Privacy Policy for Virtual Mentor™

read privacy policy for: THE COMPANY and MENTORA™ 

Institute for Personal Leadership LLC (“IPL”)

Effective Date: November 5, 2016
Prior Versions: None.

Privacy Policy
Your privacy is very important to IPL. With that in mind, we have established information handling practices for our invention Virtual Mentor™, including its software applications.  We believe these practices are consistent with the highest standards and best practices of educational organizations utilizing inventions and applications with mobile devices. Virtual Mentor is 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 Virtual Mentor including the information we collect about you, when and how we collect that information, and what may happen to 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 our invention.

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

Use of Videos
When you use Virtual Mentor, you record your video responses to role-play challenges. Your videos are uploaded to our video server and are viewed by your peers to give feedback and in turn, you view videos of your peers and give them feedback. At IPL, we will use your video responses within your own classroom or group and for our internal research purposes only. However, if your video responses are rated highly through the peer rating system, and do not disclose private, personal, or sensitive information, we may use them in other classes within IPL as a demonstration of best practices (you may, however, send written notice to us at contact@personalleadership.com to advise us that you do not want IPL to use your videos in any of its other classes).  If we want to use your videos in any other way beyond these internal and teaching related uses, we will obtain your written permission before doing so.  Generally, your videos are stored only for purposes of using Virtual Mentor, and they will be permanently deleted and destroyed approximately one year after you are no longer authorized to use Virtual Mentor.

Use of Email Addresses
We may use your name and email address to contact you with important information, required notices, and key communications about Virtual Mentor 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 any third parties, and will only send you emails we believe are important.

User-Provided Data.
The authorized user of Virtual Mentor creates certain data, such as video and audio recordings 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 Virtual Mentor.  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 Virtual Mentor to function properly.

Automatically-Collected Data
Virtual Mentor 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 Virtual Mentor platform and bring the best end-user experience to participants in the future.  We will retain Automatically-Collected Data for up to 12 months and thereafter may store it in aggregate for archival purposes.

Access to Data
User-Created Data and Automatically-Created Data (collectively, “Data”) may be accessed by you only as permitted by Virtual Mentor’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 of Virtual Mentor.  Also, if you are using Virtual Mentor as part of a program your employer has authorized, your employer may have access to Data.  Data will be owned and managed by IPL solely for purposes of operating Virtual Mentor, and will be retained or deleted in accordance with this Privacy Policy.

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

Vendors
IPL relies on trustworthy and experienced third-party vendors to provide much of the data storage and usage requirements for Virtual Mentor.  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 Virtual Mentor.  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.

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 Virtual Mentor. Please be aware that, although we endeavor to provide reasonable 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.

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.

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