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Privacy Policy – Mentora®

Effective Date: December 1, 2016

 
 

Effective Date: May 24, 2018. (For the prior version of our privacy policy, please click here.)

Institute for Personal Leadership LLC, a New York company (“IPL”), respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. This privacy policy applies to personal data that you may submit through IPL’s website or its educational app, Mentora®.

Summary

1.IMPORTANT INFORMATION AND WHO WE ARE.

2.THE INFORMATION WE COLLECT ABOUT YOU.

3.USE OF PERSONAL DATA.

4.DISCLOSURE OF PERSONAL DATA.

5.EU-U.S. AND SWISS-U.S. PRIVACY SHIELD.

6.CHILDREN.

7.MARKETING EMAILS.

8.SECURITY.

9.RETENTION OF YOUR PERSONAL DATA.

10.EXTERNAL LINKS.

11.YOUR RIGHTS.

12.DISPUTE RESOLUTION AND OTHER LEGAL MATTERS.

13.CHANGES TO THIS POLICY.


1. Important information and who we are.

Purpose of this privacy notice

This privacy policy aims to give you information on how IPL collects and processes your personal data through your use of our website https://www.personalleadership.com, our app Mentora®, and from the use of IPL portals, which make reference to this policy. For purposes of this privacy policy, the terms “user”, “participant”, “customer”, “you” and “your” are meant to refer to the individuals about whom we may collect data.

Our data operations and privacy policy were changed as of May 24, 2018, to comply with new privacy and data protection regulations promulgated under the European Union’s General Data Protection Regulation (“GDPR”). While these regulations apply only to residents of the European Economic Area (“EEA”), we have decided to implement these regulations for all individuals who submit personal data to IPL. By doing this, we are significantly expanding your rights with respect to any personal data that we collect from you. Some of these rights include the following:

    1. The right to have IPL permanently delete any of your personal data.

    2. The right to review any personal data that we’ve collected from you.

    3. The right to voluntarily and affirmatively “opt-in” to any newsletters, emails, or marketing materials sent to you by IPL.

    4. The right to receive a copy of your personal data.

    5. The right to have control and access over your personal data.

    6. The right to have your personal data protected, transferred and stored in compliance with GDPR’s data protection requirements.

    7. The right to have your personal data automatically destroyed after it is no longer being actively used by IPL.

    8. The right to only receive communications from IPL pursuant to a “Lawful Basis” under GDPR. The two most common Lawful Bases pursuant to which you may receive IPL communications are: (i) that you requested, subscribed or affirmatively consented to the receipt of the communications, and (ii) the communications are necessary for IPL’s “legitimate interests” that are not overridden by your interests or fundamental rights and freedoms that require protection of personal data.

    9. The right to have IPL appoint a Data Protection Officer (“DPO”) to manage IPL’s compliance with GDPR and to respond within 72 hours to any inquiries, complaints, or requests that you make regarding your personal data. At any time, you may contact our DPO at privacy@personalleadership.com.

    10. As required by GDPR, our authorized subscribers have affirmatively and voluntarily “opted in” pursuant to GDPR requirements to receive newsletters, emails, and marketing communications from IPL. If you believe that you did not opt in to receive these communications from IPL, please contact our DPO as soon as possible at privacy@personalleadership.com.

We will arrange for you to either affirmatively opt in or not receive any further communications from us. Additionally, all of our newsletters, emails to subscribers, and other related communications contain an opt-out (unsubscribe) button at the bottom. At any time, you may unsubscribe from all IPL communications by clicking on the button.

We take your personal data and privacy seriously. If you have any questions regarding your rights, your personal data, or IPL’s obligations, please contact IPL’s Data Protection Officer at privacy@personalleadership.com.

Your rights under GDPR are further described below in Section 11. Some of your rights described in this policy may be subject to certain rights of IPL such as legal, accounting, and archiving requirements.

For more details regarding your rights and IPL’s obligations under GDPR, this Wikipedia article offers a good summary: https://en.wikipedia.org/wiki/General_Data_Protection_Regulation.

Detailed information regarding GDPR and related legislation and directives, may be viewed at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en.

Controller

When we mention "IPL", "we", "us" or "our" in this privacy policy, we are referring to IPL, the company that is responsible for processing your data. For individuals located in the European Economic Area, IPL is the data controller, as that term is defined under the GDPR.

Contact details

IPL’s Data Protection Officer (“DPO”) is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise any rights that may be afforded to you, please contact the DPO at privacy@personalleadership.com or using the details set out below:

    Institute for Personal Leadership LLC

    Attention: Legal Department

    170 West 81st Street, Ste. 8D

    New York NY 10024

The Mentora® App

The Mentora educational app, platform, content, services, and intellectual property (collectively, “Mentora”) are owned by IPL. 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. 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 GDPR and the best practices of educational organizations utilizing inventions and applications with mobile devices. This privacy policy applies 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.



2. The Information We Collect About You.

Information We Collect Automatically

When you visit our website or app, our servers automatically collect certain browser or device generated information, which may in some cases constitute personal data, including but not limited to:

  • your domain;
  • your IP address;
  • your date, time and duration of your visit;
  • your browser type;
  • your operating system;
  • your page visits;
  • information from third parties;
  • other information about your computer or device;
  • Internet traffic.

Information You Provide

In order to access or use certain portions of IPL’s website, Mentora® app, or other IPL portals, or otherwise conduct business with us, you may be prompted to provide certain personal data to us in the following ways:

  • by filling in forms (for example, a 'Contact us' form) on our website or at a trade show or anywhere else we conduct business;
  • by downloading materials from our website or Mentora app;
  • by subscribing to newsletters or other communications;
  • by corresponding with us by phone, e-mail or otherwise using our contact details;
  • by registering or participating in IPL webcasts, webinars or seminars/classes/conferences;
  • by submitting questions or comments to us or requesting any other information from us; or
  • by submitting selfie videos and other information through our Mentora app.

Typically, the personal data you give us may include name, business affiliation, business address, telephone number, and email address, and any personal details required to resolve any inquiries or complaints. With respect to the Mentora app, your personal data may include videos that you shoot of yourself, and information that you supply, and upload to the Mentora servers as part of how the app is designed to be used.

Personal data may also be required to enter into an agreement with you or to perform an agreement with you (such as to provide services at your request), and failure to provide any information may result in our inability to provide requested services or products.

Mentora - Videos and information you submit.

When you use our Mentora app, you record your video responses to role-play challenges and provide other information. The videos you record of yourself and some of the information you provide is considered personal data. Your videos and other information are uploaded to secure third-party servers in the United States maintained by Kaltura and Microsoft Azure in accordance with the highest security standards. Your videos and information are then viewed by your peers and supervisors to give feedback and in turn, you view videos and information of your peers and give them feedback. We will use your video responses and information 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.

As part of how Mentora is used, IPL and the other participants in your program will have access to your videos and information. Also, if you are using Mentora as part of a program your employer has authorized, your employer may have access to your videos and information. Subject to GDPR and other data privacy laws, your videos and other personal data submitted through Mentora will be temporarily owned, stored and managed by IPL in the US solely for purposes operating Mentora, and it will be archived or deleted in accordance with this Privacy Policy. 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. If there is any of your personal data that you do not want IPL to use in this way, please do not submit it.

Third-Party Servers.

IPL relies on trustworthy third-party vendors located in the United States 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 Mentora personal 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.

The personal data you submit to us through our Contact Us page and email sign-ups on our website is stored and processed at www.mailchimp.com in compliance with GDPR.

IPL may change what third-party data processors it uses. IPL will perform due diligence on any new processors that it uses, and make sure that they meet the highest quality of privacy and security standards, including GDPR.

Information From Other Sources

We may receive information about you if you use any of the other websites and portals we operate, any other services we provide, seminars or classes we teach, or from our business partners or data processors instructed to collect information on our behalf.

Cookies

Our website and Mentora app may use cookies. A cookie is a small file of letters and numbers that we put on your computer or smartphone if you agree. These cookies allow us to distinguish you from other users of our website and app, which helps us to provide you with a good experience when you browse our website or use our app, and also allows us to improve our site and our app. Read more about individual cookies we use and how to recognize them by reviewing our Cookie Policy, by clicking here.



3. Use of Personal Data.

The following is an overview of our purposes for using your personal data. Additional details on how we process your personal data may be provided to you in a separate notice or agreement.

All processing and use of your personal data is justified by a "condition" for processing. In the majority of cases, processing will be justified on the basis that:

  • you have consented to the processing;
  • the processing is in our legitimate interests that are not overridden by your interests and fundamental rights; our legitimate interests are to use supplier, customer, website and app user data to conduct and develop our business activities with them and with others while limiting the use of their personal data to purposes that support the conduct and development of our business;
  • the processing is necessary to perform an agreement with you or take steps to enter into an agreement at your request, such as to fulfil an order, or to provide product information you have requested; or
  • the processing is necessary for us to comply with a relevant legal obligation, such as keeping accounting, legal, and archival records;

We use the personal data we collect to conduct and develop our business with you and with others, as more fully described below:

  • provide you with any services or products you have contracted for;
  • administer and manage performance of purchase or sales agreements with our suppliers and customers;
  • provide after-sales support;
  • process, evaluate and complete certain transactions involving the website, the Mentora app, and more generally transactions involving IPL's products and services;
  • operate, evaluate, maintain, improve and develop the website and Mentora app (including by monitoring and analyzing trends, access to, and use of the website for advertising and marketing, and analyzing how our app is functioning and delivering results);
  • evaluate, improve and develop our products and services generally;
  • customize our website and Mentora app to users' needs;
  • engage you about events, promotions, the website, the Mentora app, and IPL's products and services;
  • provide you with documentation or communications which you have requested or which we believe you would be interested in;
  • correspond with users to resolve their queries or complaints;
  • send you marketing communications, where it is lawful for us to do so;
  • protect and ensure safety of the website, the Mentora app, IPL confidential and proprietary information, and IPL employees;
  • manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our agreements or laws or regulations;
  • share your personal data with third parties in connection with potential or actual sale of our company or any of our assets, in which case personal data held by us about our users may be one of the transferred assets;

IPL will not sell or rent your personal data to third parties.



4. Disclosure of Personal Data.

IPL will share personal data with its appointed third-party service providers (who will operate under our instructions) to assist us in providing information, products or services to you, in conducting and managing our business, or in managing and improving our products, services, the website, or our Mentora app. IPL may share your personal data with these affiliates and third parties to perform services that the third parties have been engaged by IPL to perform on IPL's behalf, subject to appropriate contractual restrictions and security measures, or if we believe it is reasonably necessary to prevent harm or loss, or if we believe that the disclosure will further an investigation of suspected or actual illegal activities.

We are also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We may be required to disclose personal information that we handle in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If your personal data is transferred outside the EU to IPL or its third-party service providers, we will take steps to ensure that your personal data receives the same level of protection as if it remained within the EU, including by assuring that IPL and its service providers have entered into data transfer agreements using the European Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield. For transfers of personal data among IPL and its service providers we will make sure that the service providers have in place European Commission approved Standard Contractual Clauses. The list of all the countries to which your personal data is transferred is set forth here: United States and India. Be advised that upon information and belief, neither of these countries has currently received a decision of the European Commission determining that its laws provide adequate protection to personal data. You have a right to obtain details of the mechanism under which your personal data is transferred outside of the EU by contacting privacy@personalleadership.com.

IPL reserves the right to share any information that you provide which is not deemed personal data or is not otherwise subject to contractual restrictions.



5. EU-U.S. and Swiss-U.S. Privacy Shield

IPL, although not a member, complies with the data protection principles of the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union member countries and Switzerland. IPL adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, and access. To learn more about the Privacy Shield principles, please visit https://www.privacyshield.gov/.

In accordance with the Privacy Shield Principles, IPL commits to resolve complaints about your privacy and our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding this Privacy Shield Policy or IPL’s Privacy Policy should first contact IPL at: privacy@personalleadership.com.

IPL conducts in-house verifications to ensure that its attestations and assertions with regard to its treatment of personal data are accurate and that the company has appropriately implemented these practices.



6. Children

The website is not for use by children under the age of 16 years and IPL does not knowingly collect, store, share or use the personal data of children under 16 years. If you are under the age of 16 years, please do not provide any personal data, even if prompted by the website to do so. If you are under the age of 16 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify IPL and IPL will delete all such personal data.



7. Marketing emails.

Where lawful to do so, and subject to your consent where required, we may communicate with you by email to tell you about our products and services. If you wish to opt-out of receiving marketing communications, please use the 'unsubscribe' link provided in our emails, or otherwise contact us directly and we will stop sending you communications.



8. Security.

IPL aims to safeguard and protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and IPL utilizes and maintains certain reasonable processes, systems, and technologies to do so. However, you acknowledge that no transmission over the Internet is completely secure or error-free, and that these processes, systems, and technologies utilized and maintained by IPL are subject to compromise. Accordingly, we cannot be held responsible for unauthorized or unintended access that is beyond our control.



9. Retention of Your Personal Data.

We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. In general, we retain your personal data for a period of time corresponding to a statute of limitation, for example to maintain an accurate record of your dealings with us.

However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.



10. External Links.

The website may contain links to third party sites. Since IPL does not control nor is responsible for the privacy practices of those websites, we encourage you to review the privacy policies of these third-party sites. This policy applies solely to personal data collected by our website or Mentora app, or in the course of our business activities.



11. Your Rights.

Under applicable law, you may have the following rights:

  • 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.
  • 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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.

For further information regarding your data privacy rights under GDPR, please see the following link: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

Your California Privacy Rights.

For California residents only. We may disclose your personal information to our affiliates or other related third parties for their use in marketing to you. Pursuant to California’s “Shine the Light Act,” California residents are permitted to request information about the manner in which we share certain categories of information with third parties for their marketing use. Please send an email to privacy@personalleadership.com to request a copy of our disclosure pursuant to California law.



12. Dispute Resolution and Other Legal Matters

You may also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable law and IPL is subject to the jurisdiction of such supervisory authority.

Further, in accordance with the Privacy Shield Principles, IPL commits to promptly resolve complaints about privacy and our collection or use of personal information. Individuals with questions or concerns about the use of their personal data should contact us at: privacy@personalleadership.com and identify the company or other organization with whom they are affiliated or for whom their data was collected, if collection was for an IPL customer.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, we will have the matter submitted to our US-based third-party dispute resolution provider (free of charge).

Governing Law. By choosing to visit our website, use our Mentora app, or provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of New York and the United States of America. You also agree to abide by any limitation on damages contained in our Terms of Use, or other agreements that we have with you.

IPL’s Corporate Clients. You may be using this website or the Mentora app pursuant to an agreement between IPL and your employer. If there is a conflict between a provision of that agreement and this Privacy Policy, the provision of that agreement will prevail unless it is contrary to GDPR or other privacy laws.



13. Changes to this Policy

Any changes or updates we may make to this policy will be posted on this page. If we have your contact details on file we will endeavor to notify you in advance of any changes to this policy that are material or may impact you. For other changes, please check back frequently to see any updates or changes to this policy.