iMentor New York City Program - Privacy Policy
Last Updated: September 27, 2010
iMentor, Inc. (“iMentor,” “we,” “us”)is concerned about online privacy issues and wants you to be familiar with how we collect, use and disclose your Personally Identifiable Information (as defined below). This Privacy Policy (the “Policy”) describes our practices in connection with Personally Identifiable Information that we collect through the mentoring program that we ourselves operate (the “iMentor Program”) through our “iMentor Interactive” software platform located at http://imentor.imentorinteractive.org (“iMi”). This Policy does not address our practices regarding information that we collect through any website, or by any other means, other than through iMi; nor does this Policy govern the collection, use or disclosure of information by any third parties. In particular, and without limitation, please note that this Privacy Policy does not govern:
- Our collection, use or disclosure of information through our websites located at http://www.imentor.org and http://www.imentor.com (the Privacy Policy applicable to our collection, use and disclosure of such information is located at http://www.imentor.org/privacy-policy);
- The collection, use or disclosure of information by iMi licensees and other third parties to whom we provide access to iMi in connection with such third parties’ mentoring programs; and
- The collection, use or disclosure of information in connection with programs other than the iMentor Program.
By using iMi in connection with the iMentor Program, you agree to the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not use iMi in connection with the iMentor Program. We reserve the right to change this Policy without prior notice. You can determine when this Policy was last revised by referring to the “Last Updated” legend at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on iMi. Your use of iMi following such changes constitutes your acceptance of the revised Policy then in effect.
1. Types of Information That We Collect.
In connection with the iMentor Program, we gather two basic types of information through iMi: "Personally Identifiable Information" (or "PII") and "Non-Personally Identifiable Information" (or "Non-PII"). Personally Identifiable Information is information that identifies a person as an individual. Non-Personally Identifiable Information is aggregated information, demographic information, IP addresses and any other information that does not reveal a person’s specific identity.
a. Personally Identifiable Information. In order for you to register for and use iMi, we may require that you furnish PII. We collect PII from you through iMi, such as your name, postal address, telephone number and e-mail address (and, in some cases, your social security number and/or driver’s license number) when you register for iMi. If you are signing up to be a mentor, we may also require that you provide certain PII (such as name and contact information) of your references; by providing such PII, you represent that you have obtained the consent of the person whose PII you are providing to us or, if the person is under eighteen (18) years of age, you represent that you have obtained the consent of the parent or guardian of the person under eighteen (18) years of age. In all cases, please ensure that you have made clear to the person (or, if applicable, to the parent/guardian) the implications of the consent.
b. Non-Personally Identifiable Information. When you visit and interact with iMi, we and our service providers may collect Non-PII through iMi from sources such as IP addresses, environmental variables (such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version), “cookies” as well as so-called “pixel tags,” “web beacons,” “clear GIFs” and other similar technologies to better serve you with more tailored information and facilitate your ongoing access to and use of our iMi. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. Please be aware that, if you disable cookies, you may not be able to use all of the features and functionality of iMi.
We and our service providers may also collect Non-PII (e.g., your interests, your geographic location, etc.) when you voluntarily provide such information to us. Such information constitutes Non-PII because, unless combined with PII, it does not personally identify you or any other user. Additionally, we may aggregate PII in a manner such that the end-product does not personally identify you or any other user of iMi, for example, by using PII to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered Non-PII for purposes of this Policy.
2. How We Use Information That We Collect.
a. Personally Identifiable Information. We may use PII in the following ways:
i. Administration of iMi and the iMentor Program. iMentor may use your PII to administer and provide iMi and/or the iMentor Program (e.g., to provide you with the features and functionality of iMi, including features such as your homepage, in‑site messaging, calendar, groups, surveys, blogs, profile pages, curriculum, news announcements etc.).
ii. Fulfillment of Requests. iMentor may use your PII to fulfill your requests (e.g., to respond to your questions).
iii. Background Checks. If you apply to be a mentor in connection with the iMentor Program, we may use your PII to conduct a background check on you, subject to applicable law. By providing your PII and applying to be a mentor, you consent to such background check.
iv. Matching. We may use your PII to match you to potential mentors or mentees, as applicable.
v. Administrative Communications. From time to time, in our sole discretion, we may use your PII to send to you important information regarding iMi and/or the iMentor Program, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important to your use of iMi or participation in the iMentor Program, you may not opt-out of receiving such communications.
vi. Quotes. We may use your PII to attribute quotes to you, if you make comments about iMi. We will seek to use good faith efforts to get your permission before using any of your quotes.
vii. E-mails to Friends. We may provide functionality to permit you to send messages regarding iMi-related content to a friend through iMi. If you wish to use this feature, you may be required to provide us with, and we may use, your friend’s e-mail address so that we can facilitate your sending of such message to your friend. Please note that this functionality may permit you to send such messages only to certain other participants in the iMentor Program in which you participate.
viii. Promotions. We may operate sweepstakes, contests and similar promotions (collectively, "Promotions") through iMi. In addition, we may conduct surveys or polls through iMi or ask for your responses to questionnaires that we make available through iMi (such surveys, polls and questionnaires, collectively, “Surveys”). We typically ask you for certain PII when you enter and, if applicable, win a Promotion, and when you participate in a Survey. You should carefully review the rules, if any, of each Promotion and Survey in which you participate through iMi, as they may contain additional important information about our use of your PII. To the extent that the terms and conditions of such rules concerning the treatment of PII about you conflict with this Policy, the terms and conditions of such rules shall control.
ix. Internal Business Purposes. We may also use PII about you for our internal business purposes, such as data analysis, audits and so forth.
b. Non-Personally Identifiable Information. Because Non-PII does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Non‑PII, which does not personally identify you, with any third party, for any purpose.
In some instances, we may combine Non-PII with PII (such as combining your name with your geographic location). If we do combine any Non-PII with PII, the combined information will be treated by us as PII hereunder as long as it is so combined.
3. How Personally Identifiable Information Is Disclosed.
a. Administrators. Please note that, in connection with the iMentor Program, our program administrators will have access to all information submitted through iMi, including messages sent and received by iMi users via iMi, information appearing in iMi users’ calendars, survey responses, information regarding user interactions, and all PII submitted through iMi.
b. Third Party Service Providers. We work with third parties who provide services, including data analysis and other services of an administrative nature. We reserve the right to share PII about you with such third parties for the purpose of enabling these third parties to provide such services.
c. Other Participants in the iMentor Program. Participants in the iMentor Program, such as your mentor or mentee, as applicable, may have access to your PII. For example, your mentor or mentee, as applicable, may receive access to your PII in order to contact you. Participants may also be able to see your interactions on iMi; for example, if you choose to accept a calendar invitation, your mentor or mentee, as applicable, may see that you are attending the applicable event.
d. E-mails to Friends. Please note that any PII you provide in connection with sending messages regarding iMi-related content to a friend through iMi, such as your name, will, of course, be disclosed to your friend.
e. Promotions. We reserve the right to share PII that we collect in connection with Promotions and Surveys with any third-party sponsors or facilitators of such Promotions and Surveys (irrespective of whether such Promotions and Surveys are hosted by us), or otherwise in accordance with the rules applicable to a Promotion or Survey. You should carefully review the rules, if any, of each Promotion and Survey in which you participate through iMi, as they may contain additional important information about a sponsor's or other third parties’ use of PII about you. To the extent that the terms and conditions of such rules concerning the treatment of PII about you conflict with this Policy, the terms and conditions of such rules shall control.
f. Information Posted by Visitors. iMentor may make available through iMi services (for example, message boards, forums, resource databases and blogs, among other services) to which you are able to post information and materials. Please note that any information you disclose through such services or otherwise on iMi becomes public information, and may be available other participants in the iMentor Program. In addition, when you choose to make a posting on such services, certain PII (for example, a link to your profile that contains PII), will be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose PII, or any other information, on iMi. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PII YOU VOLUNTARILY DISCLOSE THROUGH IMI.
g. Assignment. We reserve the right to transfer any and all information that we collect from iMi users to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of iMentor's business or assets (including without limitation in connection with any bankruptcy or similar proceedings).
h. Law enforcement; emergencies; compliance. Notwithstanding any other provision of this Policy to the contrary, we reserve the right to disclose PII about you to others as we believe to be appropriate (a) under applicable law; (b) to comply with legal process; (c) to respond to governmental requests; (d) to enforce our Terms of Service; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of iMentor, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose PII about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.
4. Other Important Notices Regarding Our Privacy Practices.
a. Third Party Sites. iMi may contain links to third party websites, including iMentor-branded web pages on third-party social networking websites (e.g., Facebook). These linked sites are not under iMentor’s control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and the inclusion of a link on iMi does not imply endorsement of the linked site by iMentor. If you provide any PII through any such third party website, your transaction will occur on such third party's website (not on iMi) and the PII you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.
b. Security. We seek to have security measures and tools, such as firewalls, in place to help protect against the loss, misuse and alteration of the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. As a result, although we strive to protect PII about you, we cannot ensure or warrant the security of any information you transmit to us through or in connection with iMi or that is stored by us. You acknowledge and agree that any information you transmit through iMi or upload for storage in connection with iMi is so transmitted or stored at your own risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with Section 4.e ("Contacting Us") below (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).
c. Changing or Suppressing PII about you. If you would like to review, correct, update or suppress PII that you have previously provided to us through iMi, youmay do so by contacting your program coordinator through iMi.
Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed therefrom. We also reserve the right, from time to time, to re-contact former users of iMi. Finally, we are not responsible for removing information from the databases of third parties with whom we have already shared PII about you.
d. Jurisdictional Issues. iMi is controlled and operated by iMentor from the United States, and is not intended to subject iMentor to the laws or jurisdiction of any state, country or territory other than that of the United States. iMentor does not represent or warrant that iMi, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access iMi do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit iMi's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.
e. Contacting Us. If you have any questions regarding this Policy, please contact us by e-mail at imisupport@imentor.org. Please note that e-mail communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your e-mail correspondence with us.
