TWO HANDS MENTORING, INC.
D/B/A WORTHY MENTORING
PRIVACY POLICY

Last Updated: 04/19/2019

Introduction

This Privacy Policy explains the types of information the nonprofit Two Hands Mentoring, Inc. d/b/a Worthy Mentoring (“Organization”, “we”, or “us”) collect about you, how we use that information, and when and how you can limit our use of that information. These practices relate to information collected by us on worthymentoring.org (the “Website”) and in email or other electronic messages between you and this Website (the “Communications”), or through our digital application (the “App”, and together with the Website, the “Products”). Together, the Website and the Communications are the “Services”. Please read this Privacy Policy carefully.

Protecting your private information is our priority. By submitting your information as set forth herein, you consent to the use of that information as described in this Privacy Policy; provided however, that for users whose personal data is governed by the terms of the General Data Protection Regulation 2016/679 (the “GDPR”), such consent and the lawful basis for use of such personal data shall be governed by the GDPR and used by Worthy pursuant to the lawful basis as set out below. Our privacy practices may change. Any such changes will be reflected in our Privacy Policy, which when updated will be posted on this page. You are not required to provide the information described below. Your continued use of our services or use of the Services after we post any changes to this Privacy Policy signifies your acceptance of the updated terms, so please check the policy periodically for updates. You acknowledge that by inquiring about or using our services or accessing or using our Products you agree to be bound by all of its terms and conditions. If you do not agree to these terms, please do not inquire about or use our services or access or use the Services.

Age Restrictions

We do not target our sites or services to children under the age of 13, and in compliance with the Children’s Online Privacy Protection Act, any personal information we may receive from users we believe to be under the age of 13 will be purged from our database.

To use the mentor/mentee matchmaking services, we require users to be at least 18 years of age. If you are not 18 years of age, please do not use the mentor/mentee matchmaking services, and instead refer to the alternative resources for mentorship and support noted on the Products.

Information We Collect About You and How We Collect It

In providing better Services to you and helping you develop meaningful connections with mentors and mentees, we may collect information about you in several ways, including through your correspondence if you contact us, automatically as you navigate through the Services, and directly from you when you provide it to us either offline or on these Services, such as through the mentor/mentee matchmaking application. The information we collect includes:

Where We Store Your Information

We may collect and store information (including personal and non-personal information) locally on your device or within your web browser application. We also may store such information on our databases.

We are a nonprofit organization headquartered in California, and your personal information may be stored and processed outside your country of residence. The personal information we collect is processed in accordance with this Privacy Policy and the applicable law, wherever your information is located. We have networks, databases, servers, systems, and support located in the United States, and may work together with third parties around the world.

For further information on international transfers of your personal information outside the European Economic Area (the “EEA”), please see further below.

Retention of Your Personal Information

We will retain your personal information for as long as we reasonably require it for legal or business purposes. This period will be determined on the basis of applicable legal requirements and business purposes. When such periods end or we no longer need your personal information, we will securely delete or destroy it.

Accessing, Managing, and Deleting Your Information

If your personal data is governed by the GDPR, you have the right to request access to and manage the personal information relating to you that we store and process:

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

Consent to Transfers Outside the EEA

If originating in the EEA, please be aware that we may transfer your personal information outside of the EEA to where the Services are operated within the United States, and to your matched mentor or mentee in the United States or in other jurisdictions. We may also make similar transfers outside of the EEA where you have explicitly consented or where we consider this to be necessary for important reasons of public interest or to establish, exercise, or defend legal claims. If jurisdictions outside of the EEA do not provide the same level of data protection as your country of residence in the EEA, we take measures to ensure appropriate level of protection for your personal information.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to help@worthymentoring.org.

Data Security

We apply security measures that we believe are reasonable and appropriate that are designed to protect your personal information that is under our control from unauthorized access, use, or disclosure. We apply security measures that we believe are reasonable and appropriate that are designed to protect your personal information that is under our control from unauthorized access, use, or disclosure. Where you have a password that enables you to access our Services, you are responsible for keeping this password secure and confidential.

Unfortunately, the transmission of information via the internet is not completely secure. Although we work hard to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. While we will take all steps reasonable necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, you acknowledge that the laws, regulations, and standards of the United States, in which your information is stored or processed, may be different from those of your own country. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in our Services.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will also notify you through notices on our Website. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Services and this Privacy Policy to check for any changes.

Contact Information

To access or update your information, to stop receiving communications from Two Hands Mentoring, Inc. d/b/a Worthy Mentoring (as data controller), or to ask questions or comment about this Privacy Policy and our privacy practices, contact us by email at help@worthymentoring.org:

If you contact us in writing, please include your old and new contact information so we can make the appropriate corrections. Please note that, in order to verify that we are communicating with you or someone authorized to act on your behalf, we may make access to your personal information conditional on the verification of certain information previously provided by you.

Your Right to Complain

If you have provided personal information from within the EU, and you feel that we have not resolved your complaint to your satisfaction and you wish to make a formal complaint to the relevant national data protection authority in the EU, you can find the relevant details at ec.europa.eu.

UK/EU Users – Use of Personal Data

We use your personal data to resolve disputes, troubleshoot problems and enforce our Terms of Service.

Under EU and UK data protection laws, we are only permitted to use your data when we have a lawful basis to do so. The table below provides an overview of the legal bases that we rely on to use your data. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interest, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).

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