Smart Mentor Privacy Notice

Effective Date: 03 October 2019
Version No: 1.0
This Policy was last changed 03 October 2019.

Who we are

Smart Mentor is committed to protecting your privacy. This Privacy Notice ("the Notice") describes how we use your personal information when you interact with us via our website (www.smartmentor.io), communicate with us or use our services.
Your personal information is collected by Smart Mentor FZ-LLC ("Smart Mentor") (Commercial License number 96215) ("we"/"us"/"our").

Smart Mentor's contact details are as follows:
Email: info@smartmentor.io
Post: PO Box 930493 Dubai, U.A.E.
We operate from the in5 Tech Innovation Center, Dubai Internet City, U.A.E.

This Notice may be changed from time to time. If we change anything important about this Notice (the information we collect, how we use it or why we use it) we will highlight those changes at the top of the Notice and provide a prominent link to it for a reasonable length of time following the change and prior to the change taking effect.

To whose personal information does this Notice apply?

This Notice describes our practices when using the personal information of:

  • Users who register to use our services ("Users"); and

  • Individuals who visit our website or interact with our services.

Data collection and usage

We will collect, store and use your personal information for the purposes set out in more detail in this section.   Your information may be shared with some third parties as set out in more detail below.

Users of our Services

Information we collect about Users

We collect personal information directly from our Users. The categories of personal information we collect include:

  • contact details such as name, job title, location (country/city/time-zone), email and telephone number;

  • identification information such as date of birth and gender;

  • Employment history, experience, skills, qualifications, certifications and related data;

  • a User's professional and/or personal goals and objectives and progression towards these goals and objectives;

  • nominated calendar availability;

  • information attained from your social media platforms;

  • information, materials and content of discussions between mentors and mentees;

  • financial information specifically required for payment of services as/when agreed by specific consent; and

  • details relating to communications between us and between Users of the community forums and groups.

How we use the personal information we collect about Users

We use personal information from users of our services for certain activities, including:

  • to provide the services, including to allow mentors and mentees to connect and view each other's profiles and availability, to set up open and publicly available group discussions and create groups of interest, and to set up private group chats;

  • for internal analysis and research to help us improve our services;

  • to help match mentees with mentors;

  • to fulfil a transaction;

  • to keep records of transactions for the purpose of ensuring that any required payments are made and services received; and

  • to comply with any other contractual, legal and regulatory obligations.

Why we use the personal information of Users

We use this information because:

  • it is necessary to enter into or perform our contract with Users;

  • it is necessary to comply with legal or regulatory requirements;

  • it is necessary for the purposes of our or a third party's legitimate interests. A legitimate interest will apply only where we consider that it is not outweighed by a User's interests or rights which require protection of their personal data. We have the following legitimate interests to use User's information:

  • understanding how our User's engage with our services;

  • providing and improving our services, including understanding and responding to feedback; and

  • ensuring the security of our organization, our website and our services.

If you require further information regarding our legitimate interests, please contact us using the contact details in the "Who we are" section above.

Recipients of User information

We work closely with many third parties (business partners, sub-contractors, technical or payment delivery services) in provision of our product, including the website and mobile applications and other services that are on offer; we will ensure that contracts and data processing agreements are in place to ensure that we provide your data securely whenever shared with legitimate third parties.
We may also disclose User personal information to third parties as follows:

  • to other users of the services where you have provided your approval or where you have posted information on a publicly available section of our website;

  • to our professional advisers, suppliers or service providers (such as auditors and lawyers);

  • to third parties including for the purpose of providing the services;

  • to authorities such as tax authorities, courts, regulators and security or police authorities where required or requested by law or where we consider it necessary;

  • if we are defending a legal claim, User information may be processed as required in connection with a claim;

  • if we discuss selling or transferring part or all of our organization – the information may be transferred to qualified prospective purchasers under suitable terms as to confidentiality; and

  • if we are reorganized or sold, information may be transferred to a buyer who can continue the work of our organization.

Website User Information

Information we collect about our website users

The categories of information we collect about users of our website include:

  • information users provide in the content of their communications with Smart Mentor including when they contact us with general queries; and

  • information captured on our web logs such as device information, unique identification numbers (e.g. IP addresses), browser information, the date and time of requests, pages visited and search engine terms used.

How we use the personal information we collect via our website

We use personal information from users of our website for certain activities, including:

  • to administer the website, respond to questions and feedback and to investigate any complaints;

  • to monitor the way our website is used (e.g. locations it is accessed from, devices it is accessed from, understanding peak usage times and analyzing what functionality and information is most and least accessed); and

  • to perform statistical and trend analysis to improve the user experience and performance of our website.

Why we use the personal information of our website and social media site users

We use this information because:

  • it is necessary to comply with legal or regulatory requirements;

  • it is necessary for the purposes of our or a third party's legitimate interests. A legitimate interest will apply only where we consider that it is not outweighed by a website user's interests or rights which require protection of their personal data. We have the following legitimate interests to use this information:

  • monitoring, investigating and reporting any attempts to breach the security of our websites and improving the performance and user experience of our website;

  • assessing the number of visitors and page views in order to understand the services our website and social media users are interested in;

  • offering of approved third party products and/or services; and

  • managing our organization by monitoring our public profile and responding promptly to complaints or feedback.

Recipients of website user information

We may disclose personal information of website users as follows:

  • to third parties providing services to us, such as our professional advisors (e.g. auditors and lawyers);

  • to authorities such as tax authorities, courts, regulators and security or police authorities where required or requested by law or where we consider it necessary;

  • to third parties who work on our behalf to service or maintain our website, such as IT suppliers;

  • if we are defending a legal claim information may be transferred as required in connection with a claim;

  • if we discuss selling or transferring part or all of our business – the information may be transferred to qualified prospective purchasers under suitable terms as to confidentiality; and

  • If we are reorganized or sold, information may be transferred to a buyer who can continue to provide services to you.

Legal requirements

In certain circumstances, if you do not provide personal information which is required, we may not be able to perform or provide all functionality and/or may not be able to provide you with our services. We will make it clear if and when this situation arises and what the consequences of not providing the information will be for you.

Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defense of a legal claims. We will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

How long do we keep your information?

We will keep your information for as long as it is reasonably necessary, for example the duration of the period in which you use our services plus six years. It will depend on factors such as whether you have responded to or interacted with our recent communications. We will also retain your information as necessary to comply with legal, accounting or reporting requirements.

We will also routinely refresh our information to ensure we keep it up-to-date.

Where your information will be held

Your data is stored securely in London, United Kingdom.  Where we transfer your data outside of the UK or the EEA we will ensure that relevant data security safeguards are in place, such as European Commission-approved Standard Contractual Clauses (SCCs).

Your Rights

To the extent provided for under applicable law you may have certain rights in relation to your information. Some of these rights will only apply in certain circumstances.

  • Withdraw Consent: where we have collected your consent – for example, to use cookies when you visit our website.

  • Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information. This enables you to receive a copy of the personal information we hold about you and certain other information about it.

  • Correction: you are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected.

  • Erasure: you are entitled to ask us to delete or remove personal information in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.

  • Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

  • Transfer: you may request the transfer of certain of your personal information to another party.

If you want to exercise any of these rights, please contact us in writing per the details under the “Who we are” section.

You also have a right to lodge a complaint with a supervisory authority (data protection regulator), in particular in the country in the European Economic Area where you are habitually resident, where we are based, store data, or where an alleged infringement of data protection law has taken place.

Right to object

You have a right to object to us processing your information in certain circumstances. Where we are processing your personal information based on legitimate interests you may challenge this.  However we may be entitled to continue processing your information based on our compelling legitimate grounds or where this is relevant to legal claims. You also have the right to object where we are processing your data in order to send you any direct marketing.

Links to third party website

Our website, our services and other communications may, from time to time, contain links to third party websites.

The personal data that you provide through these websites is not subject to this Notice and the treatment of your personal data by such websites is not our responsibility. If you follow a link to any of these websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites.

Children

Our website is not aimed at children under the age of 18. If you are under 18 years old, you should not submit any personal information to us via our website without checking with your parent or guardian.

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© 2021 Smart Mentor FZ-LLC.
© 2021 Smart Mentor FZ-LLC.
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