Revised: February 10, 2020
This Policy applies only to information we collect, process and use through the Platform. This Policy does not apply to information that we collect through other channels, such as information that we collect offline, from other websites or from emails you send us.
For the purposes of this Policy, “Mento,” “we,” or “us”shall mean Brella Adventures Inc., a Delaware corporation.
Information We Collect
We collect information about you to provide our services. In order for us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. This means that the data collection is largely necessary for fulfilling the relationship we have with you, and where that is not the case, we have a legitimate interest in collecting the information described below.
Information You Give Us
When you fill out registration forms, submit your offer letter, submit your resume, or provide us with other personal information actively, we collect that information for processing and use in accordance with this Policy. Because we change our offerings and features from time to time, the options you have to provide us with personal information also may change, but here are some examples of situations in which you will have the opportunity to provide personal information to us:
Depending on how you interact with our Platform, the personal information we collect from you may vary. For example, to create an account we may ask only for an email address and password. In other circumstances, such as when you complete a form related to a particular service offering, we may ask you to provide other information, which may include your name, phone number, and/or postal address. We also collect and store certain information associated with actions you take. For example, when you may seek career guidance, or advice on negotiating your offer letter and other employment matters, we store the titles, locations and salary amounts (if available) of career opportunities you share with us. We may also store information about the career-related guidance and content that you are interested in and subscribe to, the time and duration of your activity on ourPlatform, and other information about your behavior on our Platform.
If you connect to the Platform using Facebook, Google+, or another social networking site (each a “Social Networking Site”), we will receive information that you authorize the Social Networking Site to share with us, which may include public profile information, birthday, current city work, school, and email address. When we receive this information, it becomes Mento account information for purposes of your use of the Platform. This informational so constitutes personal information and is therefore subject to this Policy.Any information that we collect from your Social Networking Site account may depend on the privacy settings you have set with the Social Networking Site, so please consult the Social Networking Site’s privacy and data practices. You have the ability to disconnect your Social Networking Site account from your Mento account by adapting the privacy settings in your Social Networking Site account. If you come to the Platform through a Social Networking Site, from other websites or with devices that enable third parties to collect information from or about you, such third parties receive information about you subject to their privacy policies.
When you set up an individual user account on the Platform, you may create a profile (a “Profile”) that will include personal information you provide. At your request, we will create your Profile with information we extract from a resume, cover letter or offer letter you have uploaded on the Platform. When you fill out and save your Profile, your saved Profile can be viewed by prospective career counselors, career coaches, employers and other partners, subject to visibility settings you control.
If you enter credit card information on the Platform in connection with a purchase, that information is sent directly from your browser to the third-party service provider we use to manage credit card processing and we do not store it on our servers. The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.
When you submit personal information to a third party and are informed at the time of collection that your information may be shared with us, we may collect that information for lawful marketing purposes.
Categories of personal information collected by Mento may include Profile Information (Name, Email Address, Resume, Current Job Title, SalaryInformation, Past Job History, Age, Gender), Sales & Support History(Purchase History, Payment Details, and other sales support interactions), CareerInterests & Activity (career preferences and your activity interacting with our content, career counselors and advisors), Security & Login Information(Your login events, password changes, email changes and mobile device information), Site Activity (Pages you viewed and “like activity”), MarketingActivity (Marketing programs you have joined, content downloaded, etc.), UserFeedback (Feedback you have provided Mento via email, app/website and other channels), and/or Content You Contributed (Employer reviews, Salary Reports,Benefit reviews, Interview reviews, Employer photos).
Information We Collect Automatically
When you use the Platform, your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version.The information we collect also may include usage information and statistics about your interaction with the Platform. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Platform.
Automated means of data collection include the following:
Log File Information. Log file information is automatically reported by your browser or mobile application each time you access a website on our Platform. For example, when you access a Mento website, our servers automatically record certain information that your web browser sends when you visit any website. These server logs include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.
Device Information. We collect information about the device you use to access the Platform, including type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone orAndroid phone. We collect the device type and any other information you choose to provide, such as username, geolocation, or email address. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
How We Use Information
We use the information we collect to provide our services.In order for us to best provide our services (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy.
Mento’s mission is to help people everywhere pursue a career they love. Mento uses your information largely to fulfill the relationship we have with you, and, where that is not the case, we have a legitimate interest in using the information we collect, including personal information, for these purposes:
When we collect any information that does not identify you as a specific natural person (“Non-Personal Information”), we are permitted to use and disclose this information for any purpose, not withstanding anything to the contrary in this Policy, except where we are required to do otherwise by applicable law. Examples of Non-Personal Information include:physical location information; demographic information, including gender, dates of birth, ZIP codes, etc.; or any personal information that has been anonymized, aggregated or de-identified (e.g. job title and salary information).If we combine any Non-Personal Information with your personal information (such as combining your ZIP code with your name), we will use and disclose such combined information as personal information in accordance with this policy.Similarly, if applicable law requires that we treat certain Non-PersonalInformation as personal information, we will use and disclose this information as personal information in accordance with this policy.
How We Share Information/Recipients
We only disclose your personal information to third parties as follows:
What types of Cookies do we use?
We use two types of Cookies on the Platform: “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on your device until you leave the Platform. A persistent Cookie remains on your device for much longer until you manually delete it (how long theCookie remains will depend on the duration or “lifetime” of the specific Cookie and your browser settings).
What are Cookies used for?
Cookies transmit information about you and your use of thePlatform, such as your browser type, search preferences, job titles, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. With the exception of an identifier Cookie that we associate with registered accounts to prevent fraud by members of the Platform, Cookies link to certain unique information such as the job titles that you entered at time of registration or on your profile, but this is not linked to your name.
Preferences and Features
Analytics and Performance
Ad Choices and Managing Cookies
Mento works with several third parties to provide you with personalized, interest-based advertising. We may target ads to you, and measure their performance, on and off the Platform using:
How We Work with Third-Party Ad Partners
When we work with our Ad Partners to serve you personalized, interest-based advertising, we do not share information with them that they can use to identify you or associate with you as a specific individual unless you have instructed us to do so (such as when you fill out a lead form in an ad, or approve your Profile for display to employers). Similarly, if one of these AdPartners has information about you saved in one of their own Cookies on your browser, they use that information to help us send you a relevant ad, but they do not share with us information that we can associate with you as an individual.
We work with third parties, such as Google Analytics, to provide analytics services that use the Cookies set on your device to measure the performance of advertising and track traffic to Mento generally. We may also implement GoogleAnalytics Demographics and Interest Reporting, which categorizes Cookie information so that we and third-party service providers can better deliver advertisements that are relevant and useful to you on the Platform and various websites across the internet. In addition, a Cookie on some of our employer clients sites provides us with aggregate data about the number of applications submitted to those sites by users of Platform.
Opting Out of Cookies
If you enable location data for the mobile version of thePlatform (including any version installed as a native application), we may use your location data to serve you geo-targeted ads for employers and other advertisers that are local to you. In such instances, we do not share your location with the advertiser or advertising network; rather, we provide the advertiser or advertising network with a means to push ads through to users located in certain areas. You may disable location services at any time in your device privacy settings or the Mento native app settings.
Ad Partner Cookies
Here are some options for managing the third-party Cookies used by our Ad Partners:
You are able to opt out of other third-party advertiser and ad network placement of Cookies or targeted advertising generally by visiting the following links: TRUSTe’s opt-out tool; NetworkAdvertising Initiative; DigitalAdvertising Alliance; EuropeanInteractive Digital Advertising Alliance (for users in the EU);or The Digital Advertising Alliance ofCanada (for users in Canada). You will continue to receive generic ads by companies not listed with these opt-out tools.
You can opt out of tracking by Google Analytics and GoogleAnalytics Demographics and Interest Reporting services by visiting Google Ads Settings orby downloading the GoogleAnalytics Opt-Out Browser Add-on.
Please note: If ads or other features on thePlatform are provided by third parties, those parties set and use their ownCookies that are subject to those third parties’ privacy notices and policies. Mento does not have access to, or control over, these Cookies. Also, if you respond to ads posted by third parties or submit information to third parties via thePlatform, such third parties receive information about you subject to their privacy policies.
Do Not Track Signals
We do not currently respond to ‘do not track’ signals and similar settings or mechanisms. When you use the Platform, we try to provide a customized experience.
Other Important Privacy Information
Your Privacy Rights
Mento operates globally and is therefore subject to a variety of data privacy laws that confer a range of privacy rights upon our users. We have chosen to provide all of these privacy rights to our users regardless of their location.
Mento does not discriminate against users’ that exercise any of these privacy rights. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We will respond to all requests within a reasonable timeframe. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Close Your Account
If you’d like to close your Mento account, you can do so within your Account Settings on the Platform[NT7] .When you close your account, you will no longer have full access to career guidance, salaries, reviews, and any content you have submitted will be pulled from the display on the Platform, but we reserve the right to keep any information in a closed account in our archives that we deem necessary to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements. If, after you close your account, you wish to know which personal information we keep you can proceed in accordance with your rights set out above.
How Long We Keep Your Personal Information
We keep your personal information only so long as we need it to provide the Platform to you and fulfill the purposes described in thisPolicy. This is also the case for anyone that we share your personal information with and who carries out services on our behalf. Retention period scan vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can’t identify you.
Security. We employ physical, electronic, and managerial measures to safeguard the information we collect online. However, no company can fully eliminate security risks, so we cannot make guarantees about any part of our services. You are responsible for keeping your username and password secret. Once you have registered with us, we will never ask you for your password. Please create a unique password for your Mento account and do not use it for any other web services or applications. Do not share your password with anyone else.
Privacy of Minors
To access or use the Platform you must be at least 16 years of age or, if older, the age of majority in your jurisdiction, otherwise you may not use the Platform. If you become aware that a child has provided us with personal information without parental consent, please contact us at firstname.lastname@example.org. If we become aware that a child has provided us with personal information without parental consent, we remove such information and terminate the child’s account.
We may revise this Policy from time to time by posting an updated version on the Platform. The revised Policy will be effective immediately for unregistered users and users registering accounts or otherwise acknowledging the Policy on or after the revision date. For other users who registered accounts before the revision date, it will also become effective immediately. However, they can object to the new Policy within thirty (30) days after the revision date. If we make a change that we believe materially reduces your rights or increases your responsibilities, we will notify you by email(sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We may provide notice of changes in other circumstances as well. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Platform is subject to the most current effective version of this Policy. If you object to the Policy after it becomes effective for you, you may no longer use the Platform.
If you have any questions or suggestions regarding this Policy, please contact us at email@example.com.