Mentor Collective Privacy Policy

Effective Date: March 16, 2026
Last Updated: March 16, 2026
Version: 2.0

We at Shearwater International, Inc. (d/b/a "Mentor Collective," "we," "us") provide a hosted platform service which is used by learning institution administrators, organization administrators, employees, educators, students, and alumni. Such services, which have been licensed for your exclusive use of the organizations that are customers of the Mentor Collective platform ("University," "College," "Partners," "Organizational Partner," "Institution"). Mentor Collective has created this Privacy Policy to describe our commitment to privacy and how we collect and use Personal Information (defined below) from and about the visitors ("Visitors") to our web sites (including https://app.mentorcollective.org/) (each, a "Site," "Platform"), and authorized users ("Users", "you", "your").

The Privacy Policy applies to our Platform, mobile features, applications, and any other interactive features or services owned or controlled by Mentor Collective that post a link to this Privacy Policy (each, a "Service" and collectively with the Sites, the "Services"), as well as any information we collect offline and combine with data collected through the Services. Certain features discussed in this Privacy Policy may not be offered on each Service at any particular time.

Please review this Privacy Policy carefully before using the Services or before submitting any Personal Information. By accessing or using the Services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Sites or otherwise use the Services. Furthermore, this Privacy Policy is incorporated into and forms part of our Mentor Collective Platform Terms of Use.

Mentor Collective currently operates its Services and processes data within the United States, including those Users who are located outside of the U.S. If you are located outside the United States, the information will be protected and subject to this Privacy Policy and applicable laws, which may not be as protective as the laws in your country.

Table of Contents

1. Privacy Policy Summary

What We Do: Mentor Collective provides a mentorship platform that connects students, alumni, and professionals through educational institutions and organizations.

What Information We Collect:

  • Contact information (name, email, phone number)
  • Profile information you provide for mentor/mentee matching
  • Communication data between mentors and mentees
  • Usage data about how you interact with our platform

Why We Collect It:

  • To match you with appropriate mentors or mentees
  • To facilitate communication within mentorship relationships
  • To provide program support and improvements
  • To meet our obligations to customers

Who We Share It With:

  • Your mentor or mentee (information you choose to share)
  • Your educational institution or organization (program administrators)
  • Service providers who help us operate the platform (with strict data protection agreements)

Your Rights:

  • Access and update your information
  • Delete your account and associated data
  • Opt out of non-essential communications
  • Request information about how your data is used

Questions? Contact our Privacy Team at privacy@mentorcollective.org.

2. About This Policy

We at Shearwater International, Inc. (d/b/a "Mentor Collective," "we," "us," "our") are committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect information about you when you use our mentorship platform and related services.

Who This Applies To:

  • Visitors: Anyone who visits our websites before creating an account
  • Users: Registered mentors, mentees, and program participants
  • Administrators: Staff at customer organizations who manage mentorship programs

What Services This Covers:

  • Our mentorship platform (app.mentorcollective.org)
  • Mobile applications
  • Email and SMS communications
  • Support services

By using our services, you agree to this Privacy Policy. If you don't agree, please don't use our services.

Important for International Users: We operate primarily in the United States. If you're located outside the US, your information will be processed according to US laws and this Privacy Policy, which may provide different protections than your home country's laws.

3. Information We Collect

A. Information You Provide Directly

Account Registration:

  • Name and contact information (email, phone number)
  • Account credentials (password, security questions)
  • Demographic information for matching purposes

Profile Information:

  • Academic and professional background
  • Interests, goals, and preferences
  • Mentorship objectives and availability
  • Profile photos (optional)

Communication Data:

  • Messages sent through our platform
  • Email and SMS communications via our relay system
  • Video testimonials and feedback (when provided)
  • Survey responses and program evaluations

B. Information from Customer Organizations

When your organization partners with us, they may provide:

  • Your contact information
  • Academic status (student, alumni, etc.)
  • Program enrollment information
  • Profile information
  • Any additional information they choose to share to facilitate your participation

C. Information We Collect Automatically

Device and Usage Information:

  • IP address and general location
  • Browser type and version
  • Device type and operating system
  • Pages visited and features used
  • Time spent on platform
  • Referral sources

Technical Data:

  • Log files and server records
  • Error reports and performance data
  • Security monitoring data

4. How We Use Your Information

We use your information for the following purposes:

Core Platform Services

  • Matching: Connect you with compatible mentors or mentees using our matching algorithms
  • Communication: Facilitate secure messaging between mentorship pairs
  • Program Administration: Manage your participation in mentorship programs
  • Support: Provide customer service and technical support

Platform Improvement

  • Analytics: Understand how users interact with our platform (using aggregated, de-identified data)
  • Product Development: Improve existing features and develop new ones
  • Quality Assurance: Monitor program effectiveness and user satisfaction

Communications

  • Program Updates: Send important information about your mentorship program
  • Automated Reminders: Prompt you to engage with your mentor or mentee
  • Surveys and Feedback: Request input on your mentorship experience
  • Educational Content: Share relevant resources and tips (you can opt out)

Legal and Business Operations

  • Compliance: Meet legal obligations and institutional requirements
  • Security: Protect against fraud, abuse, and security threats
  • Business Operations: Handle mergers, acquisitions, or other business changes

We do not:

  • Sell or rent your personal information. Ever.
  • Use your information for targeted advertising
  • Share your information for others' marketing purposes (without your consent)

5. Information Sharing and Disclosure

With Your Mentor or Mentee

You control what information you share with your mentorship partner through your profile and direct communications. This may include:

  • Profile information you choose to display
  • Messages and communications
  • Progress updates and feedback

With Customers

Your organization may have access to:

  • Your participation status and basic program metrics
  • Aggregated program effectiveness data
  • Information necessary for program administration and support

With Service Providers

We share information with trusted service providers who help us operate our platform:

Technology Infrastructure:

  • Cloud hosting providers (AWS, Google Cloud, or similar)
  • Database management services
  • Security monitoring services

Communication Services:

  • Email service providers
  • SMS/text messaging services
  • Video conferencing tools (if integrated)

Analytics and Improvement:

  • Usage analytics providers (using de-identified data)
  • Survey and feedback platforms
  • Performance monitoring tools

All service providers are contractually required to protect your information and use it only for specified purposes.

Legal Requirements

We may disclose information when required by law or to:

  • Comply with legal process (subpoenas, court orders)
  • Investigate suspected fraud or policy violations
  • Protect the safety of users or others
  • Defend our legal rights

Important: When legally permissible, we will notify affected users and work to limit the scope of required disclosures.

Business Transfers

If we undergo a merger, acquisition, or sale of assets, your information may be transferred. The new entity will be bound by this Privacy Policy.

6. Data Security

We implement comprehensive security measures to protect your information:

Technical Safeguards

  • Encryption: All data is encrypted in transit (TLS 1.3) and at rest (AES-256)
  • Access Controls: Multi-factor authentication and role-based access for all administrative accounts
  • Network Security: Firewalls, intrusion detection, and secure network architecture
  • Monitoring: 24/7 security monitoring and automated threat detection

Administrative Safeguards

  • Employee Training: Regular security awareness training for all staff
  • Background Checks: Security screenings for employees with data access
  • Incident Response: Documented procedures for security incident handling
  • Vendor Management: Security requirements for all third-party service providers

Physical Safeguards

  • Secure Facilities: Data centers with physical security controls
  • Equipment Security: Secure disposal of hardware containing sensitive data

Ongoing Security

  • Regular Assessments: Periodic security audits and vulnerability testing
  • Updates: Prompt installation of security patches and updates
  • Compliance: Adherence to industry security standards [INSERT SPECIFIC CERTIFICATIONS IF APPLICABLE, e.g., SOC 2 Type II]

Security Incidents: While we implement strong security measures, no system is completely secure. If a security incident affects your personal information, we will notify you and relevant authorities as required by law.

7. Data Retention

We retain your information for specific periods based on the type of data and business needs:

Active Account Data

  • Duration: While your account is active and for 1 year after your associated institution's agreement ends
  • Includes: Profile information, matching data, account settings

Communication Records

  • Duration: 3 years after program completion
  • Purpose: Quality assurance, dispute resolution, program improvement
  • Includes: Message logs, email communications, feedback

Usage Analytics

  • Duration: Up to 5 years in aggregated, de-identified form
  • Purpose: Platform improvement, research, reporting
  • Includes: Usage patterns, feature adoption, performance metrics

Legal and Compliance Data

  • Duration: As required by applicable laws and regulations
  • Includes: Records needed for legal compliance, dispute resolution

Early Deletion

You can request deletion of your data at any time by contacting us at privacy@mentorcollective.org. We will delete your information within 30 days, except where retention is required by law or for legitimate business purposes (such as preventing fraud).

Backup Data: Information in backup systems will be deleted according to our standard backup retention schedule (typically within 90 days of primary deletion).

8. Your Rights and Choices

Account Management

  • Access: View and download your personal information
  • Update: Modify your profile and account settings
  • Delete: Request deletion of your account and associated data

Communication Preferences

You can control the types of communications you receive:

Program Communications:

  • Essential program updates (cannot be disabled)
  • Mentorship reminders and check-ins
  • Educational content and resources

Marketing Communications:

  • Newsletter and product updates
  • Customer education and resources
  • Survey and feedback requests

Opt-Out Methods:

  • Email: Click unsubscribe links or email privacy@mentorcollective.org
  • SMS: Reply "STOP" to any text message
  • Account Settings: Update preferences in your account dashboard

Data Rights Requests

To exercise your rights, contact us at:

Response Time: We will acknowledge your request within 2 business days and provide a complete response within 30 days.

Verification: We may require identity verification before processing requests to protect your information from unauthorized access.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to operate and improve our services:

Types of Cookies

Essential Cookies (Cannot be disabled)

  • User authentication and login
  • Security features and fraud prevention
  • Basic platform functionality

Analytics Cookies (Can be disabled)

  • Usage statistics and performance monitoring
  • Feature adoption and user behavior analysis
  • Platform optimization and improvement

Functional Cookies (Can be disabled)

  • User preferences and settings
  • Language and regional preferences
  • Customization features

Managing Cookies

  • Browser Settings: Configure cookie preferences in your browser
  • Cookie Preferences: [IF AVAILABLE] Use our cookie preference center
  • Do Not Track: We currently do not respond to Do Not Track signals

Third-Party Cookies

We may use third-party services that place cookies on your device:

  • Analytics: Google Analytics
  • Support: Customer service chat tools
  • Security: Fraud prevention services

For more information about cookies, visit https://www.allaboutcookies.org.

10. International Users

Primary Operations: We operate primarily in the United States and process data according to US laws.

European Union Users

If you're located in the EU and we process your personal data, we do so based on the following legal grounds:

  • Legitimate Interests: Providing mentorship services and platform improvements
  • Contract Performance: Fulfilling our obligations to you and your institution
  • Consent: Where you have provided specific consent
  • Legal Compliance: Meeting applicable legal requirements

Your EU Rights:

  • Access, rectification, and erasure of personal data
  • Data portability and restriction of processing
  • Objection to processing based on legitimate interests
  • Withdrawal of consent (where applicable)

EU Representative: [INSERT IF APPLICABLE]

Canadian Users — PIPEDA

For Canadian users, we process personal information in accordance with applicable privacy laws and provide:

  • Clear consent for personal information collection and use
  • Access to personal information we hold about you
  • Procedures for addressing privacy complaints

Data Transfers

When we transfer data internationally, we use appropriate safeguards such as:

  • Standard contractual clauses approved by relevant authorities
  • Adequacy decisions where available
  • Other legally recognized transfer mechanisms

11. Educational Records (FERPA)

When processing student educational records, Mentor Collective acts as a service provider to educational institutions under the Family Educational Rights and Privacy Act (FERPA).

Our FERPA Commitments

  • Confidentiality: We maintain the confidentiality of educational records
  • Limited Use: We use educational record information only to provide contracted services
  • No Re-disclosure: We do not re-disclose personally identifiable information from education records without appropriate consent or as permitted under FERPA
  • Data Security: We implement appropriate safeguards to protect educational records

Student Rights Under FERPA

Through your educational institution, you have rights to:

  • Access your educational records
  • Request correction of inaccurate records
  • Control disclosure of personally identifiable information
  • File complaints with the Department of Education

FERPA Questions: Contact your institution's registrar or privacy office, or the Department of Education's Family Policy Compliance Office.

12. California Privacy Rights

California Consumer Privacy Act (CCPA/CPRA)

Categories of Personal Information We Collect:

  • Identifiers: Name, email, phone number, account credentials
  • Commercial Information: Program participation, service usage
  • Internet/Network Activity: Platform usage, log files, cookies
  • Professional Information: Career background, academic status (if provided)
  • Inferences: Matching preferences derived from profile information

Your California Rights:

  • Right to Know: Request information about personal information we collect, use, and disclose
  • Right to Delete: Request deletion of your personal information
  • Right to Opt-Out: We do not sell personal information, so no opt-out is required
  • Right to Non-Discrimination: We will not discriminate for exercising your rights

Exercising Your Rights

Submitting Requests:

Verification: We may require identity verification to protect your information.

Authorized Agents: You may designate an authorized agent to submit requests on your behalf with proper documentation.

Response Time: We will respond to verified requests within 45 days (extendable by 45 days if necessary).

California Civil Code Section 1798.83

California residents may request information about personal information disclosed to third parties for direct marketing. Since we do not disclose personal information for others' direct marketing purposes, this right does not typically apply.

13. Children's Privacy

Our services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we discover that we have collected personal information from a child under 13, we will delete it promptly.

For users under 18: If you are under 18, please ensure you have parental permission before using our services and providing any personal information.

14. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements.

How We Notify You

  • Website Notice: Prominent notice on our website and platform
  • Email Notification: Direct email to registered users for material changes
  • Customer Notification: Direct communication with customers
  • Version Updates: Updated "Last Modified" date and version number

Effective Date

Changes become effective on the date specified in the updated policy. Continued use of our services after the effective date constitutes acceptance of the changes.

Material Changes: For significant changes that affect how we collect, use, or share your information, we will provide at least 30 days advance notice and may require affirmative consent.

15. Contact Information

Mentor Collective Privacy Team

Email: privacy@mentorcollective.org

Mailing Address

Mentor Collective
Attention: Privacy Team
2810 N Church St PMB 58445
Wilmington, Delaware 19802-4447
United States

Response Commitment

  • Acknowledgment: Within 2 business days
  • Full Response: Within 30 days
  • Urgent Privacy Matters: Same-day response during business hours

Privacy Officer

Annemieke Rice, Senior Vice President of Product, annemiekerice@mentorcollective.org

16. For Customers

Privacy Resources for Customers

As a customer, you have access to:

  • Data Processing Agreements: Detailed agreements outlining our data handling practices
  • Privacy Documentation: Comprehensive documentation of our privacy and security practices
  • Template Language: Sample privacy notice language for your communications to students/participants
  • Regular Reports: Monthly privacy and security compliance reports
  • Direct Access: Priority support line for privacy-related questions

Data Responsibilities

Mentor Collective Responsibilities:

  • Secure data processing and storage
  • User access controls and authentication
  • Platform security and monitoring
  • Privacy request processing
  • Incident response and notification

Customer Responsibilities:

  • Obtaining appropriate consent for data sharing
  • Providing required FERPA notifications
  • Managing institutional user access
  • Compliance with institutional privacy policies
  • Student/participant privacy education

Contact for Customers

Email: support@mentorcollective.org
Privacy Questions: privacy@mentorcollective.org

Glossary

Aggregated Data: Information combined from multiple users in a way that does not identify individuals

De-identified Data: Information from which personal identifiers have been removed

Educational Records: Records directly related to a student maintained by an educational institution (FERPA definition)

Personal Information: Information that identifies, relates to, or can reasonably be linked to an individual

Service Providers: Third-party companies that provide services to help us operate our platform

This Privacy Policy is effective as of October 1, 2025 and replaces all previous versions. For questions about this policy or our privacy practices, please contact our Privacy Team.

Version History:

  • Version 1.0: July 13, 2021
  • Version 2.0: March 16, 2026 — Comprehensive update with enhanced user rights, security details, and compliance provisions

© 2026 Shearwater International, Inc. d/b/a Mentor Collective. All rights reserved.