Privacy policy

This Privacy Policy is designed to help you understand how Hindsight Advice, Inc. ("Company" or “we”) collect, transmit, and store information about our Users. The term "you" or "You" or “User” or “Users” shall refer to Customers, Mentors, Education Partners, or any person or entity who views, uses, accesses, browses or submits any content or material to the Site (defined below). This Privacy Policy is not a contract and does not create any legal rights. Providing your information is voluntary and your use of the Site (defined below) after the effective date of this document constitutes your acceptance of this Privacy Policy. In some cases, if you do not provide your information you may have limited access to some sections of our Site and our Services (detailed below). If you do not agree to all the terms and conditions of this Privacy Policy, do not use the Site and our Services. 

 

Although Company and many of our Users are based outside of the European Union, we do have some Users (including Mentors, Customers, Partners) who are based in the European Union. If there is processing of personal information taking place in the European Union, this processing benefits from the additional protection and safeguards set out under the General Data Protection Regulations (Regulation (EU) 2016/679) (“GDPR”) and related legislation and regulations. This is highlighted where relevant below in this Policy. 

This Privacy Policy applies only to your use of Our Site and our Services. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.


Who we are

 

We, Company, are Hindsight Advice, Inc., located at 100 Cambridge Street, 14th Floor, Boston, MA, 02114, USA. 

Our contact details are [email protected]


Information We Collect

 

This Privacy Policy applies only to information we collect via e-mail, telephone, the website https://mymentoracademy.global (“Site”), mobile applications, electronic devices and other interactive services. In order to help you get the most out of our service, we collect User submitted personally identifiable information (“PII”) when you use the Site. We ask Site users only to submit the minimum amount of information necessary to use our service. Such information may include, but is not limited to your name, address, password, zip code, email address, Skype/WeChat ID and phone number for communication purposes. Information may be submitted to the Site or via phone or email when communicating with a Company representative. We may collect information related to your documentation of payment. In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data. We may also collect Student Data, which occurs when this Service may be used or purchased by providers of educational services, such as schools, education companies, school districts, or teachers/counsellors (collectively referred to as "Education Partners"). When Company contracts with an Education Partner to provide the Service, we may collect or have access to Student Data, which may be provided by the Education Partner or by the student. We consider such Student Data to be strictly confidential and in general do not use such data for any purpose other than improving and providing our Services to the Education Partner or on the Education Partner’s behalf to students/learners. Our collection, use and sharing of Student Data is governed by this Agreement and any applicable laws and regulations. We may also gather non-PII when you use the Site. Such data is compiled in aggregate and includes things like the referring URL and the type of browser you may be using to access the Site. This data is used to better understand and enhance the user experience on the Site. Company may publish these statistics or share them with third parties without including PII.

User generated content posted through certain social networking preferences (e.g. pages you "Like" or "Follow") may be viewed by the general public. Accordingly, Company cannot ensure the privacy of any PII included in such User generated content.


Use of Personally Identifiable Information

 

Company does not disclose or sell your PII without your consent or unless we are obliged to do so as set out below. We may use PII or other personal information you specifically give to us: a) to provide services to you through the Site b) to process transactions and billing, c) for identification and authentication purposes, d) to communicate with you concerning the Site, transactions, security, privacy and administrative issues relating to your use of the Site and Services, e) to improve your response to and interaction with the Site, f) to do something you have asked us to do, or tell you of services that we think may be of interest to you (subject to your express consent if we are obliged to do so by local laws); and g) for administration of and troubleshooting regarding the Site. Certain third parties who provide technical support for the operation of the Site may need access to such information from time to time but are not permitted to disclose such information to others. Company shares a minimum amount of information between Users (including with our Mentors) in order to facilitate the arrangement of services. We reserve the right to release non-personally identifiable information collected in aggregate, however.


Under GDPR, where applicable, we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

a) you have given consent to the processing of your personal data for one or more specific purposes;

b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

c) processing is necessary for compliance with a legal obligation to which we are subject;

d) processing is necessary to protect the vital interests of you or of another natural person;

e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.


Sharing Information with Mentors

We may work with a team of Mentors, who help us provide you with Services. These Mentors are independent contractors and are not part of our company structure. In appointing our Mentors, we have entered into written agreements with those Mentors, setting out the scope of the relationship between us, them, and our Customers. In order to provide the Services, we will share relevant limited personal information about the Customers who those Mentors will be working with. The sharing of information is essential to the provision of the Services. The Mentors have entered into confidentiality and limits on the processing of personal data that they may carry out. These agreements also set out safeguards that must be in place to protect customers’ personal information and to ensure compliance with this Privacy Policy and the GDPR (among other obligations).


Right to Examine Information

You have the right to examine any of your Personal Information that we collect. Should you wish to examine such information, please send us a written request to [email protected]. We reserve the right to charge you a reasonable administrative fee to access your information, as permitted by applicable law. In certain cases, we may not be able to provide you with access to all of your Personal Information (example: if the information also pertains to the Personal Information of another user).


Withdrawal of Consent

You may withdraw your consent to the collection of Personal Information at any time by sending an email to us. Upon receiving notice that you have revoked your consent, we will stop using your Personal Information within a reasonable time, which will vary depending on what information we have collected and for what purpose. Please note that we will send you an email confirmation upon receipt of your request. Therefore, if you do not receive a confirmation email, please contact us again with your request. If you do choose to withdraw such consent, your access to the Site may be diminished, or your ability to choose some of the options on the Site may be limited.

Contact email: [email protected]


Minors

Company does not knowingly collect non-service related information from minors (children under the age of 18). If you are a minor, please do not provide personally identifiable information to Company beyond what is requested to access and use our services. If you are the teacher, parent or legal guardian of a minor who may have provided us with information without your knowledge or consent, please contact us to have this information removed.


Legal Requests and Business Transfers

Company may disclose personal information when we believe such action is necessary to comply with the law or enforce or apply our Terms of Service. In the event of a change in control of Company’s business, personal information may be exchanged as part of a merger, sale, or other business transfer. If such a transfer makes a material change to this Privacy Policy, we will notify you of any changes.


Location-Based Services Consent

You hereby expressly consent to our use of location-based services and expressly waive and release Company from any and all liability, claims, causes of action or damages arising from your use of Company’s services, including but not limited to use of the Site, or in any way relating to the use of the precise location and other location-based services.


External Links

The Site may contain links and references to other websites. We are not responsible for the collection, use and disclosure of information, or the privacy practices of such websites, and we expressly disclaim any liability relating thereto.



Additional Country Specific Privacy Terms

 

International Visitors

The Site is hosted in Virginia, USA. If you choose to use the Service from outside of USA, with laws governing data collection and use that may differ from United States law, then please note that you are transferring your personal information outside of those regions to USA for storage and processing. Also, we may transfer your data from USA to other countries or regions in connection with storage and processing of data, fulfilling your requests, providing our services and operating the Site. By providing any information, including personal information, on or to the Site, you consent to such transfer, storage, and processing.


By using the Site, participating in any of our services, and/or providing us with your Personal Information, you consent to this transfer. In order to comply with the Swiss-US Privacy Shield frameworks and the Cybersecurity Law of Mainland China, the Company commits to the resolution of complaints about your privacy and our collection or use of your personal information. In compliance with the Swiss-US Privacy Shield Principles and the Cybersecurity Law of Mainland China, the Company commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss or Mainland Chinese individuals with inquiries or complaints regarding this privacy policy should first contact Company at: [email protected]. Company has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. Finally, as a last resort and in limited situations, Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

 

 

For Residents of India:

This Privacy Policy shall be governed by, and construed in accordance with, the laws of India, including without limitation the Indian Contract Act, 1872, Information Technology Act, 2000 and the rules, regulations, guidelines and clarifications framed thereunder (including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 and the Information Technology (Intermediaries Guidelines) Rules, 2011) and without reference to principles of conflicts of law. The courts or tribunals at Hyderabad, Telangana shall have exclusive jurisdiction over any dispute arising from or relating to the User Terms, or your use of the Website. You expressly consent to the jurisdiction of the said courts/ tribunal and irrevocably waive any objection now or in future, to such jurisdiction based on forum non convenience or any other basis.

 

For Residents of EEA/Switzerland:

If you are a resident of the EEA or Switzerland, under the GDPR you are entitled to the following rights:

· The right to request data erasure – you have the right to have your data erased or corrected from the Site if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.

· The right to restrict or object to our processing – you have the right to restrict or object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

· The right to object to automated decision making – you have a right to avoid being subject to automated decision making and insist on human intervention if we make an automated decision that produces a legal or a similarly significant effect on you.

· The right to complain to a supervisory authority (in the UK, this is the Information Commissioner’s Office (“ICO”) see www.ico.gov);

· The right to be informed of what data processing is taking place;

· The right to data portability;


To enforce any of the above rights, please contact Us at
[email protected]

 

For Residents of Mainland China:

If you are a citizen of Mainland China, you are entitled to request data erasure – you have the right to have your PII erased from the Site if the PII is collected or used in violation of any law or regulation of Mainland China or any agreement or commitment binding on us, or if you close your account on the Site and will not request our services any longer.


Accessing and Updating Personal Information

Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. When you use the Site we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not for legitimate business purposes. You may update your account information by reaching out to the Company at: [email protected] or messaging the admin team directly through the Website. When requests come to Company with regard to personal information, we ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. We retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. We will respond to these requests within a reasonable timeframe.

We will retain your information for as long as your account is active or as needed 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.

We will only hold information for so long as it is necessary for us to do so.


Recourse, Enforcement and Liability

EU citizens will have recourse under the GDPR as set out under this Policy. The Company commits to resolve complaints about privacy and personal data collection or use. EU individuals with inquiries or complaints regarding this Policy should first contact Company at the address given below. Company will investigate and attempt to resolve such complaints by reference to the principles contained in this Policy.

In the unlikely last resort and in limited situations, EU individuals may seek redress through their local Privacy and Data Regulator in their jurisdiction (for example the Information Commissioner’s Office in the UK). 


Company is subject to the investigative and enforcement authority of the Federal Trade Commission (FTC) and is obliged to disclose personal data in response to lawful requests by public authorities, for law enforcement and national security purposes, and has potential liability for onward transfers to third parties.


Company will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Company determines is in violation of this policy may be subject to disciplinary action.


International Transfer

Both Personal Information and Non-Personal Information you submit via the Site is sent to our group companies and will be processed in USA and stored on secure servers located in Virginia, USA. Such information may also be transferred by us to our offices and third parties. The countries concerned may not have similar data protection laws to your country. Where we transfer your information out of your jurisdiction we will take reasonable steps to ensure that your privacy rights continue to be protected. By submitting your information to the Site, you agree to this storing, processing and transfer. Steps the Company takes when making international transfers include:

1) Having written and/or verbal protocol with receiving party setting out what steps they need to take to process/protect data, 2) Encryption, 3) Company staff and representatives have training, 4) Data is accessed by authorized users, and 5) Data to be used for limited purposes

Cookies and Similar Technologies


When you interact with the Site, we try to make that experience simple and meaningful. Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website or access or use a mobile application and which store and sometimes track information about your use of a website or application (as the case may be).


While we do not set cookies of our own, there are cookies used by the Site that are set by third parties who are delivering services on our behalf. These cookies are necessary for the website to function and are usually only set in response to actions made by you (i.e. making payment, clicking on certain buttons/links etc.). These third parties may access the cookies they set, receive your IP address, and receive some information about your browser configuration. Below is a list of third-party cookies set when you use the Site:

Name of Cookie: __stripe_mid (or "muid"; part of stripe.js)

Type of Cookie: Necessary 

Provider: Stripe

Description: Fraud prevention and detection for processing of payments transactions

How Long the Cookie is Stored: 1 year 

Name of Cookie: __stripe_sid (or "sid"; part of stripe.js)

Type of Cookie: Necessary

Provider: Stripe

Description: Fraud prevention and detection for processing of payments transactions

How Long the Cookie is Stored: 30 minutes 

Name of Cookie: m (or "guid"; part of stripe.js)

Type of Cookie: Necessary

Provider: Stripe

Description: Fraud prevention and detection for processing of payments transactions

How Long the Cookie is Stored: 2 years

Name of Cookie: __cfduid

Type of Cookie: Necessary

Provider: Cloudflare (for Jotform)

Description: The _cfduid cookie helps Cloudflare detect malicious visitors to Customers’ websites and minimizes blocking legitimate users. It may be placed on the devices of customers' End Users to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It is necessary for supporting Cloudflare's security features.

How Long the Cookie is Stored: 30 days


For more information regarding these third parties’ list of cookies and policies:

Stripe: https://stripe.com/cookies-policy/legal

Cloudflare: https://www.cloudflare.com/cookie-policy/

Jotform: https://www.jotform.com/privacy/

LearnWorlds:  https://www.learnworlds.com/privacy-policy/

                        https://www.learnworlds.com/cookie-policy/

https://www.learnworlds.com/data-security/


Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device. Please note, however, that by blocking or deleting cookies used on the Site, you may not be able to take full advantage of the Site.


Payment Processing

Payment details you provide will be encrypted using secure sockets layer (SSL) technology before they are submitted over the internet. Payments made on the Site are made through our payment gateway provider. You will be providing AliPay, credit or debit card information directly to our payment gateway provider which operates a secure server to process payment details, encrypting your credit/debit card information and authorizing payment. Information which you supply to our payment gateway provider is not within our control and is subject to their own privacy policy and terms and conditions.


Terms of Service

This Privacy Policy is incorporated into and forms part of the Terms of Use, which outlines the terms and conditions you agree to when accessing and using the Site, and which can be found here: Terms of Service


Privacy Policy Changes

Company reserves the right to change this Privacy Policy, from time to time, due to modifications to the Site’s features and functionality. We will post any changes here and indicate the new effective date of the Privacy Policy at the top of the document. We encourage you to review the Privacy Policy for any updates while you are an active User of the Site.


California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, if you are a California resident and have an established business relationship with Company, you can request a notice disclosing the categories of personal information that Company has shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request to the address directly below.


Our Contact Information

Please contact us with any questions or comments about this Policy, your personal information, our use and disclosure practices, or your consent choices by email at [email protected] or by regular mail at:

Hindsight Advice, Inc.

100 Cambridge Street, 14th Floor, Boston, MA, 02114, USA