1. SUMMARY

Web Fuel Agency Ltd and its subsidiaries (collectively referred to as “Mentor Plus”, “we”, “us”, and “our”) value your privacy and take the protection of your personal data very seriously. If you have any questions, comments, or concerns regarding this Privacy Notice or our handling of your personal data, please refer to the end of this Privacy Notice for contact information. Mentor Plus is the data controller responsible for the collection and processing of your personal data.

 

Mentor Plus is a platform which enables users to share their content, view content from other users, or both. We refer to those users who share content as “Mentors” and those users who pay to view Mentors’ content as “Proteges”. This Privacy Notice outlines our practices with regard to the personal data we collect and process regarding you. This includes information collected through or in connection with our website located at https://mentorplus.app, our services that are offered on our website, our associated social media sites (e.g. Twitter, Instagram), or any other interactions you have with us (the website, our social media pages, and services, referred to as the “Services”).

 

Please read the following to gain an understanding of how we process and protect your personal data. By using any of our Services, either through visiting our website or other means, and/or by willingly providing personal data to us, you are agreeing that you have read and comprehend the practices outlined in this Privacy Notice. This Privacy Notice may be revised periodically, so make sure to keep checking this Privacy Notice to stay up-to-date.

 

2. PERSONAL DATA COLLECTION

We collect information that can be associated with or linked to, a particular individual or household (“personal data”). In addition, we may collect data that is not identifiable to you, such as aggregated data, which is not considered to be personal data. If this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this Privacy Notice.

 

a. Types of Personal Data We May Collect

The types of personal data we collect from you depend on your interactions with us and how you take advantage of the Services. During the past twelve (12) months, we have collected the following categories of personal data from users:

• Identifiers such as real name, alias, mailing address, IP address, email address, account name, Social Security Number, driver's licence number, passport number, or any other similar identifiers. 

• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)). 

• Characteristics of protected classifications under California and federal law. Business-related information like records of personal property, services purchased, or consuming histories and tendencies. 

• Biometric information. Note: Even though we don’t collect biometric information, if you choose to authenticate yourself through certain service providers we use, they may collect biometric information in accordance with their privacy policies. We are never granted access to this information.

• Internet or other electronic network activity details, such as browsing history, search history, and information regarding a consumer’s interactions with an internet site, application, or advertisement.

• Audio, electronic, visual, thermal, olfactory, or similar information.

• Professional or employment-related information.

• We will not be collecting any additional categories of personal data except for the ones listed here. If we are planning to collect additional categories of personal data, new notice will be given at or before the collection time.

b. Purposes of Using Your Personal Data

Our goal is to provide content that can be enjoyed by all, and to keep it appropriate, tasteful, and lawful. To do this, we collect and process your personal data for the following business and commercial purposes:

• Developing, improving, operating, providing, predicting, or performing tasks, such as maintaining and servicing accounts, improving the Services and your experience with them, providing customer service, processing or fulfilling orders, verifying your identity, and processing payments. 

• Communicating with you via email and text regarding the Services, verifying your identity, answering support inquiries, and sharing information about the Services. 

• Auditing related to your current interaction with us and concurrent transactions. 

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal actions, and prosecuting those responsible for those actions. 

• Debugging to identify and fix errors that prevent existing intended functionality. 

• Conducting internal research for technological development and demonstration. 

• Performing activities to verify or maintain the quality or safety of the Services owned, produced, or controlled by us, as well as to upgrade, enhance, or improve the Services owned, produced, or controlled by us. 

• Adhering to applicable laws, regulations, rules, and requests from relevant law enforcement and/or other governmental authorities, or for other purposes, as allowed or required by law. 

• Enforcing our Terms of Service and other usage policies. 

• As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.

We will not use the personal data we have collected for purposes that are significantly different, unrelated, or incompatible without providing you with notification and obtaining your consent. 

 

c. How We Obtain Your Personal Data

We collect your personal data from the following sources: 

• Directly from you. When you provide it to us to open an account and use the Services, or when you update the information in your account (refer to the “Accessing, Updating, Correcting, and Rectifying Collected Personal Data” section for more information).

• Indirectly or automatically from you. For example, from your use and access to the Services. We also collect IP addresses and browser types from your devices. 

• From our service providers.

 

d. Legal Bases for Processing

We process personal data for or based on one or more of the following legal bases:

• Performance of a Contract. By using the Services, you have contracted with us through the Terms of Service, and we will process certain personal data to fulfil that contract. 

• Legitimate Interests. We may process personal data for our legitimate interests, such as complying with any applicable law, rule or regulation, investigation or remedy; enforcing our Terms of Service; protecting our, our users' or others' rights, property, and safety; and detecting and resolving any fraud or security concerns. 

• Compliance with Legal Obligations and Protection of Individuals. We may process personal data to comply with valid legal process and governmental requests, as well as to protect those individuals who use our Services and others.

 

e. Who We May Share Your Personal Data With

We may share your personal data with our service providers, affiliated entities, and/or with government agencies or regulators when it is permitted or required by law. This includes responding to a request from law enforcement authorities, government authorities, or regulatory agencies, and/or protecting the integrity of our Services, our interests, rights, property, or safety, as well as that of our users and others.

 

f. Personal Data We Share for a Business Purpose

In the past twelve (12) months, we have shared certain categories of personal data, such as identifiers (e.g. name, address, email address, government ID, IP address), account names, and personal information categories listed in the California Customer Records statute (e.g. government ID, bank account numbers) with our service providers. We also share audio, electronic, visual, thermal, olfactory, or similar information (e.g. content you create) with our service providers. Other Mentors and Proteges have also received identifiers (e.g. account name) from us.

 

3. YOUR PERSONAL DATA RIGHTS

You have certain rights regarding the collection and processing of your personal data. Depending on the applicable laws, these may include the right to access, rectify, erase, restrict, transfer, or object to the use of your data. If you would like to exercise any of these rights, please contact us using the information provided at the end of this Privacy Notice, or follow the instructions indicated in this Privacy Notice or in communications sent to you.

 

Depending on the applicable laws, your rights may also include the right to know whether and for what purpose we are processing your personal data, be informed about the personal data we have collected and/or processed, learn the source of personal data we have processed, access, modify, and correct collected personal data (see the “Accessing, Updating, Correcting, and Rectifying Collected Personal Data” section for more information), know with whom we have shared your personal data and/or for what purpose, and withdraw consent for processing personal data (when this is based on your consent). You also have the right to lodge a complaint with a supervisory authority in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.

 

For more information about certain legal rights, please review “Your California Privacy Rights”, “Your Nevada Privacy Rights”, and “Your European Union and UK Privacy Rights”.

 

a. Accessing, Updating, Correcting, and Rectifying Collected Personal Data.

We strive to keep all personal data collected from you accurate by promptly responding to any updates. While we do our best, we rely on you to ensure that the information you provide is complete, accurate, and up-to-date. Please review all of your information carefully before submitting it to us and make any updates or corrections to your information through your account settings.

Depending on the applicable laws, you may be able to obtain certain personal data from us. To access, review, or make changes to the personal data you have provided to us, please contact us at the information provided at the end of this Privacy Notice. We reserve the right to deny access as per permitted or required by law.

 

b. Your California Privacy Rights

California's "Shine the Light" law permits our users who are California residents to request and obtain a list of personal data (if any) we disclosed to third parties for their own direct marketing purposes in the past calendar year, along with the names and addresses of those third parties. These requests may be made once per person, per year, free of charge and should be sent to the email address provided below. Please note that we do not disclose personal data protected under the "Shine the Light" law to third parties for their own direct marketing purposes. Additionally, the California Consumer Privacy Act ("CCPA") provides our users who are California residents with the following additional rights:

 

1. Right to Know: You have the right to request that we disclose certain information to you about the personal data we collected, used, disclosed, and sold about you in the past 12 months. This includes a request to know any or all of the following:

   • The categories of personal data collected about you;

   • The categories of sources from which we collected your personal data;

   • The categories of personal data that we have sold or disclosed about you for a business purpose;

   • The categories of third parties to whom your personal data was sold or disclosed for a business purpose;

   • Our business or commercial purpose for collecting or selling your personal data; and

   • The specific pieces of personal data we have collected about you.

2. Data Portability: You have the right to request a copy of personal data we have collected and maintained about you in the past 12 months.
3. Right to Deletion: You have the right to request that we delete the personal data we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your personal data, we may deny your request or may retain certain elements of your personal data if it is necessary for us or our service providers to:

• • Complete the transaction for which the personal data was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

  • Debug to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.

  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Otherwise use the personal data, internally, in a lawful manner that is compatible with the context in which you provided the information.

4. Right to Opt-Out/In: You have the right to opt-out of the sale of your personal data. You also have the right to opt-in to the sale of personal data. However, we do not sell your personal data.

5. Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:

• • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
    
    

To exercise your California privacy rights described above, please submit a verifiable request to us by visiting https://mentorplus.app/contact or emailing us at [email protected].

 

If you have an account with us, you can exercise any of the above rights from your profile. If you don’t have a profile or if you are unable to access, control, or delete your information from within your profile, you can contact us through any of the above methods.

 

Only you, or a person authorised by you to act on your behalf, may make a verifiable consumer request related to your personal data.

 

You may only make a verifiable consumer request for Right to Know or Data Portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorised representative. Depending on the nature of the request, we may need to verify your identity through an additional Ondato verification cycle, which requires a government issued ID and a photo of yourself holding your government ID (see Identity Verification section below for more information).

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  
  

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

 

Consumer Request by an Authorized Agent

If any authorised agent submits a consumer request on your behalf, in order to confirm that person or entity’s authority to act on your behalf and verify the authorised agent’s identity, we require an email be sent to [email protected], along with all of the below items:

 

• Proof that you gave the authorised agent signed permission to submit the request.

• Sufficient information to verify the authorised agent’s identity, depending on the nature of the request.

• To verify your identity, depending on the nature of the request, we may also require a valid Government Issued ID (not expired), email address, and the last 4 digits of the social security number.

 

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require creating an account with us. However, if you do have an existing login, we will require you to log in to submit a request. We will only use personal data provided in a verifiable consumer request to verify the request’s identity or authority to make the request.

 

We will acknowledge receipt of the request within ten (10) business days of its receipt. We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability requests, we will provide the responsive information in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit the information to another entity without hindrance.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

c. Your Nevada Privacy Rights

Nevada law allows our users who are Nevada consumers to request that their personal data not be sold (as defined under Nevada law), even if their personal data is not currently sold. Requests may be sent to [email protected], and are free of charge.

 

d. Your European Union and UK Privacy Rights

In addition to the above-listed rights, European Union and UK privacy law provides individuals with enhanced rights in respect of their personal data. Depending on the circumstances surrounding the processing of personal data, these rights may include:

 

• The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you;

• The right to request restriction of processing of personal data or object to processing of personal data carried out pursuant to (i) a legitimate interest (including, but not limited to, processing for direct marketing purposes) or (ii) performance of a task in the public interest;

• In certain circumstances, the right to data portability, which means that you can request that we provide certain personal data we hold about you in a machine-readable format; and

• In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain personal data we process about you.

 

Note that we may need to request additional information from you to validate your request. To exercise any of the rights above, please visit https://mentorplus.app/contact or email us at [email protected].

 

4. YOUR OPTIONS:

You have options regarding certain information we collect, how we communicate with you, and how we process personal data. You are not obligated to provide information, but if you decline to do so and it is necessary to use specific services, you may be unable to take advantage of them. Additionally, it is possible to adjust your browser settings to stop the automatic collection of certain data.

 

You have the option to opt-out of receiving email communications from us at any time by following the opt-out link or other unsubscribe instructions in any of our emails, by contacting us as specified in this Privacy Notice, or by changing your notification preferences in your account settings. If you want to opt-out by email, please include “Opt-Out” in the subject line and provide your name and the email address used for signing up for communication in the body. Note that if you do business with us in the future, subject to applicable law, certain automated notifications (e.g., order or subscription confirmations) may not be opt-out-able. 

 

You can limit or prevent us from receiving location information from you by denying or removing the permission for certain services to access it or deactivating location services on your device. Refer to your device manufacturer or operating system instructions for details on how to do this. 

 

For more information about controlling and/or opting out of certain web tracking technologies, cookies, and how to disable cookies, visit cookiesandyou.com.

 

5. PROTECTING YOUR PERSONAL DATA

To protect your personal data, we employ reasonable and appropriate physical, technical, and organisational safeguards to secure our systems and protect the confidentiality, integrity, availability, and resilience of personal data. This includes encrypting data where needed, performing backups, and testing our safeguards regularly. However, no security measures are completely foolproof. We cannot guarantee that our safeguards will be effective or sufficient, and data transmission over the internet is never 100% secure. Thus, we cannot guarantee that information you transmit using our Services will be secure.

 

6. RETENTION OF PERSONAL DATA

We keep personal data for six (6) months after a user closes their account and certain personal data for longer as needed to carry out the processing activities described in this notice, such as compliance with laws, regulations, rules, and requests from relevant law enforcement and government agencies, and to protect our and our partners’ rights, property, or safety, as well as the rights, property, and safety of our users and other third parties. By law, we must retain certain financial information for seven (7) years.

 

7. OTHER INFORMATION ABOUT PERSONAL DATA AND THE SERVICES

a. Identity Verification. To ensure that we do not knowingly offer our Services to or collect personal data from anyone under 18 or anyone using a false identity, we may require identity verification checks for Mentors and offer them as an option for Proteges. This involves sharing certain information with one or more of our current or future service providers (e.g. Ondato, Aristotle, and Jumio) for verification. If you start the registration process, you agree to have your personal data transferred to and processed by Ondato, Aristotle, and/or Jumio, in accordance with their respective privacy policies and terms and conditions. These services require submitting a passport or other government identification document and using facial analysis software to verify your identity. Ondato also requires you to provide a photo of yourself holding your government ID.

 

b. Payment Information. Payments made to Proteges for access to content are processed by third-party payment providers. When making a payment, you will provide the provider with your credit card number, expiration date, and security code. We do not receive your full credit card details; instead, we are provided with a "token" that represents your account, expiration date, card type, and the first two and last four digits of your card number. If you must provide your name and email address to the payment provider, they will also provide us with that information. Payments issued to Mentors for their content are made by Mentor Plus using bank account information that we have collected and stored.

 

c. Collection of Personal Data from Children. Our Services are not intended for anyone under 18 years of age. We do not knowingly collect personal data from children under the age of 18, and anyone under 18 is not permitted to use the Services. By using the Services, you are confirming that you are 18 years of age or older.

 

d. Third-Party Websites and Services. As a convenience, we may reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business. When you access these third-party services, you are leaving our Services and we are not responsible for nor do we control the content, security, or privacy practices employed by such third-party websites and services. You access these third-party services at your own risk. This Privacy Notice does not apply to any third-party services; please refer to the Privacy Notices or policies of such services for information on how they collect, use, and process personal data.

 

e. Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations, or assets to a third party, whether by merger, acquisition, or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be part of the assets transferred.

 

f. Do Not Track. We currently do not use any cross-site tracking technologies and do not process or comply with any web browser's "do not track" signal or similar mechanisms. You may find information about how to block or reject certain tracking technologies at cookiesandyou.com.

 

g. International Use. Your personal data may be stored and/or processed in the United States, as well as in the European Union and the United Kingdom. By using the Services, you acknowledge that we will transfer your data to and store your personal data in these countries, which may have different data protection rules than your country. Personal data may become accessible as permitted by law in these countries, including to law enforcement and/or national security authorities. For transfers of data into and out of the European Economic Area, we use data transfer agreements subject to EU-approved standard contractual clauses, as per Article 46 of the General Data Protection Regulation.

 

8. MODIFICATIONS AND UPDATES TO THIS PRIVACY POLICY

This Privacy Policy replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Policy, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Policy. We will use reasonable efforts to notify you of material changes to our processing activities and/or this Privacy Policy, such as by posting a notice on the Services or sending you an email. Your continued use of the Services following our posting of any revised Privacy Policy will constitute your acknowledgement of the amended Privacy Policy.

 

9. APPLICABILITY OF THIS PRIVACY POLICY

This Privacy Policy is subject to the Terms of Service and any Acceptable Use Policy that govern your use of the Services. It applies regardless of the means used to access or provide information through the Services.

This Privacy Policy does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and we are not responsible or liable for any third party's compliance therewith.

 

10. ADDITIONAL INFORMATION AND ASSISTANCE

If you have any questions or concerns about this Privacy Notice and/or how we process personal data, please contact us at [email protected]. 

This is also the method of contacting our Data Protection Officer (DPO), who is responsible for responding to questions, requests, and concerns in relation to this Privacy Notice and our use of personal data.

If we are unable to resolve your query or concern about our use of your information, you can contact the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.