Last modified: April 6, 2021
Data Controller information. Overview information.
If you are a citizen of the EU (European Union) you could e-mail the contact person in MentorMate for the processing of your personal data: Eleonora Georgieva, e-mail for contact: [email protected]
If you have any inquiries regarding the processing of your personal data, please contact us.
2. Personal data
Personal data is all data that relates to you personally as a data subject and enables your direct or indirect identification. The data includes information such as name, address, phone number and date of birth. Information that cannot be linked to your identification, such as favorite websites or the number of users of a site, is not considered personal data.
3. Purposes of processing. Legal basis for processing.
MentorMate processes personal data only if necessary or based upon your consent. The purposes of processing and the legal grounds are the following:
3.1 For the performance of a contract or in the context of a pre-contractual relationship
For pre-contractual and contractual reasons, we need personal data to offer and provide our services and products, to comply with the obligations arising from our pre-contractual relations and contractual agreements with you or the entities you represent.
The data may be processed for communication and response to inquiries and transactions, for provision of products and services, for the administration of customer accounts, including for management and maintenance of our products and services, for corrections, improvements and updates, etc.
We use the received personal data and other data to better understand our customers and visitors on our Website and the way they interact with it. MentorMate uses the information and personal data to improve its customer experience, implement your choices, get to know you better, maintain and improve the accuracy of the information it stores about you, improve the quality and reliability of its products, services and Website, identify problems and undertake actions as well as to improve the accuracy of our records.
The legal basis is usually Art. 6 (1) b) of the GDPR since the processing is required for the performance of a contract or the pre-contractual relationship initiated by you.
3.2 For fulfillment of regulatory obligations applicable to MentorMate
MentorMate has legal requirements to collect and store for certain evidence of identification of the persons with whom it enters into a relationship, as well as to store information in connection with payments made and received by contractors. In such limited cases, your personal data as representing the client will be stored until the expiration of the statutory deadlines under Bulgarian law.
The legal basis in this case is Art. 6 (1) c) of the GDPR – processing is necessary to comply with a legal obligation that applies to the administrator.
3.3 For marketing purposes
If you give consent to MentorMate by subscribing to our newsletter, your personal data (name, e-mail, address) will be processed to provide you with the latest information on offers, news, products and services. Also, based on your consent, we will contact you to provide information about our events or partner events in which we participate and a profile of the event. If you are participating in a MentorMate event or a partner event, MentorMate may post a photo on our Website for publication purposes about the event.
You have the right to object at any time to the processing of personal data for marketing purposes. To exercise your right, simply contact us using the contact details above or click the link in the marketing message. You can withdraw your consent at any time. If you unsubscribe from our emails and newsletters or withdraw your consent, the relevant data will be removed or blocked from the list and will no longer be processed for these purposes unless you provide new consent for their processing for marketing purposes.
If you are a regular visitor to our Website and/or seem interested in our product portfolio, you may be shown a teaser with an invitation to contact us voluntarily.
If the personal data is processed based on explicit consent, including for marketing purposes, the provision of personal data is not mandatory. The legal basis for this data processing shall be the consent according to Art. 6 (1) (a) of the GDPR;
3.4 Visiting our website
MentorMate is committed to maintaining the privacy of users of our website. When you visit the website, the web servers always temporarily store for connection and setup and security purposes the connection data of the computer connecting to the site, a list of the web pages you visit within the site, the date and duration of your visit, IP the address of your device, the identification of the type of browser and operating system used, and the website through which you linked to our site. Additional personal data such as your name, address, telephone number, or email address will not be collected unless you provide this data voluntarily, e.g. while completing an online contact form, as part of a registration, survey, contract performance, or request for information.
The legal basis for the processing of the above categories of data is Art. 6 (1) (a) of the European General Data Protection Regulation (GDPR). Due to the mentioned purposes, in particular to ensure security and seamless connection setup, we also have a legitimate interest in processing this data.
3.5 Online presence and optimization of our website
We may use tracking software to determine how many users visit our Website and how often. We do not use this software to collect individual personal data or individual IP addresses. The data is used only in an anonymous and aggregated form for statistical purposes and Website development.
3.6 Processing to protect the legitimate interests of MentorMate or a third party
In limited cases and to protect our legitimate interests, MentorMate will process personal data. In this case, the processing shall be admissible only to the extent that the interests or fundamental rights and freedoms of the data subject which require the protection of personal data take precedence over such interests, in particular where the data subject is a child.
4. Principles of processing Personal data
MentorMate observes the following principles in the processing of your personal data:
- legality, good faith and transparency;
- limitation of processing purposes;
- relevance to the purposes of processing and minimizing the collection of personal data;
- accuracy and timeliness of the data;
- limitation of storage to achieve the objectives;
- integrity and confidentiality of the processing and ensuring an appropriate level of security of personal data.
5. Recipients and categories of recipients of your personal data:
MentorMate does not share, sell, transfer or otherwise distribute your personal data to third parties and will not do so in the future unless such is required by law, necessary for the execution of a contract, or when you have given us your consent. For example, you may be required to provide your personal data or personal data held by you lawfully to enter and execute an agreement between MentorMate and you or a company you represent. In such a case, MentorMate will be able to provide your or your data to third parties with whom it has a contractual relationship, including in countries outside the European Union (such as MentorMate, USA).
We will protect your personal data and undertake appropriate contractual and other steps to protect it following the legal requirements. These steps might include the application of standard contractual clauses approved by the European Commission for personal data transfers. Standard contractual clauses can be provided upon request. We have put in place appropriate safeguards with our service providers and partners.
Any provision of personal data by MentorMate outside the EU shall be made after an assessment which includes: identification and planning of data transfer and all subsequent transfers; identification of the legal mechanisms on which we base the data transfer – for example, Article 45 of the GDPR (adequacy decision issued by the European Commission), Article 46 of the GDPR (appropriate safeguards such as standard contractual clauses drawn up by the European Commission or mandatory corporate rules) or Article 49 of the GDPR (derogations) – only in limited circumstances, explicit consent by the data subject; assessment whether the circumstances of the data transfer ensure a level of protection guaranteed by EU law; analysis and undertaking of additional measures (technical, contractual and organizational) to ensure essentially equivalent protection of personal data; additional procedural steps, if necessary; monitoring to ensure effective protection of personal data, including a regular reassessment of the level of protection.
MentorMate’s external service contractors are required to maintain strict confidentiality when processing personal data. The service providers will follow the instructions of MentorMate. Personal data is guaranteed by technical and organizational measures, as well as through inspections and controls. In any case, MentorMate shall be responsible for the protection of your personal information in any circumstance.
6. Retention periods
The personal data is stored and processed for the following term:
- for a period of 5 years – when the personal data are obtained for the performance of contracts or pre-contractual relationships. The 5 years period starts from the latter of the two dates: the date of correspondence on the possible conclusion of a contract or the date of execution of a contract;
- for the relevant statutory term – if the personal data is collected and processed based on fulfillment statutory obligation of MentorMate;
- for a period of 5 (five) years – when the personal data is processed for marketing purposes, incl. information on events, training, and publications to job applicants, if they the provided us with explicit consent;
- for a period of 5 (five) years – when personal data is processed to protect our legitimate interests – protection of the MentorMate website, systems and trade secrets.
7. Data security
MentorMate undertakes technical and organizational security measures to ensure the most comprehensive protection of personal data from unwanted access. We use an encryption procedure in some areas to prevent the misuse of third-party data in addition to the usage of secure work environment. Our data security applies the relevant current level of technology. For example, your data is stored in a secure operating environment that is not accessible to the public. In certain cases, your data is encrypted by Secure Socket Layer (SSL) technology during transmission to third parties.
We make every reasonable effort to protect your personal information.
8. Rights of personal data subjects
8.1 Right to information
You may at any time request from us information about your personal data that we store and process, as well as about the origin, recipients or categories of recipients to whom we transmitted it and the purpose of processing it.
8.2 Right of Withdrawal
If you have provided us with your consent to process your data, you can withdraw it at any time without giving any reasons.
8.3 Correction rights
If your personal data processed by MentorMate is incorrect, you can ask us to correct it at any time.
8.4 Erasure and blocking rights
You have the right to delete and block your personal data that MentorMate processes. Deleting can be done at any time by contacting us. In general, your data will be deleted immediately, at the latest 30 days after exercising this right as a data subject. If deletion is contrary to legal, contractual, criminal or commercial law, or other legitimate reasons, instead of deletion, only blocking of your data may take place. After deleting your data, it is no longer possible for us to recover it.
8.5 Right to data portability
If you require us to provide you with your personal data, we will transfer the data to you or another controller in a structured, widely used and machine-readable format. We will only transfer the data directly if it is technically feasible.
8.6 Right of objection
You have the right at any time and without giving any reason to object to our processing of your data, including if we process it for the purposes of marketing or application for a job position.
8.7 Advanced rights in automated data processing, including profiling
MentorMate does not perform automated data processing including profiling. Notwithstanding the above, with respect to automated data processing including profiling, you have the additional right to request human intervention from the Controller, the right to challenge the decision and the right to express your point of view.
8.8 Contact (for the exercise of your rights as a data subject)
10. Competent supervisory authority
If you are citizen of the EU (European Union) you could file a complaint before the Commission for Personal Data Protection, with address: Sofia, postal code 1592, 2 „Prof. Tsvetan Lazarov Bld., www.cpdp.bg, phone number: +359 2 9153518.
11. Sharing Your Information
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
12. Your Access and Control Over Your Information
You can opt-out of receiving targeted ads served by our advertising partners:
Our personalized advertisements are served via AdRoll, a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes of Conduct. You may use the NAI opt out tool here (http://optout.networkadvertising.org/), which will allow you to opt out of seeing targeted ads from all NAI approved member companies.
AdRoll also complies with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt out of receiving targeted ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAA website here (http://optout.aboutads.info).
Canadian citizens may opt out of receiving targeted ads from companies that perform ad targeting services, including some that we may work with as Advertising Partners via the the Digital Advertising Alliance of Canada (DAAC) website here (http://youradchoices.ca/choices/).
If you are located in the European Economic Area you may opt out of online advertising via the European Interactive Advertising Digital Alliance (EDAA Your Online Choices website here (http://www.youronlinechoices.com/).
If you are located in the European Economic Area you may also have the right to access, correct or update some of the information we hold about you as listed above You can also request that we delete your information. If you wish to exercise any of these rights, please contact us at [email protected].
13. Links to Other Websites
Our Website may contain links to third party websites. These links are provided solely as a convenience to you. By linking to these websites, we do not create or have an affiliation with, or sponsor such third-party websites. The inclusion of links within our Website does not constitute any endorsement, guarantee, warranty, or recommendation of such third-party websites. MentorMate has no control over the legal documents and privacy practices of third-party websites; as such, you access any such third-party websites at your own risk.
15. General Terms