Privacy Policy

Last modified: April 5, 2021

ProMentor ("Company" or "we" or “us”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes (i) the types of information we may collect from you or that you may provide Company when you engage with us, such as when you visit the website (our "Website") or download, install, or use our ProMentor Application (“App”), (ii) our practices for collecting, using, maintaining, protecting, and disclosing that information, and (iii) the responsibilities and rights you may have with respect to such information.

Please read this policy carefully to understand our policies and practices regarding your information and how we will process it. If you do not agree with our policies and practices, your choice is not to use our Website or App or otherwise engage with us or our services. By accessing or using this Website, or our App or services, you agree to this privacy policy.


For purposes of this policy, the term “personal information” refers to any information that, either alone or in conjunction with other data, can be used to distinguish or identify a particular individual and is subject to, or otherwise afforded protection under, a law, statute, or regulation governing data privacy or security.

Our Services Are Not Intended for Children

Our services, including our Website and App, are not intended for children under 13 years of age and we do not knowingly collect personal information from children under 13. If you are under 13, do not use our services or provide any information to us. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will undertake commercially reasonable measures to delete that information. If you believe we may have any information from or about a child under 13, please contact us.

Information We Collect About You and How We Collect It

We collect personal information and other data under a broad range of circumstances. When you do not provide personal information to us (as requested), you may not be able to use our Website or App, we may not be able to provide you the services you need, and/or we may not be able to complete a transaction, and you agree that Company will not be liable or otherwise responsible for any actions resulting therefrom. Generally, we collect the following types of personal information and data directly from you when you use our Website, App, or other services, or otherwise engage with us:

  • Identity data, such as your name, title, company/organization name, email address, telephone and fax numbers, physical address (including street, city, state, postal code, and/or country), and date of birth.
  • Registration data, such as information provided by you when you register for an account to use our Website or App, including usernames and passwords.
  • Business contact data, such as information related to other employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we may conduct, or possibly conduct, business activities.
  • Marketing and communications data, including your marketing preferences and your subscriptions to our publications.
  • Transaction data, including orders for our products and services and details of payments to and from you, including purchase history and preferences and (limited) payment card information.
  • Your feedback, including feedback from you about our Website as well as our services generally, which may include data gathered from any of our surveys in which you participate.
  • Correspondence data, including records and copies of your correspondence (including email addresses), if you contact us.

Usage Details. When you access and use the Website or our App, we may automatically collect certain details of your access to and use of the same, including traffic data, logs, and other communication data; the resources that you access and use on or through the Website or App; and, your device’s location. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, and mobile network information. Our Website and App also may access metadata and other information associated with other files stored on your device, such as photographs, audio and video clips, personal contacts, and address book information.

Cookies and Tracking Technologies. We use cookies on our Website and App. A cookie is a small file placed on your smartphone or device. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting you may be unable to access certain parts of our Website or App. Our email to you, and certain areas of our Website and App, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company analyze data on the users (e.g., recording the popularity of certain app content and verifying system and server integrity).

Third-Party Information Collection

When you use our Website or the App, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include: advertisers, ad networks, and ad servers; analytics companies; your mobile device manufacturer; and, your mobile service provider. These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information and Data

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

  • To present our Website and App to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account/subscription, including expiration and renewal notices.
  • To effectuate our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website and App or any products or services we offer or provide through our Website or App.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

How We Share and Disclose Your Information and Data

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business .
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company is among the assets transferred.
  • To third parties to market their products or services to you
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Website or App’s contractual terms of use or and other agreements, including for billing and collection purposes.
  • To third parties if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction

Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to us if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon any individual’s data privacy rights or privileges. You must never provide us with sensitive health information. IF YOU PROVIDE US WITH ANY PERSONAL INFORMATION ABOUT YOURSELF OR A THIRD PARTY, YOU EXPRESSLY REPRESENT AND WARRANT TO US THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO DISCLOSE SUCH PERSONAL INFORMATION TO US, WE CAN USE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY, AND YOU ARE IN COMPLIANCE WITH THE REQUIREMENTS SET FORTH HEREIN. You also agree to fully reimburse us for any damages, losses, or expenses that arise based on your violation of your representations, warranties and responsibilities set forth in this privacy policy.

Your Rights and Choices

Depending on the jurisdiction in which you reside, you may have certain rights and privileges related to your personal information, which are set forth here:

  • Marketing. You have the right to opt-out of receiving electronic direct marketing communications from us. The electronic direct marketing communications that you may receive from us, such as email messages, may give you an “unsubscribe” option of not receiving such communications in the future. You may also contact us directly to opt-out of receiving such communications. California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties whom we have reason to believe use such information for their own direct marketing purposes.
  • We Do Not Sell Information. Although we do not currently conduct sales of personal information, you may submit a request directing us to not sell your personal information that we maintain about you to third parties. Please send us such requests at the contact information list below.
  • Disabilities. We strive to ensure that every person has access to information related to our products and services, including this privacy policy. Please contact us if you would like this privacy policy provided in an alternative format and we will seek to meet your needs.
  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website or App may then be inaccessible or not function properly. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
  • Accessing and Correcting Your Information. You can review and change your personal information by logging into the Website or App, as applicable, and visiting your account profile page. You may also contact us to request access to or correct any personal information that you have provided to us. We will respond to any such request in our sole reasonable discretion.

User Contributions

You may also provide information for publication or display (“Posted”) on public areas of our Website or App (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.  Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or App. WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO OUR WEBSITES, APP, AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENTS THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION AND WE ARE NOT RESPONSIBLE FOR CIRCUMVENTION OF ANY PRIVACY SETTINGS OR SECURITY MEASURES CONTAINED ON THE WEBSITE OR APP. In the event you believe your username and/or password to our App or your account with us has been compromised, you must contact us immediately with respect to the same and change your username and/or password.

Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with products and services, to facilitate transactions you have requested, or to engage in marketing activities, and for so long as necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this privacy policy or to facilitate a legitimate business interest. We are based in the United States and the personal information that we collect and process is retained and stored in the United States. Please be aware that the United States may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States, your personal information may be accessible by, or otherwise made available to, government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations, applicable in the United States. By continuing to provide us such information, you hereby consent to your personal information being transferred to, and stored in, the United States.

Video Teleconferencing

We host and use video teleconferencing platforms to facilitate our services, conferences, meetings, training events, and other programs, including through our App. We may use online platforms that are owned and administered by a third-party service provider (e.g., Zoom, Cisco, or Microsoft). Please be aware that our video teleconferencing may record the content, sessions, conversations, and discussions thereon, and such records may be stored or retained by us or our third-party service providers. By participating in these events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and hereby consent to the recording of such activities, including on our App.

Third-Party Links

As a resource to you, our Website and App may include links to third-party websites. This privacy policy does not apply to such websites, and you should contact them directly for information regarding their privacy policies.

Do Not Track

We do not currently take steps to respond to browsers’ “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

Changes to Our Privacy Policy

We may amend this privacy policy, in whole or in part, at any time, for any reason, and in our sole discretion. If we make material changes to how we process personal information, we will provide notice of the same by updating the date of this policy. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any amendments.

Contact Information

To ask questions or comment about this privacy policy or our privacy practices, please contact us at any time at the following address:

ProMentor Inc.
2020 Front Street
Cuyahoga Falls, Ohio 44221.