Privacy Policy

Mentormatic Solutions Limited (hereinafter the 'Company', 'we', 'us' or 'our'), owner of the Mentormatic mentoring and coaching platform available at https://mentormatic.com/ (the 'Platform'), respects your privacy and is committed to protecting your personal data.

This privacy policy (the 'Privacy Policy' and together with our Terms and Conditions as set out at [INSERT LINK] (the 'Terms') and any additional terms incorporated by reference into the Terms) applies to your use of:

• the Platform, once you have validly registered thereon and have therefore become a user in one of the following capacities: Mentor, Mentee or Programme Manager (as defined below), and
• any of the services accessible through the Platform, as such are described in the Terms (the 'Services').

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This Privacy Policy:

• provides an overview of how we collect, process and protect your personal data, including any sensitive data.
• informs you about your rights under the General Data Protection Regulation 2016/679 (GDPR), as amended from time to time, and any national law supplementing or implementing the GDPR (jointly with the GDPR, the "Privacy Laws").
• contains important information about what personal data we collect, what we do with such personal data, who we may share it with and your rights in relation to the personal data you have given us.

For the purposes of this Privacy Policy:

• When we refer to "Mentors/Coaches" we mean individuals with relevant professional experience who provide guidance, support and advice to Mentees, as part of a structured mentorship programme on the Platform.
• When we refer to "Mentees/Coachees" we mean individuals seeking professional development, guidance or career support, who participate on the mentorship programme available on the Platform to learn from and engage with Mentors.
• When we refer to "Programme Managers" we mean individuals responsible for the management, coordination and operation of one or several mentoring and/or coaching programs they created and/or manage on the Platform, including facilitating mentorship sessions and ensuring the smooth running of the mentorship programme.
• When we refer to "personal data" or "personal information" we mean data which identifies or may identify you and which may include, for example, your name, address and telephone number. It does not include data where your identity has been removed (anonymous data).
• When we refer to "processing" we mean the handling of your personal data by us, including collecting, protecting and storing your personal data.
• When we refer to "sensitive data" we mean special categories of personal data which identify or may identify you and which may reveal, inter alia, details about your racial or ethnic origin, your political opinions, your religious or philosophical beliefs, your trade union memberships, your health, your sex life or your sexual orientation.
• When we refer to "Account" we mean the account Mentors or Mentees create on the Platform following successful completion of the sign-up process.

Mentormatic Solutions Limited, who owns, operates and manages the Platform, is the controller and is therefore responsible for your personal data.

If you have any questions or concerns regarding the collection and processing of your personal data by us or if you wish to exercise any of your rights (as set out in section 9 of this Privacy Policy), please contact us using the details set out below and we shall provide you with a response as soon as possible.

• Email address: contact@mentormatic.com
• Postal address: Office 201, 4 Diagoras Str., Nicosia, 1097, Cyprus

The Company takes the protection of your personal data very seriously. If you feel that we have not dealt with your concerns adequately, you have the right to submit a complaint to the data protection supervisory authority of the country in which you reside. We would, however, appreciate the chance to deal with your concerns before you approach the relevant data protection supervisory authority; so please contact us in the first instance. The data protection supervisory authority in Cyprus is the Office of the Commissioner for Data Protection and you can visit their website at: http://www.dataprotection.gov.cy.

We will only use your personal data when we have a lawful basis to do so. We rely on one or more of the following legal bases when using your personal data:

• Performance of a contract: where we need to provide our Services to you through the Platform. Where we need to collect personal data under the terms of the contract we have with you, and you fail to provide that data when requested, we may not be able to provide you with the Services (either partly or fully). For example, if you fail to provide us and/or the payment service providers we work with the correct payment details, we will be unable to process your payments and you will therefore be unable to purchase a subscription package and use the Services offered through the Platform.
• Legitimate interest: where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Consent: where you have provided your explicit consent before the processing. Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose, such as, where you subscribe to an email newsletter. Consent will only be valid if it is a freely given, specific, informed, and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us using the contact details set out in section 2 of this Privacy Policy or through the opt-out options available on your Account or in email communications we send you.
• Legal obligation: where we need to use your personal data to comply with a legal or regulatory obligation that we are subject to, such as, a tax obligation. Where we rely on legal obligation and you do not provide the necessary information, we may be unable to fulfil a right you have or comply with our obligations to you, or we may need to take additional steps, such as informing law enforcement or a public authority or applying for a court order.

We provide further details in connection to each legal basis on which we rely, in the table below:

We may share your personal data with third parties as listed below for the purposes set out in section 5 above. When we do so, we request from such third parties to have appropriate technical and organisational measures in place to protect your personal data. We will not share any of your personal data for any purpose other than the purposes described in this Privacy Policy:

All information you provide to us is stored on our secure servers.

We are committed to protecting our users' personal data. We have put in place appropriate technical and organisational security measures that ensure the security of your personal data and prevent them from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, you should be aware that no system is ever secure in its entirety.

We and our business partners do our utmost to protect your personal data in line with the Privacy Laws by means of physical, electronic, and process-oriented security precautions. However, we cannot guarantee 100% protection against unauthorised access from third parties. When we do become aware of such unauthorised access, we immediately take all steps necessary to block such third party from retrieving, accessing, or otherwise compromising any personal data and ensure that any risks to our users are mitigated.

There are things you can do to protect the security of your data as well. Where we have given you (or where you have chosen) a password for your Account, you are responsible for keeping this password confidential. Please do not share it with anyone. If at any time you suspect or become aware of a breach of your Account or if you believe that your information is no longer secure, please contact us immediately using the contact details in section 2 of this Privacy Policy, so that we can take any necessary action.

We shall process and retain your personal data only for the period necessary to fulfil the purpose for which the data was collected.

To determine the appropriate retention period for your personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you have tried to register as a user on the Platform but have been unsuccessful (due to the fact that you have not provided us with all the information we have requested or you are not eligible to become a user or for any other reason), we will delete any personal data you have provided to us during the registration procedure immediately following your unsuccessful attempt to register.

In some circumstances you can ask us to delete your data. See section 9 below for further information.

You have the following rights in terms of the personal data and information we hold about you:

To exercise any of your rights as set out in section 9, you can use the contact details set out in section 2 above.

For security reasons, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also contact you to ask you for further information in relation to your request to speed up our response.

In some cases, such as when you wish to change or update your personal data, you may be able to do so by accessing your Account and making changes to the relevant fields that need to be corrected or updated.

Our Platform may, from time to time, contain links to and from the websites of our partner networks and/or advertisers.

Please note that these websites and any services that may be accessible through them have their own privacy policies. We do not accept any responsibility or liability for these third-party privacy policies or for any personal data that may be collected through these websites or services.

Please check these policies before you submit any personal data to these websites or use these services.

We sometimes use automated measures including artificial intelligence (AI) tools, to assist us in offering you the best possible service. This includes the use of AI tools to analyse user profiles and suggest optimal mentor-mentee pairings based on psychological compatibility scores and complementary skill/knowledge level.

Our automated methods of processing are often supported by manual methods. For example, we may use AI tools to analyse your data to identify patterns and trends, which are usually manually reviewed and interpreted by humans.

We keep our Privacy Policy under regular review.

If we update our Privacy Policy in the future, the changes will be posted on this page and, where appropriate, notified to you either by email or when you next access the Platform. The new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the Platform or the Services.

We do, however, encourage you to review this policy periodically to stay informed about how we are processing and protecting your personal information.

It is important that the personal data we hold about you is accurate and current. Please keep us informed of your personal data changes during our relationship with you.