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MicroMentor Privacy Policy

Effective Date: May 25, 2018 (View the prior version)

1. About this document

  1. MicroMentor's Privacy Policy explains how we collect, use, store and share the personal information you decide to share and will help you make informed decisions when accessing or using the MicroMentor website, located at www.micromentor.org, or any successor websites, including any and all international and mobile versions thereof (collectively, the "Website").
  2. By registering with MicroMentor, using or accessing the Website, you are agreeing to the practices described in this Privacy Policy. Your use of the Website is also subject to the MicroMentor Code of Conduct and Terms of Use. If you do not agree with these policies, do not access or use our Services or interact with any other aspect of our business.
  3. If you have questions or concerns regarding this statement, you should contact our staff at support@micromentor.org.

2. MicroMentor’s Privacy Principles

  1. MicroMentor operates as a non-profit, social impact organization. We are powered by volunteer mentors who care deeply, a community based on mutual trust, and the belief that a better world is possible.
  2. We will never sell or rent your data to third parties.
  3. Your profile information is public.
  4. Other information that you provide to MicroMentor is confidential.
  5. Your conversations with others in the MicroMentor community are confidential. It is also your responsibility to help us keep it that way.
  6. General information about your activity on the site helps us to do our job.
  7. We only share data with trusted partners in order to: improve our service, to measure our impact, and identify misuse, and to respond to your requests.
  8. If you join MicroMentor through your employer or other organization, some information about your activity will be shared with them.
  9. You can control how we communicate with you.
  10. You have rights to the information that we request or have collected about you.
  11. You can ask to be removed from the community.
  12. We are based in the United States, and data is transferred and held securely within US-based data centers. When our global operations require us to transfer information to other countries we utilize appropriate safeguards
  13. You can contact us at any time at support@micromentor.org

3. About Us

  1. MicroMentor is an initiative of Mercy Corps, a non-profit, humanitarian agency ("MicroMentor"). MicroMentor's mission is to help small businesses grow faster and employ more people by making it easy to be a mentor, find a mentor, and build a business.
  2. Our contact information is as follows:

    Mercy Corps - MicroMentor
    Dept. W
    PO Box 2669
    Portland, OR 97208-2669
    Email: support@micromentor.org
    Phone: 503-465-4181

  3. If you have joined MicroMentor through your employer or other organization, you may be subject to their policies and procedures regarding privacy and acceptable use of this website. Please contact your program administrator for more details.

4. Information we collect about you

  1. Information you provide to us
    1. Registration information
      • When you register with MicroMentor and create a user profile to participate in MicroMentor's programs, you provide us with certain personal and business information, such as your name, your email address, your telephone number, your postal code, your group or company affiliations, and your password.
      • MicroMentor also collects other contact, demographic and business information in order to provide a mentor matching service to facilitate virtual mentoring, to provide other services provided by MicroMentor and as otherwise described in this Privacy Policy.
    2. Your public profile
      • If you choose to create an entrepreneur profile on MicroMentor, certain profile information will be collected by the Website. This may include your name, business name, primary industry, business website, start date of business, general business description, business street address, annual business revenue, number of employees, household size, household income, and additional information you provide when you register with MicroMentor.
      • If you choose to create a mentor profile on MicroMentor, certain profile information will be collected by the Website. This may include your name, city of residence, position or title, company name, industry, areas of expertise, a description of business expertise, years of ownership experience, years of management experience, and additional information you provide when you register with MicroMentor.
    3. Surveys and business details
      • In order to demonstrate our global impact and improve our services to entrepreneurs, we may ask you for private information about you or your business. When we do, we will:
        • Give you choices about what to share
        • Inform you about what information we are collecting, why we need it, and how it will be used
        • Keep the information secure and confidential
        • MicroMentor collects demographic information including, but not limited to, your birth year, gender, ethnicity, country of origin, language(s) spoken, any disabilities the mentor or mentee has, and any other personal or preference information that you provide to us.
      • From time-to-time, we request information from users via surveys. The requested information may include contact information (such as name and email address) or may be linked to your MicroMentor account that already holds this information. Contact information may be used to follow up on the survey.
    4. Your interactions with other users
      • By sending communications to other users (including, but not limited to, mentor/mentee requests, messages, and participation in public forums), you consent to MicroMentor storing the conversations you have with other users on its servers owned or controlled by us. You understand that even if you delete a conversation you have with another user, that user may also be able to save it. You further agree that we may retain, use, and scan copies of your conversations for a limited time solely to filter spam, detect viruses, test and improve our messaging services, and to deliver personalized features to you.
    5. Referring your friends & colleagues
      • If you choose to use our referral service to tell a friend about our Website, we will ask you for information needed to send the invitation, such as your friend's email address. We will send your friend an email with your name listed in the invitation inviting him or her to visit the site. MicroMentor stores this information to send invitations, to allow you to see invitations or referrals you have sent, and to track the success of our referral program. Your friend may contact us at support@micromentor.org to request that we remove this information from our database.
    6. Customer support
      • We use your information to resolve technical issues you encounter, to respond to your requests for assistance, and to repair and improve the services.
    7. Participation in events
      • If you have participated in an in-person mentoring event sponsored by MicroMentor, we will use information about your attendance, experience, and your contact information in order to communicate with you about future events and to provide you with access to the MicroMentor website and related services.
  2. Information we receive from other sources
    1. Other users
      • Messages, endorsements and feedback
        • MicroMentor may collect or request information about you from other users you have interacted with. This may include messages they exchanged with you, feedback on your conversations, ratings, or endorsements. We also collect negative feedback such as when there may be evidence of spam, solicitation, or fraud.
      • References
        • MicroMentor occasionally asks participants to submit references to us before being accepted into the program. MicroMentor stores this information for the sole purpose of conducting reference checks. The reference may contact MicroMentor at support@micromentor.org to request the removal of this information from our database.
    2. Other services you link to your account
      • We receive information about you when you link a third-party service with our services. For example, if you create an account or log into MicroMentor using your Facebook, Google, or LinkedIn credentials, we receive your contact details as permitted by your profile settings for those services in order to authenticate you. You may also integrate our services with other services you use, such as to allow you to access, store, share and edit certain content from a third-party through our services. For example, you may authorize our services to access, display and store files from a third-party document-sharing service. Or you may authorize our services to connect with a third-party calendaring service so that your meetings and connections are available to you through the services. You may authorize our services to sync a contact list or address book so that you can easily connect with those contacts within the services or invite them to collaborate with you on our services. The information we receive when you link or integrate our services with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared with our services.
    3. Your company or member organization
      • If, when you register with MicroMentor, you identify yourself as a member of a group or corporation that is affiliated with or has a relationship with MicroMentor, MicroMentor may receive additional information from that organization in order to improve the services that we provide to you.
  3. Information we collect automatically when you use our service
    1. Device and web browsing data
      • When you access the Website, we collect your IP address, browser type, internet service provider (ISP), referring/exit pages, platform and device type, date/time stamp, and number of clicks. This information is gathered for all Website users.
      • We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience.
      • How much of this information we collect depends on the type and settings of the device you use to access the Services.
    2. Cookies, Web Beacons, and Other Similar Technologies
      • We collect and store certain information from your browser using "cookies." A cookie is a piece of data stored on the user's computer tied to information about the user. We use cookies to confirm that users are logged in and to track their usage of the site. Cookies do not contain personally identifiable information. These cookies terminate once the user closes their browser or once they expire.

5. How we use information we collect

  1. To provide services and personalize your experience
    • To match you with either a mentor or a mentee. Once a match is made or you connect with another user, your name and the URL of your public MicroMentor profile and associated content will be supplied to the person you have been matched with.
  2. For research and development
    • To improve our services
      • To evaluate and improve the MicroMentor services and the Website and offer personalized features.
    • For Impact measurement
      • We will also use non-identifiable, aggregate information to guide our program efforts and report to funders, stakeholders and external partners.
  3. To communicate with you about the service
    • To communicate with you regarding our services, the mentoring process, and upcoming MicroMentor events or initiatives.
    • MicroMentor may send you service-related announcements from time to time through the general operation of the service. For instance, if you receive a mentoring request or an offer for mentoring advice, you may receive an email or other message alerting you to that fact.
  4. To market and promote the service
    • With your explicit permission, we may use your personal details to promote MicroMentor. You will be contacted before any release of such information for MicroMentor's promotional purposes, and you may withdraw any permission that you may grant at any time.
  5. For customer support
    • We communicate with users to provide requested services and in regards to issues relating to their account. We reply via email, regular mail or phone, depending on the nature of the communication.
  6. For safety and security
    • We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
  7. With your consent
    • We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote MicroMentor, or display photographs of you from a MicroMentor event, with your permission. In such instances, terms and conditions for the collection and use of information will be stated separately and made explicit to respondents in advance of data collection.
  8. Legal bases for processing (EEA users)
    • If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
      • We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
      • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
      • You give us consent to do so for a specific purpose; or
      • We need to process your data to comply with a legal obligation.
    • If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

6. How we share information we collect

  1. Sharing with other MicroMentor users
    1. Your public profile and business information
      • If you choose to create a profile on MicroMentor, certain profile information will be collected and displayed publicly on the Website. This will include your name, the city and state where you live, and your membership with a group or company.
      • If you choose to create an entrepreneur profile on MicroMentor, certain profile information will be collected and displayed publicly on the Website. This may include your name, city of residence, membership with a group or company, a photograph you provide, business name, industry, business website, start date of business, general business description, and additional information you provide when you register with MicroMentor.
      • If you choose to create a mentor profile on MicroMentor, certain profile information will be collected and displayed publicly on the Website. This may include your name, city of residence, a photograph you provide, your position or title, company name, industry, areas of expertise, a description of business expertise, years of ownership experience, years of management experience, and additional information you provide when you register with MicroMentor.
    2. Your interactions with other users on the site
      • When you use the Website, certain information you post or share, such as answers to questions, messages, photos or other information, may be shared with other users. All such sharing of information is done at your own risk. Please keep in mind that if you disclose personal information in your profile or when posting comments, messages, photos or other items, this information may become publicly available.
    3. Your member organization
      • If, when you register with MicroMentor, you identify yourself as a member of a group or corporation that is affiliated with or has a relationship with MicroMentor, MicroMentor may provide that group or corporation with individual non-anonymous reports, that may include any or all of your profile data, detailing your use of the Website and any feedback you or your matches have reported to MicroMentor regarding your mentoring relationships and business outcomes. The group or company may use this information for the purposes of facilitating the MicroMentor program, measuring the activity and evaluating the outcomes of their participants in MicroMentor, and promoting MicroMentor and the services the organization provides to its members.
  2. Sharing with third parties
    1. To provide services
      • MicroMentor may provide information to certain third party companies which we may contract to perform services to you on our behalf. These services may include postal and e-mail delivery, customer relationship management, customer service, development and research, data analysis, fraud protection, and payment processing (e.g., through PayPal or a similar service which collects and processes donations on our behalf). The third parties we contract with for the provision of these services will be permitted to obtain only such personal information as they require to deliver the services and only use such information for their provision of the applicable services to us.
      • Also, profile information you submit to MicroMentor may be made available to third party search engines. This is primarily so potential mentors or mentees can find you and send a mentor request or an offer for mentoring advice. People who see your name in searches will be able to access your profile information by clicking on your name or profile picture thumbnail.
      • MicroMentor may provide information in your profile without identifying you as an individual to third parties. We may do this for purposes such as personalizing advertisements and promotions.
      • Though we may use an intermediary to conduct user surveys, they may not use users' personally identifiable information for any secondary purposes.
    2. To promote volunteer and mentoring opportunities
      • In order to promote and notify prospective users of the volunteer opportunities available on the Website, as well as mentoring opportunities, some features of your profile may be exported to Third Party Sites that promote small business development and/or volunteerism, and social networks that cater to small business owners and business professionals. Such features that may be exported to and displayed on such Third Party Sites include but are not limited to your name, picture, industry, business name, experience needed, city and state of business, mentoring request summary, mentoring request expertise, profile URL and mentoring request URL.
    3. With your consent
      • Additional information gathered by surveys or other means is not shared with third parties unless we give prior notice and choice.
      • With your explicit permission, MicroMentor may use your details, including name, likeness, and biographical information, in connection with highlighting successes of the MicroMentor programs. You will be contacted before release of this information and may withdraw this permission at any time. You agree that any content you provide to us in connection with the foregoing is covered by the license to your content set forth in the Terms of Use.
    4. Impact reporting
      • MicroMentor may provide reports containing aggregated, anonymous information to third party entities including but not limited to groups, companies or organizations that MicroMentor may have a relationship with.
    5. Legal disclosures & compliance
      • We may be required to disclose user information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we may share account or other information when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through MicroMentor or using the MicroMentor name, or to prevent threats to the physical safety of any person or violation of the Terms of Use or Code of Conduct. This may include sharing information with other companies, lawyers, agents or government agencies.
  3. Sharing with affiliated companies
    1. Mercy Corps
      • MicroMentor is a program of Mercy Corps and Mercy Corps Europe.
    2. Change in control
      • If the ownership of all or substantially all of MicroMentor or the Website were to change, your information may be transferred to the new owner so the Website can continue operations. In any such transfer of information, your user information would remain subject to the promises made in any pre-existing Privacy Policy.

7. How we store and secure information we collect

  1. Information storage and security
    • This Website takes technical and other precautions to protect our users' information. If you have questions about the security of the Website, please contact our support staff at support@micromentor.org. Unless otherwise stated in this Privacy Policy, only employees and independent contractors operating on MicroMentor's behalf who need the information to perform a specific job (for example, a customer service representative) are granted access to personally identifiable information. You agree to maintain the security of your password and identification.
    • You post User Content (as defined in the MicroMentor Terms of Use) on the Site at your own risk. Please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users. We are not responsible for unauthorized circumvention of any security measures contained on the Website. You understand and acknowledge that, even after removal, copies of User Content may remain viewable in cached and archived pages or if other users have copied or stored your User Content.
  2. How long we keep information
    • How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
    1. Account information
      • We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
    2. Information you share on MicroMentor
      • If your account is deactivated or disabled, some of your information and the content you have provided will remain in order for other users to make full use of the Services. For example, we continue to display messages you sent to the users that received them and continue to display content you provided.
    3. Managed accounts
      • If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account. For more information, see “Your member organization” above.
    4. Marketing information
      • If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your MicroMentor account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

8. How to access and control your information

  1. Your choices
    • You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. Where the Services are administered for you by an administrator (see "Notice to End Users" below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
    • Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
  2. Access and update your information
    • Our Services and related documentation give you the ability to access and update certain information about you from within the Service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
  3. Deactivate your account
    • To deactivate your account on the Website, send an email to support@micromentor.org with "Deactivate" in the subject line.
  4. Delete your information
    • Our Services and related documentation give you the ability to delete certain information about you from within the Service. For example you can remove certain profile information within your profile settings. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
  5. Request that we stop using your information
    • In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable).
  6. Opt out of communications
    • Users will occasionally receive information on MicroMentor services, messages regarding participation in MicroMentor, and newsletters. Users cannot opt out of certain communications that are necessary for them to receive in order to participate in MicroMentor. Users who have deactivated their accounts can opt-out of these mailings.
    • By registering or otherwise agreeing, users agree to receiving communications from MicroMentor. Users may 'opt-out' of receiving further marketing communications by replying to support@micromentor.org with "Unsubscribe" in the subject line. There may be up to a seven-day delay in manually processed requests.
  7. Opt out of cookies and related technologies
    • To opt-out of our use of cookies, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our services. MicroMentor and our third party partners also collect information using web beacons (also known as "tracking pixels").
    • Many browsers include their own management tools for removing HTML5 local storage objects. To manage "flash cookies" please click here.
    • You will not be able to opt-out of any cookies or other technologies that are “strictly necessary” for the services.
  8. Data portability
    • If you require data from your account in a machine-readable format, you may send your request to support@micromentor.org. When you make such requests, we may need time to investigate and facilitate your request.

9. How we transfer information we collect internationally

  1. International transfers of information we collect
    • By using MicroMentor, you are consenting to have your personal data transferred to and processed in the United States. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the services. Whenever we transfer your information, we take steps to protect it.
  2. International transfers within Mercy Corps offices
    • To facilitate our global operations, we transfer information to the United States and allow access to that information from countries in which the Mercy Corps has operations for the purposes described in this policy.
  3. International transfers to third parties
    • Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information to third parties, we make use of standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.

10. Other important privacy information

  1. Notice to end users
    • Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the accounts and/or sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization's policies. We are not responsible for the privacy or security practices of an administrator's organization, which may be different than this policy.
    • Administrators are able to:
      • require you to reset your account password;
      • restrict, suspend or terminate your access to the Services;
      • access information in and about your account;
      • access or retain information stored as part of your account;
    • In some cases, administrators can also:
      • restrict, suspend or terminate your account access;
      • change the email address associated with your account;
      • change your information, including profile information;
      • restrict your ability to edit, restrict, modify or delete information
    • Even if the Services are not currently administered to you by an organization, if you use an email address provided by an organization (such as your work email address) to access the Services, then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date.
    • If you do not want an administrator to be able to assert control over your account or use of the Services, use your personal email address to register for or access the Services. If an administrator has not already asserted control over your account or access to the Services, you can update the email address associated with your account through your account settings in your profile. Once an administrator asserts control over your account or use of the Services, you will no longer be able to change the email address associated with your account without administrator approval.
    • Please contact your organization or refer to your administrator’s organizational policies for more information.
  2. Your privacy and confidentiality obligations
    • In accordance with MicroMentor’s Code of Conduct and Terms of Use, you have obligations to the MicroMentor community regarding collecting and sharing information that is available on the site or with you directly through a mentoring relationship. Users in violation of these terms may have their profiles deactivated and/or be reported to relevant authorities.
  3. Links to third party sites
    • This Website contains links to other sites. Please be aware that MicroMentor is not responsible for the privacy or other practices of such other sites. We encourage our users to be aware when they leave our Website and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this Website.
  4. Our policy towards children
    • The services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact support@micromentor.org.
  5. Changes to our Privacy Policy
    • If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Changes we deem to be material will be communicated via an email alert to the email address you provided when registering your account.
    • If, however, we are going to use users' personally identifiable information (i.e. name) in a manner different from that stated at the time of collection, we will notify users via email. Users will have a choice as to whether or not we use their personal information in this different manner. However, if users have opted out of all communications, or deleted/deactivated their account, then they will not be contacted, nor will their personal information be used in this new manner.
  6. Contact us
    • Our contact information is as follows:

      Mercy Corps - MicroMentor
      Dept. W
      PO Box 2669
      Portland, OR 97208-2669
      Phone: 503-465-4181