PRIVACY POLICY

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:

1. 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.

2. 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.

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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.

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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.

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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. 

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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: 

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• 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.

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• 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.

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You may only submit a Request to Know twice within a 12-month period. Your request to know or delete must:

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• 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;

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• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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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.

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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. 

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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.

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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.

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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. 

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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.

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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. 

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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. 

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If you would like to opt out of our online disclosure of your personal information for purposes that could be considered “sales” or “sharing” for purposes of targeted advertising, please click here: www.mentra.com/opt-out

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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. 

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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.

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