Privacy Policy for Mentora™ 

READ PRIVACY POLICY FOR: THE COMPANY and VIRTUAL MENTOR™ 

Effective Date: December 1, 2016
Prior Versions: None.

1.  Privacy Policy
The Mentora™ educational app, platform, related invention (Virtual Mentor™), content and intellectual property (collectively, “Mentora”) are owned by Institute for Personal Leadership LLC (“IPL”).   Your privacy in using Mentora is very important to us. With that in mind, we have established information handling practices for Mentora intended to guard and respect your privacy.  We believe these practices are consistent with the highest standards and best practices of educational organizations utilizing inventions and applications with mobile devices. Mentora is a platform for learning principles of personal leadership, and a tool for practicing personal impact skills using role-play challenges and peer-to-peer feedback.  This privacy policy describes the practices that apply to Mentora including the information we collect about you, when and how we collect that information, how that information is used, how we safeguard that information, and our procedures for archiving and deleting that information. We have prepared a detailed policy because we believe you should know as much as possible about our practices so that you can make an informed decision about your use of Mentora.

2.  Terms of Use
Your use of Mentora is also subject to the Terms of Use for Mentora, a copy of which can be found here.  The Terms of Use provides further information regarding Mentora and its use.

3.  Conflicts
Your use of Mentora may be pursuant to an agreement between IPL and your employer.  If there is any conflict between that agreement and this Privacy Policy, that agreement will prevail with respect to the conflict.

4.  Use of Videos
When you use Mentora, you record your video responses to role-play challenges. Your videos are uploaded to our secure video server and are viewed by your peers and supervisors to give feedback and in turn, you view videos of your peers and give them feedback. We will use your video responses within your own classroom or group and for our internal research purposes only.  If we want to use your videos in any other way, we will obtain your written permission before doing so.  Generally, your videos are stored temporarily and only for purposes of using Mentora, and they will be permanently deleted approximately one year after you are no longer authorized to use Mentora.

 5.  Use of Email Addresses
We may use your name and email address to contact you with important information, required notices, and key communications about Mentora and IPL’s educational programs.  You will always have the option to unsubscribe to IPL’s emails.  We will never sell or lease your email to third parties.

 6.  User-Provided Data
The authorized user of Mentora creates certain data, such as self-recorded videos of the user, written texts, and other recorded responses and content (“User-Provided Data”).  Your User-Provided Data will generally be deleted approximately one (1) year after you are no longer authorized to use Mentora.  If you’d like us to delete User-Provided data sooner than that that, please contact us at contact@personalleadership.com and we will use best efforts to respond within 48 hours. Please note that some or all of the User-Provided Data may be required in order for Mentora to function properly.

 7.  Automatically-Collected Data
Mentora also collects certain information automatically, including the following:

  • Login Timestamp 
  • IP Address Video upload Timestamp     
  • Duration of video recorded
  • Feedback provided by user: quantitative and qualitative
  • Device type and Operating System information
  • Usage data

 (“Automatically-Collected Data”).  Such information will help us to continue to improve the Mentora platform and provide the best end-user experience to participants.  We will retain Automatically-Collected Data for up to 12 months and thereafter delete or store it in aggregate for archival purposes.

8.  Access to Data
Both User-Created Data and Automatically-Created Data (collectively, “Data”) may be accessed by you as permitted by Mentora’s programs and procedures.  IPL and the other participants in your program, if any, may have access to Data (including videos) in accordance with this Agreement and the established methods of using Mentora.  Also, if you are using Mentora as part of a program your employer has authorized, your employer may have access to Data.  Data will be owned and managed temporarily by IPL solely for purposes of operating Mentora, and will be archived or deleted in accordance with this Privacy Policy.

9.  Loss of Data
In administering Mentora, IPL may delete Data at any time, whether for storage or other reasons.  Data may also be lost through human or computer error.  IPL will not be responsible for any loss of Data.

10.  Vendors
IPL relies on vetted and trustworthy third-party vendors to provide much of the data storage and usage requirements for Mentora.  User-provided videos, including related content, are stored with Kaltura Inc. http://corp.kaltura.com/.  Information is transmitted to Kaltura over HTTPS, an encrypted protocol. The information stored within Kaltura is stored behind credentials and can be delivered to customers over HTTPS as well, securing encryption on outgoing traffic.  IPL is working with Kaltura to meet the highest standards of safely storing and transmitting video and other data using state-of-the-art technology and encryption.

 All Data, other than videos stored at Kaltura, is stored in Microsoft Azure. https://azure.microsoft.com/en-us.  Microsoft states that it has made an industry-leading commitment to the protection and privacy of its clients’ data.  Microsoft was the first cloud provider recognized by the European Union’s data protection authorities for its commitment to rigorous EU privacy laws. Microsoft was also the first major cloud provider to adopt the new international cloud privacy standard, ISO 27018.

 IPL may change what vendors it uses in connection with Mentora.  IPL will perform due diligence on any new vendors that it uses, and make sure they meet the highest quality of professional and security standards.

11.  Security
We take safeguarding the confidentiality of your information very seriously. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve Mentora. Please be aware that, although we endeavor to provide reasonable and good security for information we process and maintain, no security system can prevent all potential security breaches.  In general, IPL does not store sensitive information such as social security numbers or credit card information.

12.  Changes to this privacy policy
This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here.  You are advised to review this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes. You can check the history of this policy here.

13.  Contact us
If you have any questions regarding privacy while using Mentora, or have questions about our practices, please contact us via email at contact@personalleadership.com.