Privacy

The MENTOR Network
Privacy Policy

Date Privacy Policy Last Modified/Reviewed: January 1, 2020.

INTRODUCTION

The MENTOR Network and its affiliated entities (“Company” or “We”) respects your privacy and are committed to protecting your personal information through our compliance with this Privacy Policy.

This Policy will inform you as to how we look after your personal information, your privacy rights, how the law protects you, and our practices for collecting, using, maintaining, protecting and disclosing your personal information when you visit any of our websites (our “Website”) or transact with us (collectively, the Website and our services are referred to as the “Services”)

Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services because we will not be able to perform the Services.

By accessing or using our Services, you agree to this Privacy Policy, and if you are under age 16, you have your parent or legal guardian’s permission to use our Services and your parent/legal guardian has agreed to this Privacy Policy.

1. IMPORTANT INFORMATION

PURPOSE OF THIS PRIVACY NOTICE
This Privacy Policy will inform you how the Company collects and processes your personal information through your use of the Services. This Policy applies to Personal Information we collect:

• Directly from you when you visit our Website or communicate with us or our representatives (whether electronically, by telephone or paper forms); and
• Automatically from you as you browse our Website.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat Personal Information, we will notify you through a notice on the Website home page or by sending an email to the email address you provided to us. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes to our Privacy Policy.

It is important that the Personal Information, and importantly, the contact information we hold about you is accurate and current.  If you provide your e-mail address to us, you are responsible for ensuring we have a current e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

The date the privacy policy was last revised is identified in the first paragraph above.  Historic versions are available upon request to the contact listed below.

2. THE PERSONAL INFORMATION WE COLLECT
   We collect types of information which identify, relate to or is reasonably capable of being associated with a particular individual (“Personal Information”).

3. HOW PERSONAL INFORMATION IS COLLECTED
   We use different methods to collect this information from you and about you including:

• Direct interactions. You may give us your Personal Information by filling in forms or by corresponding with us by mail, phone, email or otherwise.  This includes Personal Information you provide when you:
  • Use our Services
  • Request marketing be sent to you;
  • Fill out a form or contact our representatives; or
  • Give us some feedback or report a problem with our Services.
• Automated technologies or interactions. As you interact with our Services, we may automatically collect Personal Information about your equipment, browsing actions and patterns. Information collected automatically may include usage details, IP addresses and information collected through cookies.  The technologies we use may include cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Third parties or publicly available sources. We may receive Personal Information about you from various third parties and public sources as set out below:
  • Web analytics providers.
  • Advertising networks.
  • Search information providers.

THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES.
The Services may include links (and advertisements) to third-party websites, plug-ins, and applications.  These third parties may use cookies or other tracking technologies to collect information about you when you use our Services. Clicking on those links or enabling those connections may allow third parties to collect or share data about you and about your online activities over time and across different websites and other online services.   They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.  We do not control these third-party websites or their privacy practices, and are not responsible for their privacy statements/notices.  When you leave our Services (including the Website), we encourage you to read the privacy notice of every website you visit and application you use.

4. HOW WE USE PERSONAL INFORMATION
   We may use information that we collect about you or that you provide to us, including your Personal Information for the following purposes:

• To fulfill or meet the reason you provided the information.
• To create, maintain, customize, and secure your account with us.
• To process your requests.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To provide you with updates and marketing communications about services and offers that may be relevant to you.
• To personalize your website experience and to deliver content and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, services, databases and other technology assets and business.
• For testing, analysis, and product development, including to develop and improve our Website, Services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred.
• To enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

5. SHARING YOUR PERSONAL INFORMATION
   We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose your Personal Information to affiliated companies and external parties for business purposes, and when we do so, the parties are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.  We may also share your Personal Information with the following categories of third parties: Service Providers (such as technology service providers and financial service providers).

6. CHILDREN AND PRIVACY
   Our Website and Services are not intended for children under the age of 16 and we do not knowingly collect, use, disclose or sell Personal Information from children under age 16. If you know or suspect that your child has submitted Personal Information to us and you would like to request that such information be removed, you may do so by contacting us at the address listed below in the Contact Information section. 

7. INTERNATIONAL TRANSFER
   If you are located in a province, country, or other government jurisdiction outside of the United States, and if you choose to provide your Personal Information to the Company through our Services, please be aware that your personal information will be transferred to and maintained on computers located in the United States and the applicable US privacy laws may not be as protective as those in your jurisdiction.

8. DATA SECURITY
   We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.  We also limit access to Personal Information to those employees, agents, contractors, and other third parties who have a business need to know.  These individuals will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of the data transmitted to or through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

9. DATA RETENTION
   We may maintain one or more databases to store your Personal Information and may keep such information indefinitely in order to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  In some circumstances we may anonymize your Personal Information 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.

10. YOUR LEGAL RIGHTS

 CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Disclosure of Your Information for Third-Party Advertising. We do not share your Personal Information with any unaffiliated third parties for advertising purposes.
• Updates and Promotional Offers from the Company. If you do not wish to have your e-mail address used by the Company to promote or provide updates about our own or third parties’ services, you can opt-out by sending us an e-mail stating your request to the e-mail address provided below in the Contact Information section. If we have sent you a marketing or promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt out does not apply to communications with the Company as a result of a service experience or other transactions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an e-mail stating your request to the e-mail address provided below in the Contact Information section.
• We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website. 

11. CONTACT INFORMATION

Contact for General Inquiries and Requests to Change Information

If you provided us with Personal Information and have a general inquiry or would like to request changes to your information, or unsubscribe from an e-mail subscription, please contact us in one of the following methods.

E-mail: [email protected]
Telephone: 617-790-4800
Mail: 313 Congress Street, 6^th Floor, Boston, MA 02210
Attn: General Counsel

Privacy Notice for California Residents

The California Consumer Privacy Act (“CCPA”) requires businesses subject to the CCPA to provide certain disclosures to California residents and also provides California residents with specific rights regarding their Personal Information unless an exception applies. Read the Notice