PRIVACY POLICY

Personal data transferred from the European Economic Area (“EEA”) to the United States of America (“US”)
TRUSTe European Safe Harbor certification
 
1. Introduction:
Management Mentors, Inc. (“MM”) respects the privacy of its customers, business partners and employees and recognizes the need for appropriate protection and management of personal information provided. MM on behalf of itself and its clients has made a decision to voluntarily participate in the Safe Harbor principles available to US organizations under the European Commission’s directive on data protection. Should there be any conflict between the Safe Harbor principles and this Privacy policy (“Policy”), the Safe Harbor principles will prevail. This policy outlines the general practices for implementing the requirements of Safe Harbor in connection with personal data that is transferred from the EEA to the U.S.; including the types of information that is collected and transferred; how it is used; and, the choices individuals located in the EEA have regarding the use of, and their ability to correct, that information.

MM complies with the U.S.-E.U. Safe Harbor framework and the U.S.-Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union and Switzerland respectively. Information regarding the both the E.U. and Swiss Safe Harbor Frameworks can be found at: http://export.gov/safeharbor
 
2. Scope:
This Privacy Policy applies to all MM operations, divisions, subsidiaries as far as personal information from the EEA is collected, received or stored on our Site. This Privacy statement applies to the Site www.mentoringcomplete.com This Policy applies to Agents (defined below that handle and process EEA personal data on behalf of MM. MM respects your privacy and has created this Privacy Statement in order to demonstrate our commitment to consumer privacy. We have established this Statement as a means to communicate our information gathering and dissemination practices to our customers and visitors. This online Privacy Statement describes how we use, disclose and protect personal information that you share with us. By using this Site, you agree to this Privacy Policy. Management Mentors Inc. has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at rpetrin@management-mentors.com. If you are not satisfied with our response you can contact TRUSTe here.
 
3. Definitions:
For purposes of this Policy, the following definitions shall apply: “Agent” means any third party that collects and/or uses personal information provided by MM to perform tasks on behalf and under the instructions of MM. “Personal information” means any information relating to an identified or identifiable person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to information such as name, email address or phone information. Personal information does not include information that is anonymous and/or statistical. “Sensitive personal information” means that personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or that concerns health matters, financial or sexual orientation.
 
4. Processing of EEA personal data:

MM may from time to time processes certain EEA personal information about client and client employees including information recoded on various media as well as electronic data. MM has online mentoring systems that also collect data on each participant for the purpose of achieving mentoring objectives by the client user. Information gathered consists of: name, email, phone number, job title, date of hire, location, gender, ethnicity and other filters that clients may opt to add into the system for their mentoring program matching purposes. This information is available only to the individual, the client’s program manager, Management Mentors (owner of MentoringComplete), the tech support team and the hosting team. None of this information is used for marketing purposes or shared with third parties for marketing purposes. MM will use personal information concerning its clients to provide the services necessary to accomplish the purposes of the mentoring contract. MM licenses the client to create accounts which allow client employees to access the system for purposes of entering into a mentoring relationship. MM uses this information to better understand the needs of the client in utilizing a mentoring system and achieving the objectives of a client’s mentoring program. Occasionally, and with permission from the client, MM may contact users to obtain feedback on the system in order to ascertain needs and preferences for those using such a system, as well as send you newsletters with updates and news about our Site. We don’t share this personal information with third parties for their promotional purposes. MM may also share personal information with its service providers and suppliers for the sole purpose and only to the extent needed to support a client or clients’ mentoring needs. Service providers and suppliers are required to keep confidential personal information received from MM and may not use it for any purpose other than as originally intended. Service providers consists of the tech team who need access to system information to resolve technical issues that arise and the hosting team that hosts all data onto their servers

 
5. Privacy Principles:
When MM collects personal information directly from individuals in the EEA, it will inform those individuals about the purposes for which it collects and uses personal information about them; the types of non-agent third parties to which MM discloses that information; and the choices and means, if any, MM offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to MM, or as soon as practicable thereafter, and in any event before MM uses the information for a purpose other than that for which it was originally collected. We collect your name, email address and physical address as well as your phone number when you request a demo from us to view how the program works. We use this information to contact you with further details on our program and store the information in our database prior to allowing you to download your presentation. None of this personal information you submit is used for any other purpose short of providing you the information you’ve requested from MM regarding our program.
 
6. Choice:
By using the Site, you express consent to receive information regarding your mentoring system, facilitated by our Site. Given that these messages are not promotional in nature, you generally cannot opt-out of them. If you change your mind about receiving our newsletters, you can unsubscribe by selecting the “unsubscribe” link present in every newsletter email we send.
 
7. Onward Transfer to Agents:
MM will obtain assurances from its Agents that they will safeguard personal information consistent with this Policy. Examples of appropriate assurances that may be provided by Agents include: a written contract obligating the Agent to provide at least the same level of protection as is required by the relevant Safe Harbor principles, being subject to EU Data Protection Directive 05/46, Safe Harbor certification by the Agent, or being subject to another European Commission adequacy finding. Where MM has knowledge that an Agent is using or disclosing personal information in a manner contrary to this Policy, MM will take reasonable steps to prevent or stop the use or disclosure. Once notified of the disclosure, MM will contact the Agent within 24 hours to verify this violation and take decisive action. This could mean replacing the Agent within the service provider system or replacing the service provider entirely depending on the nature of the violation. MM does not share your personal information with any third parties for their promotional purposes or otherwise.
 
8. Access:
Upon request, MM will grant individuals access to personal information that it holds about them. In addition, MM will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. In the case of MM’s online system, users have access to all their personal information at all times so can easily make corrections without further assistance from MM by using your username and password to access your account and update your information. You can expect a response within 30 days to your inquiry.
 
9. Security:
MM will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.We employ industry accepted standards in protecting your information on our Site. We employ Secure Socket Layer technology {SSL} to protect the information you submit on our Site. We also limit the accessibility to your information to only those employees who need access to perform their job tasks.
 
10. Data Integrity:
MM will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. MM will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.We will retain your information for as long as your account is active or as needed to provide you services. Please contact us if you wish to cancel your account or request that we no longer use your information to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
 
11. Enforcement:

MM utilizes the self-assessment approach to assure its compliance with this Privacy Policy. MM periodically verifies that this Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Safe Harbor principles. MM encourages interested persons to raise any concerns with it using the contact information below. MM will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles in this Policy. If MM determines that any person in its employee is in violation of this Privacy Policy such person will be subject to disciplinary action.

 
12. Dispute Resolution:

Any questions or concerns regarding the use or disclosure of personal information should be directed to the Compliance Officer at the address given below. MM will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of personal information in accordance with the principles contained in this Policy.
 
13. Targeting Minors:
MM does not knowingly collect personally identifiable information from persons under the age of 13. If for some reason MM determines that a person with respect to whom it has collected personal information is under 13, MM will promptly delete or destroy that information. Cookies: When you interact with the Site, we try to make that experience simple and meaningful. When you visit our Site, our Web server sends a cookie to your computer. Cookies are files that Web browsers place on a computer's hard drive and are used to indicate whether you have visited the Site previously. Choices about Cookies: You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.) If you reject all cookies, you will not be able to use services that require you to "sign in," and you may not be able to take full advantage of all offerings. Our Practices Regarding Cookies: MM uses cookies for a number of purposes, including to: access your account information when you "sign in," so that we can provide you with customized content; keep track of preferences you specify while you are using MM services; estimate and report our total audience size and traffic; and conduct research to improve MM’s content and services. Third Party Cookies: We may from time to time engage third parties to track and analyze non-personally identifiable usage and volume statistical information from visitors to our Site to help us administer our Site and improve its quality. Such third parties may use cookies to help track visitor behavior. Such cookies will not be used to associate individual website visitors to any personally identifiable information. Third-Party Sites: The Site contains links to other web sites. Management Mentors Inc. is not responsible for the privacy practices or the content of these other web sites. Customers and visitors will need to refer to the privacy statements of these others web sites to understand their information practices. We encourage our users to exercise discretion in sharing their information with other Sites. Legal Disclosure In the event of a sale, acquisition or merger of some or all of MM’s assets, your personal information would likely be amongst the transferred assets. In such an event, we shall notify you of the change and your choices regarding how your information is to be used henceforth by email. We may be legally obligated to disclose information to the government or to third parties under certain circumstances, such as illegal activity on our Site. MM reserves the right to release personal information to its service providers, law enforcement or other government officials or in response to a formal request in a civil action, Court order or judicial proceeding as MM, in our sole and absolute discretion, deems necessary or appropriate.
 
14. Contact information:

Complaints, Questions or comments regarding this Policy should be submitted to MM by mail or email to the following: Mr. Rene D. Petrin, Compliance Officer for Safe Harbor at Management Mentors, Inc., located at 111 Nonantum Street, Brighton, MA 02135, USA.PO Box 67291, or at rpetrin@management-mentors.com. In your letter, please describe in as much detail as possible the ways in which you believe that the Privacy Policy has not been complied with or what your specific concerns are regarding the Site and or Privacy Statement. We will investigate your complaint promptly and respond to your inquiry within 30 days of receiving it.

 
15. Changes to this Policy:
We reserve the right to review this privacy statement from time to time; please review it regularly to stay up to date on any changes we make. In the event that we make a material change in the manner we collect or use your personal information, we shall notify you by means of a prominent notice on our site as well as via email. Effective Date: February 23rd, 2009