

We collect information about how you use the Services and your actions on the Services, including IP addresses, what
software and hardware you use (such as browser types, operating systems, ISPs, platform type, device type, mobile
device identifiers such as make and model, mobile carrier), pages or features of MentorWorks used and associated dates
and time stamps, search terms, links you click, whether you open messages sent to your account, and other statistics
related to your usage of the Services. We may also use tools, including third-party tools, to collect analytics data.
Some of this information is collected through the use of “cookies” and other tracking technologies, such as web
beacons, session replay scripts, and similar technologies (“tracking technologies”). We may also work with third party
partners to employ tracking technologies.

If you would prefer not to accept cookies or otherwise wish to disable our use of tracking technologies, please see
“Managing Your Information,” below. Please note that doing so may negatively impact your experience using the
Services, as some features may not work properly.

Location Information

In some cases, we may collect limited location information. For example, we may use Google Analytics convert your IP
address into a rough geolocation to understand in what areas our users are located and to improve and personalize our
Services (for example, to display time data in the correct local time).

Aggregated and anonymized information

We may collect information by aggregating and anonymizing other information. The aggregation and anonymization
process prevents the information from being associated or identified with any one customer account, user, or
individual. We may use aggregated and anonymized information for a wide variety of statistical and analytical
purposes.

How we use the information we collect

We use the information we collect for a variety of purposes, and how we use it depends on what we collect and what
Services you use (or features of the Services). These purposes may include:

  • Providing the Services to you
  • Responding to requests or inquiries from you
  • Providing customer support or technical assistance
  • Contacting you to provide product updates, information about products you have requested or purchased
  • Marketing MentorWorks products, services and features that you may be interested in, and monitoring the
    performance of our advertisements and marketing efforts
  • Creating or administering your account, including identifying you with your account or the account of an
    MentorWorks customer
  • Billing you or your organization
  • Deriving market insights, ways to improve the Services, and other business analysis or research purposes
  • Customizing existing and future product offerings and other aspects of the Services to you and other users
  • Securing the Services and our systems, and protecting your information and data
  • Sharing with third parties for the purposes discussed in “How we share information”, below
  • Any legitimate business purpose, provided that the information is aggregated and anonymized

Personally Identifiable Information

Specifically, we may use personally identifiable information (including those contained within the Customer
Information or otherwise collected by us) for the above purposes, but only as to the extent necessary for the purposes
for which you have provided us with the information, to respond to inquiries or requests (including requests for
customer support or technical assistance), to otherwise perform our obligations or act consistently with our Terms of
Service, to respond to law enforcement or other governmental or legal authorities, and to otherwise use the
information consistent with your instructions to us (both explicit, such as when you contact us directly with a
request understood in connection with your engaging us to provide you with the Services). If you wish to change these
instructions, either by request, by correcting, amending, or deleting information we may have collected about you, or
by opting out of certain data collection practices, please see “Managing Your Information”, below.

Use of Content

Notwithstanding anything else in this Privacy Policy to the contrary, we will not use or access your Content except
in the following cases: for providing the Services to you; where you (or, if you are an end user, the MentorWorks
customer through which you have an account) explicitly approve access (e.g., during a customer support inquiry); where
compelled to do so in response to lawful requests by law enforcement or government regulators; where necessary to
ensure the stability and security of the Services and our systems (e.g., where we have reason to believe specific
Content is degrading server stability); and where necessary to protect the rights, privacy, safety, or property of
you, us, or others. We may also analyze metadata related to Content (such as total number of records, file size, API
volume, access logs, etc.).

How we share information

We disclose information we collect in the following cases:

  • You asked us to, or otherwise gave your specific consent
  • With vendors we engage to provide you with aspects of the Services, such as data storage, hosting, and payment
    processing.
  • With third-party service providers who enable certain features or functionalities of the Services that you or your
    organization requested. A sample list of third party providers who enable these features or functionalities is
    available upon formal request
  • With vendors we engage to help us gain insights and analytics into how the Services are used and how they might be
    improved (for example, we may use third-party data enrichment services to match Customer Information or other
    personally identifiable information we collect with publicly available database information in order to communicate
    more effectively with you).
  • As necessary to comply with applicable law, including governmental requests, law enforcement requests, and
    otherwise to protect the rights, privacy, safety, or property of you, others, or us.
  • As necessary in the event of a proposed or actual reorganization, merger, sale, joint venture, assignment,
    transfer, financing, or other disposition of all or any portion of MentorWorks business, assets, or stock.
  • With others for any legitimate business purpose, provided the information is aggregated and anonymized.

How we secure your information

We implement appropriate technical and organizational measures to protect the information we collect and store.
Unfortunately, no security measures are 100% foolproof, and as such no network or system (including ours) can be
guaranteed to be 100% secure against destruction, loss, alteration, unauthorized disclosure of, or access to
information we collect and store. If you believe your information may not be secure for any reason, please contact us
immediately at contact@mentorworks.com.

Managing Your Information

You have many choices to access information we collect about you and about how we use or disclose that information.
This section details many of those choices, including how you can exercise rights you may with respect to your
information (including personally identifiable information), how you can opt out of collection and use of certain
types of information for certain purposes (such as marketing), and how you can use your browser or third-party tools
to disable certain collection methods (such as cookies or tracking technologies).

You may access, correct, amend, or delete Content by accessing it within MentorWorks. You control all Content you
upload. Content you delete (including Content containing personal information) may be retained in archived or backup
copies in order to enable you to use certain features like revision history and base snapshots. For instructions on
how to permanently delete Content from your MentorWorks account, please contact us at privacy@mentorworks.com. Please note that permanent deletion of Content
through this process will impair or disable those features with respect to that Content.

You may access, correct, amend, or delete Customer Information we have about you by logging into your account and
navigating to your Account page. If you wish to cancel your account, you may do so by emailing us at privacy@mentorworks.com. If you do, personally identifiable
information associated with your account will be deleted as soon as is reasonably practical or as required by
applicable law. Please note that we may retain information that is otherwise deleted in anonymized and aggregated
form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by
law.

Even if you do not request its deletion, Customer Information and other personal data will not be kept for longer
than is necessary for the purpose (s) for which it was collected, but in general, we will retain information for
future use without a specific time limit, unless you formally request removal of your information.  Removal of your
information may affect your ability to use Services.  It is not possible for us to specify in advance the periods for
which your personal data will be retained. We may determine if the period of retention noted above needs to be
modified based on the use of the data over time.  Notwithstanding this, we may retain your Customer Data where such
retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your
vital interests or the vital interests of another person.

We may use some of the information we collect for marketing purposes, including to send you informational
communications about new MentorWorks features, products, events, or other opportunities. If you wish to stop receiving
these communications, you can contact us at privacy@mentorworks.com to opt
out.

Cookies and Tracking Technologies – How to Opt Out

If you would prefer not to accept cookies or otherwise wish to disable our use of tracking technologies, most
browsers and mobile devices allow you to change your settings so as to notify you when you receive cookies or other
tracking technologies are being used, and to choose whether or not to accept/allow it. Most browsers also allow you to
disable or delete existing cookies or to automatically reject future cookies. Disabling cookies may limit your ability
to use the Services.

Certain tracking technologies we use are related to advertising networks, and through those technologies we may share
certain information such as IP addresses. No personally identifiable information is shared with these advertising
networks, but please note that the information we share with those advertising networks might be combined with other
information about you that those networks may have collected from other sources.

Certain tracking technologies we use involve the use of session replay scripts or other scripts that run directly
from your browser. If you wish to disable these tracking technologies, you can install a third-party browser analytics
blocker plug-in such as Ghostery.

If you have any questions about how our third-party service providers or we use cookies or other tracking
technologies that aren’t answered in this Privacy Policy, please contact us at privacy@mentorworks.com.

International Transfers And Information for Users From the European Union or European Economic Area

If you are a resident of or are located in the European Union or European Economic Area (“EEA”), you may also have
certain rights under the General Data Protection Regulation (“GDPR”).  Personal data you provide on any MentorWorks
may be transmitted outside of the EEA to MentorWorks (or computer servers maintained for the benefit of MentorWorks),
as described in this Privacy Policy.

In general, under the GDPR you may:

  • request access to your Personal Data
  • have incomplete or incorrect data corrected
  • have your Personal Data deleted
  • suspend or restrict our use of your personal data, or withdraw your consent
  • request a copy of your personal data
  • complain to a supervisory authority if you believe your rights under the GDPR are not being respected

Should you request a copy of your personal data, we will supply it to you. The first copy will be provided free of
charge, but additional copies may be subject to a reasonable fee.  Should you request the deletion of your personal
data, MentorWorks will generally do so as soon as practicable, although your right to have your personal data deleted
is subject to exceptions, such as, for example, compliance with a legal obligation or for the establishment, exercise
or defense of legal claims.

If you consider that our processing of your personal information infringes data protection laws, you have a legal
right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU
member state of your habitual residence, your place of work or the place of the alleged infringement.

Contact us (the Data Protection Officer or DPO) at privacy@mentorworks.com if you have concerns regarding your
personal data, or wish to exercise any of these listed rights.

We process and store information on servers located in the United States, and we may store information on servers
and equipment in other countries depending on a variety of factors, including the locations of our users and service
providers. By using the Services, you consent to the transfer of information (including Customer Information, Content,
and personally identifiable information) to locations that may be outside of your country of residence, including the
United States. You acknowledge and agree that, as a condition of providing any Content, you can legally transfer it to
the United States or another country. If we transfer your information outside of the EEA in this way, we will take
steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights
continue to be protected as outlined in this policy.

With respect to transfers of information out of the European Union (EU), we may process some personally identifiable
information pursuant to data processing agreements that include the EU Standard Contractual Clauses. To learn more
about our data processing agreements, please contact us at contact@mentorworks.com.

Information from Children

MentorWorks is not directed to children under the age of 13 and we do not knowingly collect personally identifiable
information from children under the age of 13. If we learn that we have collected personally identifiable information
of a child under the age 13, we will take reasonable steps to delete such information from our files as soon as is
practicable. Please contact us at contact@mentorworks.com if you believe
we have any information from or about a child under the age of 13.

Changes to Privacy Policy

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected.
We may, however, revise the Privacy Policy from time to time. If a revision is material, as determined solely by us,
we will notify you, for example via email. The current version will always be posted to our Privacy Policy page.