Privacy Policy – Mentora Foundation®

Effective Date: February 15, 2022 (There are no prior versions of our privacy policy.)

Mentora Foundation (the “Foundation”) is a Delaware not-for-profit corporation that is an IRC § 501(c)(3) tax-exempt private operating foundation.  We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. This privacy policy applies to personal data that you may submit through the Foundation’s website or by other means.

Mentora Foundation
Mentora Foundation was formed in 2018 by Professor Hitendra Wadhwa, an instructor of personal leadership at Columbia Business School and the owner of the executive leadership company Mentora Institute. Professor Wadhwa formed the Foundation to respond to important social, functional, and spiritual needs in challenged parts of the world. Mentora Foundation follows the basic eleemosynary purposes set forth in its certificate of incorporation including engaging exclusively in charitable, artistic, educational, spiritual, and scientific purposes. Under Professor Wadhwa’s support and guidance, the Foundation provides educational and training programs to appropriate disadvantaged and challenged individuals, organizations, and communities in various parts of the world, and then works with them to foster positive growth and development. This is accomplished through using new tools in the field of personal leadership and development and applying them to those in fragile and challenged circumstances so that they may directly shape the future of their lives, communities, and countries. The Foundation works cooperatively with governments, businesses, multilateral organizations, spiritual groups, and civil society to increase and facilitate self-growth, development, spiritual awakening, and achieving constructive goals. The Foundation also captures, collects, and analyzes data related to individual and organizational effectiveness, and uses these findings to advance the science and understanding of management and personal leadership. The Foundation shares accurate, representative, and widely-applicable insights with (i) individuals to spur constructive dialogue, and (ii) with decision makers to develop more durable, effective, and productive outcomes. The Foundation’s mission is to use the science of personal leadership to drive innovation, understanding, and positive growth among individuals, communities, and governments in challenged and developing societies. The Foundation also supports other tax-exempt organizations that are aligned with the Foundation’’s goals for human development and dedicated to spiritual leadership and advancement. The Foundation accepts donations, which for US donors are usually tax deductible (consult with your accountant). To learn more about the Foundation and its activities, please visit our website at www.mentora.foundation.

Summary of Privacy Policy

1. Important information and who we are

Purpose of this privacy notice

This privacy policy provides you with information on how the Foundation collects and processes your personal data through your use of our website, https://mentora.foundation, as well as other possible portals, apps or other data collection means which make reference to this policy. For purposes of this privacy policy, the terms “user”, “participant”, “customer”, “you” and “your” are meant to refer to the individuals about whom we may collect data.

Our data operations and privacy policy endeavor to comply with the latest US and international privacy and data protection regulations.  These regulations include those promulgated under the European Union’s General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) where applicable. While GDPR regulations apply only to residents of the European Economic Area (“EEA”), we have decided to adopt and implement these regulations for all individuals who submit personal data to the Foundation. By doing this, along with implementing strict data protection standards from other jurisdictions such as California, we provide you with expansive rights with respect to any personal data that we collect from you. Some of these rights include the following:

We take your personal data and privacy seriously. If you have any questions regarding your rights, your personal data, or the Foundation’s obligations, please contact the Foundation’s Data Protection Officer at privacy@mentora.foundation.

Your rights under GDPR are further described below in Section 11. Some of your rights described in this policy may be subject to certain rights of the Foundation such as legal, accounting, and archiving requirements.

For more details regarding your rights and the Foundation’s obligations under GDPR, this Wikipedia article offers a good summary here.

Detailed information regarding GDPR andrelated legislation and directives, may be viewed at this link.

Information about the California Consumer Privacy Act may be found at this link.

Controller

When we mention "the Foundation", "we", "us" or "our" in this privacy policy, we are referring to Mentora Foundation, the company that is responsible for processing your data. For individuals located in the European Economic Area, the Foundation is the data controller, as that term is defined by GDPR.

Contact details

The Foundation’s Data Protection Officer (“DPO”) is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise any rights that may be afforded to you, please contact the DPO at privacy Mentora.Institute or using the details set out below:

     Attention: Data Processing Officer
     Mentora Foundation
     170 West 81st Street, Suite 8D
     New York NY 10024 USA

The Foundation Website, Portals and Apps

The Foundation’s website, apps, digital platform, content, services, trademark, and other intellectual property, are owned or licensed by the Foundation.

Your privacy in engaging with the Foundation’s website and technology platforms is very important to us. With that in mind, we have established information handling practices for the Foundation intended to guard and respect your privacy. We believe these practices are consistent with GDPR and the best practices of websites providing foundation information and services. This privacy policy applies to all Foundation digital platforms and includes the information we collect about you, when and how we collect that information, how that information is used, how we safeguard that information, and our procedures for archiving and deleting that information.  This privacy policy applies primarily to the personal information such as your name and email address that you submit through this website or other digital platforms.

2. The Information We Collect About You

Information We Collect Automatically

When you visit our website, our servers automatically collect certain browser or device generated information, which may in some cases constitute personal data, including but not limited to:

Information You Provide

Typically, the personal data you give us may include name, address, telephone number, email address, mental health issues, aspirations, and any personal details required to resolve any inquiries or complaints. Your personal data may also include your login name and passcode, and information that you supply and upload to the Foundation digital servers as part of how the website is designed to be used.

Personal data may also be required to enter into an arrangement with you or to perform an agreement with you (such as to provide programs or consulting services for you), and failure to provide any information may result in our inability to provide requested services or products.

Third-Party Servers

The Foundation relies on established and trustworthy third-party vendors located in the United States to provide much of the data storage and usage requirements for the Foundation.  The personal data you submit to us through a Contact Us page, an email sign-up on our website, or through other digital platforms, if any, are stored and processed at secure servers in compliance with GDPR.  The Foundation may change the third-party data processors it uses. the Foundation and its technology team will perform due diligence on any new processors that it uses, and make sure that they meet the highest quality standards of privacy and security, including GDPR.

Information From Other Sources

We may receive information about you if you use any other websites or portals we may operate, any other services we provide, seminars, webinars, or classes we teach, or from our activity partners or data processors instructed to collect information on our behalf.

Cookies

Our website may use cookies. A cookie is a small file of letters and numbers that we put on your computer or smartphone if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website or watch our media, and also allows us to improve our site and platform.  If you have any questions regarding our use of cookies, please contact our DPO at privacy@mentora.foundation.

3. Use of Personal Data

The following is an overview of our purposes for using your personal data. Additional details on how we process your personal data may be provided to you in a separate notice or agreement.

In accordance with GDPR, all of our processing and use of your personal data is justified by a "condition" for processing. In the majority of cases, processing will be justified on the basis that:

We use the personal data we collect to conduct and develop our services with you and with others, as more fully described below:

The Foundation respects and safeguards your personal data and will never sell or rent it to third parties.

4. Disclosure of Personal Data

The Foundation will share personal data obtained through this website and digital platforms with its appointed third-party service providers (who will operate under our instructions) to assist us in providing information or services to you, in conducting and managing our services and the website. The Foundation may share your personal data (but not your confidential information) with these affiliates and third parties to perform services that the third parties have been engaged by the Foundation to perform on the Foundation’s behalf, subject to appropriate contractual restrictions and security measures.

We are also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We may be required to disclose personal information that we handle in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If your personal data is transferred outside the EU to the Foundation or its third-party service providers, we will take steps to ensure that your personal data receives the same level of protection as if it remained within the EU, including by assuring that the Foundation and its service providers have entered into data transfer agreements using the European Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield. For transfers of personal data between the Foundation and its service providers we will use best efforts to make sure that the service providers have in place European Commission approved Standard Contractual Clauses. The list of all the countries to which your personal data is transferred is set forth here: The United States. You have a right to obtain details of the mechanism under which your personal data is transferred outside of the EU by contacting privacy@mentora.foundation.

The Foundation reserves the right to share any information that you provide which is not deemed personal data or is not otherwise subject to contractual restrictions.  These restrictions on the disclosure of your personal data will not affect our use of your data as stated in Section 3, above.

5. EU-U.S. and Swiss-U.S. Privacy Shield

The Foundation is not a registered member of the EU-U.S. Privacy Shield Framework but complies with its data protection principles as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union member countries and Switzerland. The Foundation adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, and access. To learn more about the Privacy Shield principles, please visit https://www.privacyshield.gov/.

In accordance with the Privacy Shield Principles, the Foundation commits to resolving complaints about your privacy and our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding this Privacy Shield Policy or the Foundation’s Privacy Policy should first contact the Foundation at: privacy@mentora.foundation.

The Foundation conducts in-house verifications to ensure that its attestations and assertions with regard to its treatment of personal data are accurate and that the company has appropriately implemented these practices.

6. Children

The website is not for use by children under the age of 16 years and the Foundation does not knowingly collect, store, share or use the personal data of children under 16 years. If you are under the age of 16 years, please do not provide any personal data, even if prompted by the website to do so. If you are under the age of 16 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify the Foundation and the Foundation will delete all such personal data immediately.

7. Marketing Emails

Where lawful to do so, and subject to your consent where required, we may communicate with you by email to tell you about our products and services. If you wish to opt-out of receiving marketing communications, please use the 'unsubscribe' link provided in our emails, or otherwise contact us directly and we will stop sending you communications.

8. SeCurity

The Foundation strives to safeguard and protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and the Foundation utilizes and maintains certain reasonable processes, systems, and technologies to do so. However, you acknowledge that no transmission over the Internet is completely secure or error-free, and that these processes, systems, and technologies utilized and maintained by the Foundation are subject to compromise. Accordingly, we cannot be held responsible for unauthorized or unintended access that is beyond our reasonable control.

9. Retention of Your Personal Data

We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. We also retain your personal data for a period of time corresponding to a statute of limitations, for example to maintain an accurate record of your transactions with us including licenses that you have entered with us.

However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.

At any time, you can request our DPO to permanently delete your data not subject to legal or other requirements.  You can also always unsubscribe to our emails, in which case we will delete your personal information other than licenses and other matters that survive your request for deletion.

11. Your Rights

Under applicable law, you may have the following rights:

For further information regarding your dataprivacy rights under GDPR, please see the following link: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

13. Changes to this Policy

Any changes or updates we may make to this policy will be posted as a revised policy with a new date stated at the top of this document. You are responsible for checking back to review any revised policy.

Please address any questions or comments you might have to privacy@mentora.foundation.