Privacy Policy of secure.mentoringcomplete.com
This Website collects some Personal Data from its Users.
Owner and Data Processor
Engagedly Inc.
911 Washington Avenue,
St. Louis, MO 63101
Owner contact email: privacy@engagedly.com
Among the types of Personal Data collected, by itself or through third parties, there are: Cookies and Usage Data.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. The Personal Data may be freely provided by the User, Data Controller or, in case of Usage Data, collected automatically when using this Website.
All Data requested by the Mentoring Complete web application is required and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences on the availability or the functioning of the Mentoring Complete product.
Users who are uncertain about which Personal Data is mandatory are welcome to contact Engagedly.
Any use of Cookies or of other tracking tools by this Website or by the owners of third-party services used by this Website serves the purpose of providing the service required by the User, in addition to any other purposes described in the present document.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Data Processor.
Mentoring Complete processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. Data may be collected for the Mentoring Complete Platform through the web application or Mobile Application. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
To use the Mobile Application, you will need to be an active user of the Mentoring Complete Platform with valid credentials. All data related to the Mobile Application is stored within the Mentoring Complete Platform Web Application. Users can perform a limited subset of actions using the Mentoring Complete Mobile Application. These features include:
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that Mentoring Complete suspend or remove the data.
The Data concerning the User is collected to allow the the Mentoring Complete web application to provide its designated features and functions.
The Personal Data used for each purpose is outlined in the specific sections of this document.
Personal Data is collected for the following purposes and using the following services:
This Website uses only Strictly Necessary Cookies.
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
| Name | Purpose | Description |
|---|---|---|
| ASP.NET_SessionId | Session | This cookie is automatically generated by ASP.NET. It is used to identify the users session on the server. The session being an area on the server which can be used to store data in between http requests. |
The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Website or the related services.
The User declares to be aware that Mentoring Complete may be required to reveal personal data upon request of public authorities.
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested any time. Please see the contact information at the beginning of this document.
Users have the right, at any time, to know whether their Personal Data has been stored and can consult Mentoring Complete to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be submitted through the Engagedly Data Subject Access Rights (DSAR) portal . If the Engagedly DSAR portal is unavailable requests can be sent to privacy@engagedly.com.
Mentoring Complete reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Website and can request that the Mentoring Complete remove their Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data Mentoring Complete has about Users.
Mentoring Complete Inc. is responsible for this privacy policy.
Important Notice to Non-U.S. Residents
We participate in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise. Engagedly has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.
If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Engagedly certification, please visit https://www.privacyshield.gov/ (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commerce https://www.privacyshield.gov/list).
Engagedly is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.
This, most importantly, includes the right of individuals to access their personal data processed by Engagedly.
Engagedly also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, the Engagedly is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.
Engagedly is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, Engagedly commits to resolve complaints about its collection or use of the User’s Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact Engagedly at the contact details supplied at the beginning of this document referring to “Privacy Shield” and expect the complaint to be dealt with within 45 days.
In case of failure by Engagedly to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.
In this regard, Engagedly has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint ) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Background: The new ‘California Consumer Protection Act’ (CCPA) came into effect in on January 1, 2020. The state law grants California consumer residents new rights over their personal information. These rights are, the right to know (or access), the right to delete, and the right to opt-out of sale of personal information that a company may collect, retain, or disclose about a consumer. Additionally, the CCPA prohibits businesses from discrimination against consumers in terms of access to services if they choose to exercise their rights under the CCPA.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | Yes Email address, full name, IP address, unique employee identifier. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | Yes Name, address, telephone number and employment details like title and history |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Yes Age, Ethnicity, Gender |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | No |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | No |
| G. Geolocation data. | Physical location or movements. | No |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | No |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | Yes Job History, Title |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | No |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | No |