ART OF MENTORING

PRIVACY POLICY

 

INTRODUCTION

 

This Privacy Policy is effective as of 29 May 2018 (the Privacy Policy).

 

This Policy sets out how Art of Mentoring Pty Ltd, ABN 31 620 225 372, with an address at Level 5, 115 Pitt Street, Sydney NSW 2000, Australia (AoM), and its affiliates, collects, stores, uses, protects and shares your personal information. It applies to all users of the AoM websites, Platform, applications, products and services (together ‘the AoM Deliverables’).

 

By visiting or using the AoM Deliverables, you agree to the terms and conditions of this Privacy Policy.

 

This Privacy Policy should be read in conjunction with the Platform Terms of Acceptable Use Policy and the Website Terms of Acceptable Use Policy, and any other terms of use policy as may be applicable, and together referred to as the “TOU”. Unless otherwise defined, words defined in the TOU have the same meaning in this Privacy Policy. In the event of any discrepancy between the TOU and this Privacy Policy, the TOU will prevail.

 

We reserve the right to amend this Privacy Policy at any time by posting the amended terms on the Website. If we make material changes to this Privacy Policy, we will notify you by means of an email notice so that you can access and review the changes. By continuing to use the AoM Deliverables after notice of changes has been sent to you or published on the Website, you are deemed to have consented to the changes.


PRIVACY POLICY

 

  1. Personal Information

In this Privacy Policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous or aggregated so that it cannot be used, whether in combination with other information or otherwise, to identify a specific customer.

 

  1. How we collect personal information

AoM collects personal information in a number of ways, including:

  1. Active Collection

This is information you provide to AoM when you create an account or use any of the AoM Deliverables. We may collect certain information you voluntarily provide to us which may contain personal information. For example, when you:

  • create an account or user profile,
  • fill out a survey, questionnaire, or form,
  • attend a seminar or workshop conducted by AoM or its affiliates,
  • subscribe to our newsletter or other publication,
  • make purchases from our Website,
  • download specific content from our Website; or
  • submit a comment to us or contact us by email or other means.
  1. Automatic Collection

When you visit our website, some information is automatically collected, such as your Internet Protocol address, your operating system, the browser type, the address of a referring website and your activity on our Website. We treat this information as personal information if we combine it or link it to any information that we actively collect about you that can identify you. Otherwise it is used in the aggregate only and is not personal information.

 

  1. What we collect

We actively collect the following types of personal information in order to supply you with information or provide you with access to and use of the AoM Deliverables:

  1. your name, Customer ID’s and passwords, phone number, mobile telephone number, email address, physical address, place of employment and other contact information when you submit contact requests, download special information or create an account or user profile on the Platform or Website or when you use the AoM Deliverables;
  2. information you input, upload or enter as part of completing a mentoring program application on the Platform, which may include information about your employment history, other work-related information, opinions and preferences;
  3. records and content of communications with AoM or any other User of the Platform;
  4. to the extent permitted by law, other personal information provided by or obtained from third parties (such as a credit bureau) including navigation and demographic data and credit check information;
  5. additional personal information we may ask you to provide to verify your identity, conduct background checks or when we suspect that you are in breach of this Privacy Policy or the Terms of Acceptable Use (including your personal ID and your answers to any questions we pose to you); and
  6. personal information from your interaction with the Website including device identifiers, device type, geo-location information, connection information, statistics on page views, traffic to and from the Website, mobile network information, time, date, referring URL, the type of operating system and browser, ad data, IP address, standard web log and analytics data.

While we don’t store credit card information, we do store an anonomised token provided to us via our Payment Processing provider, Stripe. We interact with their services in an encrypted, secure and standardized way. You can read more on their security policy here: https://stripe.com/docs/security/stripe

 

  1. How personal information is used

Our principal purpose in collecting, using and storing your personal information is to provide you with access to and use of the AoM Deliverables. Some of the information you provide us for a mentoring program may be shared with program organizers or program sponsors for the purpose of matching or connecting you with others. In addition, we may use this data or the data collected from the Website, training programs, seminars and other sources for direct email communication specific to AoM.

We do not sell or share your personal information to third parties for third party direct marketing purposes.  However, the program organizer or program sponsor that engages us to provide the AoM Deliverables may share the information you provide on the Platform and the sharing of this information will be governed by the program organizer or program sponsor’s privacy policy.

You consent to us collecting, using, storing and sharing your personal information to:

  1. facilitate the interaction between Users;
  2. verify and conduct background checks on Users;
  3. operate the Website, to provide our Services and provide customer support and billing services (including updates and improvements);
  4. provide customer support and other such services requested by you;
  5. research, develop and improve the AoM Deliverables;
  6. to conduct surveys to determine use and satisfaction with our AoM Deliverables;
  7. to generate statistics in relation to the Website;
  8. detect, investigate and prevent potentially unlawful acts or omissions with the potential to breach our TOU or this Privacy Policy;
  9. enforce our TOU or this Privacy Policy;
  10. verify information for accuracy or completeness (including by way of verification with third parties);
  11. combine or aggregate your personal information with information we collect from third parties and use it for the purposes set out in this Privacy Policy;
  12. contact you at the contact details we have collected, by way of voice call, post, text message or email;
  13. aggregate and/or make anonymous your personal information, so that it cannot be used, whether in combination with other information or otherwise, to identify you;
  14. collect fees, resolve disputes and to identify, test and resolve problems;
  15. notify you about updates to the AoM Deliverables from time to time; or
  16. supply you with generalized, targeted or personalized marketing, advertising and promotional notices, offers and communications to measure and improve our marketing, advertising and promotions.

 

  1. Access to Personal Information

You own the information we actively collect under clause 2(a) and we will not use or make available for use any of this information without your permission, except as provided in Clause 4 and 5 of this Privacy Policy or as expressly indicated in the provision of the AoM Deliverables.

We can access non-identifying information and/or aggregated information in order to better understand how our customers are using the AoM Deliverables and improve the design of the AOM Deliverables.

 

  1. Opting out

You may withdraw your consent to us collecting, storing, using and disclosing your personal information in accordance with this Privacy Policy or request us to delete or restrict the information we hold about you. However, we must collect some information in order to provide the AoM Deliverables. You may not be permitted to continue to use the AoM Deliverables which would otherwise be available if you withdraw your consent, delete or otherwise restrict the personal information we hold about you.

Under the European General Data Protection Regulation (also known as “GDPR”), you also have rights to:

  • Know what personal information we hold. You can request an explanation of the personal information that we hold about you and how we use that personal information. You can also receive a copy of the personal information that we collect about you as part of the provision of the AoM Deliverables
  • Ask us to correct any personal information we hold. Platform users, you can also access their own account or user profile to update and correct any information that you provide as part of the Services;
  • Ask us to delete or restrict any personal data we hold, except for information that we are required to hold by law or regulation of the relevant jurisdiction; and
  • Object to our processing of any personal information or file a complaint relating to our handling of personal information.

You can exercise these rights by sending us an email to info@artofmentoring.net.

You may also opt out of receiving our marketing, advertising and promotional notices, offers and communications by communicating this to us in writing at info@artofmentoring.net.

 

  1. Where we disclose to third parties

Other than as provided in Clause 5, and with prior notice to you,  we may disclose your personal information to:

  1. enforce our TOU and this Privacy Policy;
  2. comply with any applicable law, request by a governmental agency or regulatory authority or legally binding court order;
  3. respond to or resolve claims that a customer has violated the rights of others;
  4. protect a person’s rights, property or safety;
  5. AoM directors, staff, contractors, professional advisers and related entities for legitimate business interests;
  6. outsourced service providers who assist AoM to provide its AoM Deliverables such as information technology providers and marketing advisers (including in relation to fee collection, fraud investigations and Website operations);
  7. third parties to whom you expressly ask us to send, or consent to us sending, your personal information;
  8. credit agencies (including regarding missed and late payments or other defaults or breaches on your account); or
  9. such entities that we propose to merge with or be acquired by and in such case, we will require that the new entity following the merger or acquisition adhere to this Privacy Policy.

 

  1. Use of Cookies

We (or a third party providing services to AoM) may use cookies, pixel tags, “flash cookies”, or other local storage provided by your browser or associated applications (each a Cookie and together Cookies). A Cookie is a small file that stays on your computer or device until, depending on whether it is a sessional or persistent cookie, you turn your computer or device off or it expires (typically between 7 and 30 days depending on your settings).

Cookies may be used to provide you with our range of services including to identify you, remember your preferences, customize and measure the effectiveness of the Website and our promotions, advertising and marketing, analyze your usage of the Website, and for security purposes.

Cookies may collect and store your personal information. This Privacy Policy applies to personal information collected via cookies. You may adjust your internet browser to disable cookies. If Cookies are disabled, we may not be able to provide you with the full range of Services.

You also may encounter Cookies used by third parties and placed on certain pages of the Website that we do not control and have not authorized. AoM is not responsible nor liable for the use of such Cookies.

The AoM Deliverables may also include links to third party websites and applications and advertising delivered to by third parties (Linked Sites). Organizations who operate Linked Sites may collect personal information including through the use of Cookies. AoM is not responsible nor liable for Linked Sites and recommends that you read the privacy policies of such Linked Sites before disclosing your personal information.

 

  1. No Spam, Spyware or Spoofing

You are prohibited from engaging in spam, spyware or spoofing type activities, regardless of whether directed towards AoM or other customers of AoM.

You must not use the AoM Deliverables to send, upload or distribute spam, viruses or malicious, illegal or prohibited content to the Website or Platform or otherwise send content that would breach our TOU or this Privacy Policy.

We may (or we may engage a third party service provider to) take steps to scan and filter messages to check for spam, viruses, phishing attacks and other malicious activity or unlawful or content prohibited by our TOU.

To report spam, spyware or spoof activities to AoM, email us at info@artofmentoring.net.

 

  1. Accessing and amending your personal information

It is your responsibility to keep your password safe and choose a strong password by using unique letters, numbers and special characters. If you disclose or lose control of your password or your personal information to a third party, you may be responsible for all actions taken in the name of your account. If you suspect that your password or account has been comprised, you must immediately notify AoM at info@artofmentoring.net and change your password.

You can access the information you provide as part of the Platform and correct and/or update this information at any time. It is your responsibility to ensure that such information is accurate and up to date.

 

  1. Storage and security

You consent to the transfer, storage and retention of information onto the servers of the host provider used from time to time by AoM, regardless of the location of those servers.

AoM has taken steps to protect your personal information.  These measures are designed to mitigate, but do not guarantee against, the risk of loss, misuse, unauthorized access, disclosure and alteration. We implement industry standard data encryption practices such as:

  • Leveraging SSL certificates across the Website, Platform and related services
  • Not storing credit card details
  • One-way encrypting (hashing) passwords using the BCrypt hashing algorithm

 

  1. Account Closure

Subject to this clause, if you request us to do so, we will as soon as reasonably practicable close your account.

We may also close, terminate or deactivate inactive accounts or accounts that have been used in breach of our TOU and this Privacy Policy.

In general, but subject to other terms of this Privacy Policy, personal information from closed, terminated or deactivated accounts will be deleted and the login access to the account will be disabled as soon as reasonably practicable after account closure, termination or deactivation so that you and others cannot access the account.

To the extent permitted by law, we reserve the right under certain situations to retain and store your personal information for such period as is deemed necessary by AoM, notwithstanding closure, termination or deactivation of your account. Such situations include where we are required to comply with laws or regulations, the collection of fees owing to AoM, the resolution of disputes, the prevention of fraud, unlawful activity or activity prohibited by this Policy or our Deed.

 

  1. Information Sharing with Social Websites

We may also offer services that allow you to share public aspects of the AoM Deliverables with third party websites such as YouTube, Google Plus, Twitter, LinkedIn, Facebook and others social media websites.

 

  1. Complaints

Any issues or complaints concerning this Privacy Policy and the terms contained therein should be directed to: Alex Richardson, Director at alex@artofmentoring.net.  If the complaint cannot be resolved, you may Opt Out, close your account and/or cease use of the AoM Deliverables.