Effective date: August 3, 2020
Last Revised: March 18, 2024
We at Mentra know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.
Remember that your use of Mentra’s Services is at all times subject to our Terms, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms.
What Does This Privacy Policy cover?
This Privacy Policy covers how we collect, use and disclose personally identifiable information (“personal information” or “information”) that we gather when you are accessing or using our Services, but not to the practices of companies we do not own or control, or people that we do not manage. We gather various types of personal information from our users, as explained in more detail below, and we use this personal information internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some personal information with third parties, but only as described below.
As noted in the Terms, we do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from an individual under age 18, we will delete that information as quickly as possible. If you believe that an individual under 18 may have provided us personal information, please contact us at support.mentra.com.
Information We Collect
We collect several types of information from and about you, depending on how you interact with our Services and Website. The information you provide, and that which we may collect, varies and may be disclosed by you knowingly or unknowingly depending on the type of data; this is all discussed in more detail below.
Information You Provide Us:
We receive and store information you knowingly provide to us through your use of our Services. The following list describes common types of information that we may collect from you.
Information We Collect from Job Seekers
Your Contact Information. We collect contact information you provide, such as your real name, email address, profile picture, zip code, phone number, login information and third-party account credentials, when you sign up for our Services. Certain information may be required to register an account with us or to use the full suite of features offered through our Services. Creation of an account with us is not a requirement for us to collect this type of information; see “Communications with Us” further down on this list.
Your phone number may be provided to Stytch, a third-party vendor, for the purposes of two-factor authentication. This phone number is stored securely by Stytch, and is stored according to their privacy policy. If your phone number is used for two-factor authentication, they will only use it for the sole purpose of two-factor authentication for your account (see "Third Party Vendors" for their privacy policy.)
Your Employment History. We collect employment information you provide, such as, your employment and education history, employment credentials (such as licenses or memberships), job preferences, and certain personal characteristics such as your military/veteran status. You can also provide other information such as your honors, awards, training, a personal website URL, and other information.
Demographics. We may collect your demographic information, such as your age, gender, and zip code. We may also ask you for optional demographic information such as citizenship, race, disability status, and ethnicity in connection with certain employment opportunities. Providing this information is entirely voluntary and will be used only for the purpose of providing the Services to you. Please note that this information may be considered “sensitive” or “sensitive personal information” under applicable law, and we will comply with applicable legal requirements in our collection and use of such information.
Your Content. We may collect content that you may voluntarily choose to submit or otherwise make available, whether in correspondence, message boards, or otherwise through our Services. For example, you may post your resume, work history, transcripts, photos and other application materials.
Inferred Information. Using the other information collected about you, we may draw inferences about you to help build a unique profile for what we believe to be your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes. This information is used to track the efficacy of our marketing efforts, understand which of our users are active on the platform, and tailor recommendations for candidates, services, and job roles.
Communications with Us. We may collect communication information if you contact us for customer service, to provide feedback, or to participate in a survey, and we may receive information such as your name, email address, and/or phone number in connection with the communication. As stated above, registration or creation of an account with us is not a requirement for us to collect this or any other type of information.
Information We Collect from Current or Potential Business Partners
Contact and Business Information. We may collect your information if you are an employee or agent of a company or other organization that is interested in learning about our Services, and you provide us with your information through the Services or other correspondence. We may collect your name and contact information, your organization’s name, your organization’s postal address, and any other information you choose to provide.
Commercial Information. We collect information regarding products or services you may order from us or provide to us, and information necessary for us to maintain our commercial relationship.
Communications. We may communicate with you if you have provided us with the means to do so. We may also collect any information derived from correspondence and survey or questionnaire responses.
Information Collected Automatically
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include certain information, as described below:
Usage Data. We collect and analyze usage information, including your IP address, geolocation data, “cookie” information, dates, times, the type of browser used to access our Services, and the page or features you request. We also may collect information regarding your interaction with our Website and any advertisements such as error logs, mouse movements, scroll activity, and keystroke data.
Device Data. We collect and analyze data relating to the device(s) you use to access our Services. This information may include your IP Address, general device identification, device hardware, operating systems and version of the operating system, browser, language preferences, unique device identifiers such as mobile ID or advertising IDs, and other device ID and similar information.
Geographic Data. We collect general location (city and state) information from your computer or mobile device when you use the Services. We may also request that you provide your zip code. This information allows us to recommend jobs or other content based on your general location. With your permission, we may also collect precise geolocation information from your device, passed to us from third-party services or GPS-enabled devices that you have set up.
Information Collected from Other Websites and Do Not Track Policy
When you visit our Website, we or our service providers may collect information about you and your use of our Services through the use of cookies and similar technologies such as ad tags (together “cookies”) placed on your browser or device. Just like any other usage information we collect, this information allows us to improve the Services, provide you with a more personalized online experience, for account authentication, personalized advertisements, saving of preferences and otherwise as described in this Privacy Policy.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services may not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.
Third Party Vendors
As part of using our website, we use several third-party vendors that may or may not collect personal information about you. Below is a list of all third-party vendors that may or may not collect your personal information, the vendor's privacy policy, and why this information is necessary for them to collect.
| Title | Privacy Policy | Purpose |
|---|---|---|
| Meta (Facebook Pixel) | https://www.facebook.com/policy.php | The Facebook Pixel is used for conversion tracking, ad optimization, and remarketing activities. |
| Wix | https://www.wix.com/about/privacy | CMS for mentra.com, tell visitors about Mentra, our mission, our team, and how to sign up |
| Stytch | https://stytch.com/legal/privacy-policy | Platform identity management and access, SSO connections |
| Sovren | https://www.sovren.com/policies-and-agreements/privacy-policy/ | Resume parsing |
| Sentry | https://sentry.io/privacy/ | Error tracking, performance monitoring, connection of errors to the originating page and user |
| OpenAI | https://openai.com/policies/privacy-policy | Powers with "Neuro" our chat bot, job description parsing |
| OneSignal | https://onesignal.com/privacy_policy | Push notifications for Twilio-based chat and other transactional platform actions |
| HubSpot | https://legal.hubspot.com/privacy-policy | Support database, chat with visitors, maintain records of correspondence, monitor user behavior |
| FullStory | https://www.fullstory.com/legal/privacy-policy/ | Track user behavior over time, identify errors across our site, monitor platform performance and errors |
| Google SSO, Analytics and Tag Manager | https://policies.google.com/privacy | Data collection and analysis for how users browse our website, single-sign on for jobseekers |
| Affinda | https://www.affinda.com/privacy-and-data-protection-policy | Resume parsing and redaction |
Google Analytics and Google Tag Manager
We use Google Analytics, Google Tag Manager to collect and analyze data about how visitors interact with our website. These tools help us better understand user behavior and improve our website's performance and content. Here's how we use them:
Google Analytics: Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. It helps us gain insights into how visitors find and navigate our site. The information collected includes:
User Demographics: This data helps us understand the age, gender, and interests of our visitors.
Geographic Information: We can see where our visitors are located, which helps us tailor our content accordingly.
Page Views: We track which pages are most popular to improve their content.
Referral Sources: We can see how users find our website, such as through search engines, social media, or direct visits.
Device and Browser Information: This data helps us optimize our site for different devices and browsers.
Google Analytics uses cookies to collect this information, and we have implemented IP anonymization to protect your privacy. You can opt-out of Google Analytics by using the Google Analytics Opt-Out Browser Add-on.
Google Tag Manager: Google Tag Manager is a tag management system that allows us to manage and deploy various tracking codes, including Google Analytics, more efficiently. It helps us streamline our website's performance and data collection processes.
By using Google Analytics and Google Tag Manager, we aim to provide you with a better user experience and continually enhance our website's content and functionality. Please note that while these tools collect data, we do not collect any personally identifiable information unless explicitly provided by you.
Additionally, we use Google's single signon product to allow jobseekers to signup and signin to Mentra using their Google account. Use of this feature is completely optional. The only information collected from this process is your name, Google email address, and a unique identifier to associate your Mentra account with your Google account.
If you have any concerns about the use of Google Analytics or Google Tag Manager on our website or would like to opt-out of tracking, please refer to "Opting out of Sales" for more information on how to manage your preferences.
California Privacy Notice
If you are a California resident, please see section “California Privacy Notice” withing this Privacy Policy.
How We Use the Personal information We Collect
Mentra and our service providers use the information we collect for the business and operational purposes described below:
Provide and operate the Website and Services
Analyze, improve, personalize, enhance, and promote our Services
Conduct research, both specifically relating to our current or future Services, but also generally as it relates to the market in which Mentra operates
Detect and prevent fraud and abuse
Protect Mentra, our users, you and others; enforce any legal terms that govern use of our Services
Conduct any surveys or questionnaires
Communicate with you; provide customer support, including responding to questions, requests, and issue
Analyze, improve, and prevent discriminatory practices both with internal algorithmic applications and from other users, service providers or others engaged in or using our Services
Comply with laws, regulations, and other legal processes and procedures
Combined, Aggregated, and /or De-identified Information
We may combine information you provide to us with information we collect automatically and through cookies to help us with the business and operational purposes described above. The combined information will be used in accordance with this Privacy Policy. We may also aggregate and/or de-identify other information in such a way that the information cannot reasonably be tracked or linked to you or your device. We may use de-identified or aggregated data for any purpose, including for research and marketing purposes, and we may disclose such data to any third parties, including consultants, advertisers, promotional partners, and others.
How We Disclose the Personal information We Collect
Mentra discloses the information we collect from and about you for the following business and operational purposes:
Potential Employers. To provide the Service, we may disclose your contact information and employment information with potential employers, as well as with their affiliates, agencies and service providers.
User Profiles and Usage. Certain user profile information, including your name, location, and any video or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account’s “Privacy Settings” may allow you to limit what information other users can see. Please remember that any content you upload to your public user profile, along with any personal information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your username may also be displayed to other users if you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments.
Advertisers. We allow advertisers and/or merchant partners (“advertiser”) to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any Information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in Atlanta to show you ads or offers for Atlanta businesses, but we will not tell such businesses who you are. Or we might allow advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.
Service Providers. We may employ or partner with other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the information we share with them beyond what is necessary to assist us. Note that an “agent” may also be considered a “partner” in certain circumstances and may be subject to the terms of the “Combined, Aggregate and/or De-Identified Information” section above in that regard.
Affiliates. In certain situations, businesses or third-party websites we are affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.
Protection of Mentra and Others. We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms https://www.mentra.com/terms-and-conditions and other agreements; or protect the rights, property, or safety of Mentra, our employees, our users, or others.
Business Transfers. We may choose to buy or sell assets and may share and/or transfer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.
Your Consent. If you consent to our disclosure of your information, Mentra will disclose your information consistent with your consent.
Your Rights and Choices
You have the following rights and choices with respect to your information:
Rights Regarding Your Information
Depending on where you live, you may have certain rights with respect to your personal information. We extend these rights to all individuals who are entitled to such rights under applicable law and may extend some or all of these rights to all individuals, regardless of residency, subject to this Privacy Policy. Specifically, applicable individuals have the right to ask us to:
Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information (“right to know”).
Provide you access to and/or a copy of certain personal information we hold about you in some cases in a portable format, if technically feasible.
Correct or update personal information we hold about you.
Delete certain personal information we have about you. See “Right to Delete” section below.
Opt-out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (“right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request and reach out to you if we believe that we are unable to delete your account. If we find that your request can be fulfilled, your account will be deleted 30 days from the time that the request is initiated. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
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 information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your, or your dependent’s, right to know or right to delete described above, please submit a request by either:
Calling us at (415) 376-8480; or
Emailing us at support@mentra.com
Only you, or a legally authorized agent to act on your behalf, may make a request to know or delete related to your personal information. You may designate an authorized agent to submit certain requests on your behalf by providing the authorized agent with signed, written permission to make such requests or a power of attorney; either document must be supplied to us prior to responding to any request. We may also follow up with you to verify your identity before processing the authorized agent's request.
You may only submit a Request to Know twice within a 12-month period. Your request to know or delete must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
Name and Email Address;
Authorized Agent permission form or power of attorney;
Additional verification information dependent on the sensitivity of information requested;
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.
You do not need to create an account with us to submit a request regarding your right to know or right to delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by requesting in writing to support@mentra.com. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your personal information after you update or delete it, but not in a manner that would identify you personally.
For instructions on exercising your sale opt-out or opt-in rights, see “Opting Out of Sales/Sharing of Personal Information” below. However, if you refuse to provide personal information or request the deletion of personal information necessary for us to provide you with our Services, we may not be able to complete the transaction or provide the quality of Services expected by you.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email support@mentra.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 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 by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity 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.
Opting Out of Sales/Sharing of Personal information
We do not currently sell the personal information of users, however personal information may be visible to third parties, Affiliates, and Partners during the normal course of business and according to their contracts with us. These disclosures may be considered a “sale” of personal information for targeted advertising purposes under applicable law. You do have the ability to direct what personal information is available for disclosure to these third parties at any time through the “Privacy Settings” found in your account. You may opt-in or opt-out of disclosures at any time.
You do not need to create an account with us to exercise your opt-out rights. If you do not have an active Mentra account, please either: call us at (415) 376-8480 or email us at support@mentra.com. We will only use personal information provided in an opt-out request to review and comply with the request.
How We Protect the Personal Information We Collect and Store
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We endeavor to protect the privacy of your account and other personal information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
Minors
Mentra.com and its Services are not intended for minors and, per our Terms, users must be 18 years of age to use our website. We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register to use the service. No one under the age of 18 is allowed to provide any personal information to or on Mentra.com or its services. If you become aware that a child has provided us with personal information without parental consent, please contact us. If we become aware that a child under 18 years of age has provided us with personally identifiable information, we will delete such information as quickly as possible.
California Privacy Notice
This California Privacy Notice (“Notice) gives California residents the additional information about our information collection and use practices required by the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020. Any term capitalized in this Notice but not defined herein, has the definition as found within this Privacy Policy.
This Notice provides information about the categories of personal information that we collect from California residents, the purposes for which we use the information, the categories of third parties to whom we disclose the information for business purposes, out “sales” and “sharing” of information, and retention practices. Personal information does not include: (a) publicly available information from government records; or (b) deidentified or aggregated consumer information.
Geolocation Information
Such as your approximate location based on IP address or precise location (with your consent)
Provide the Services and customer service
Personalize your experience and customize the Services
Improve the Services
Understand your interest and engage in analysis
Engage in marketing and advertising
Detect bugs and identify errors and improve the Services
Increase security, prevent fraud, and promote legal compliance
Service Providers
Ad networks and advertising partners
Affiliates
Entities to assist with legal and security purposes
Entities in connection with sales or transfer of business assets
Others, with your consent
Protected Information
Such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Provide the Services and customer service
Improve the Services
Understand your interest and engage in analysis
Detect bugs and identify errors and improve the Services
Increase security, prevent fraud, and promote legal compliance
To mitigate bias and discrimination in our matching algorithm and practices
Ensure job recommendations are tailored to physical and mental needs and preferences
Potential employer, employment agencies, and other business partners
Service Providers
Affiliates
Entities to assist with legal and security purposes
Entities in connection with sales or transfer of business assets
Others, with your consent
Other Information
Any other information that you provide in the course of using the Services
Purposes of use will depend on the additional information provided
Disclosure will depend on the additional information provided
Categories of Information collected
Purpose of use
Categories of third parties to whom we disclose the information for business and operational purposes
Identifiers
Such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, or other similar identifiers.
Register users
Provide the Services and customer services
Communicate with you
Personalize your experience and customize the Services
Understand your interest and engage in analysis
Engage in marketing and advertising
Detect bugs and identify errors and improve the Services
Increase security, prevent fraud, and promote legal compliance
Potential employer, employment agencies, and other business partners
Service Providers
Service providers for employers and agencies
Ad networks and advertising partners
Affiliates
Entities to assist with legal and security purposes
Entities in connection with sales or transfer of business assets
Others, with your consent
Commercial Information
Such as transaction history
Provide the Services and customer services
Understand interest and engage in analysis
Communicate with you
Personalize your experience and customize the Services
Engage in marketing and advertising
Detect bugs and identify errors and improve the Services
Increase security, prevent fraud, and promote legal compliance
Service Providers
Affiliates
Entities to assist with legal and security purposes
Entities in connection with sales or transfer of business assets
Others, with your consent
User-generated content and demographic Information
Such as any user-generated content you voluntarily decide to upload on the Services, or other information you provide in connection with your account such as your resume
Provide the Services and customer service
Improve the Services
Understand your interest and engage in analysis
Detect bugs and identify errors and improve the Services
Increase security, prevent fraud, and promote legal compliance
Potential employer, employment agencies, and other business partners
Service Providers
Service providers for employers and agencies
Affiliates
Entities to assist with legal and security purposes
Entities in connection with sales or transfer of business assets
Others, with your consent
Internet Network and Device Activity Data
Such as browsing information and usage information
Provide the Services and customer service
Personalize your experience and customize the Services
Improve the Services
Understand your interest and engage in analysis
Engage in marketing and advertising
Detect bugs and identify errors and improve the Services
Increase security, prevent fraud, and promote legal compliance
Service Providers
Ad networks and advertising partners
Affiliates
Entities to assist with legal and security purposes
Entities in connection with sales or transfer of business assets
Others, with your consent
Sale and Sharing of Personal Information
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
As explained in “How We Disclose the Personal information We Collect,” we sometimes disclose personal information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our Services, or use analytics partners to assist us in analyzing use of our services and our user/customer base. The disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information under the CCPA, or, the “sharing” of your personal information for purposes of “cross-context behavioral advertising.”
The following chart lists the categories of personal information we have sold or shared over the last 12 months and the categories of third parties to which we have sold or shared:
Categories of Information collected
Categories of Third Parties to Which we Have “Sold” this PI
Categories of Third Parties to Which we Have “Shared” this PI
Identifiers
Ad networks and advertising partners; Analytics providers
Ad networks and advertising partners
Internet network and device activity data
Ad networks and advertising partners; Analytics providers
Ad networks and advertising partners; Analytics providers
If you would like to opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered a “sale” or “sharing,” please refer to the “Your Rights and Choices” section of this Privacy Policy.
Sensitive Personal Information
The CPPA provides consumers with the "right to limit" the use of their "sensitive personal information" (as defined in the CCPA) to certain business purposes. As explained in our Privacy Policy, we may ask you for optional demographic information such as citizenship, race, disability status, and ethnicity in connection with certain employment opportunities. Your provision of this information is entirely voluntary, and will be used only for purposes in connection with providing the Services to you. This information may be considered "sensitive personal information" under the CCPA. However, please note that we do not use sensitive personal information for purposes for which the "right to limit" applies.
“Shine the Light” Disclosure
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information about whether we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To make such a request, please email us at support@mentra.com.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA 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.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. If you ask a us to delete or stop selling your personal information through changes in your account settings, you may not be able to continue participating in the special deals they offer in exchange for personal information.
Data Breach Notification
At Mentra, we take the security and privacy of your data seriously. In the event of a data breach that may compromise the security of your personal information, we have established a comprehensive process to promptly notify affected data subjects. Our commitment is to keep you informed and take appropriate steps to mitigate the potential impact of any such breach.
Notification Process:
Identification and Assessment: Our security team continuously monitors our systems for any unusual activities or potential security threats. If a breach is suspected, we conduct a thorough assessment to determine the scope and nature of the breach.
Notification to Authorities: If required by applicable data protection laws, we will promptly report the breach to the relevant supervisory authorities.
Notification to Affected Data Subjects: If we determine that the breach poses a risk to your personal information, we will notify affected data subjects without undue delay. We will communicate the following information:
A description of the breach, including the types of data involved.
Steps we are taking to investigate and mitigate the breach.
Recommendations for you to protect yourself, if applicable.
Contact information for our Data Protection Officer or designated representative.
Timely Communication:
We understand the importance of timely notification. Our goal is to provide you with clear and transparent information about any data breach that affects your personal information. We will strive to notify affected data subjects within the timeframe required by applicable data protection laws.
Your Responsibility:
To help us protect your personal information, please keep your contact information up to date in your account profile. This ensures that we can reach you in the event of a data breach.
Questions and Concerns:
If you have any questions, concerns, or believe that your personal information may have been compromised in a data breach, please contact us immediately using the contact information provided in the "Contact Information" section. We are committed to maintaining the security and privacy of your data and will take all necessary steps to address and rectify any breach promptly.
Changes to Our Privacy Policy
We are constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the Services, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you have not provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all changes.
Contact Information
If you have any questions or comments about this notice, the ways in which Mentra collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us at:
Phone: (415) 376-8480
Email: Support@Mentra.com
Address:
Mentra, Inc.
9805 Statesville Road
Suite 6169
Charlotte, NC 28269
If you need to access this Policy in an alternative format for accessibility purposes, please contact Support@Mentra.com or (415) 376-8480.