Mentor Collective Privacy Policy

Updated: July 13, 2021

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 purchased for your exclusive use of the universities, colleges, and 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 (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.

Visitor Information

What types of information do we collect from visitors?

When you visit the Site prior to registering or authenticating, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.” Some mobile service providers may also provide us or our service providers with information regarding the physical location of the Device and your mobile carrier used to access a Service.

Why is this information collected?

We use this information to monitor, analyze use of and administer the Site, and better tailor it to your needs.

By what means is this information collected?

We collect Device Information using the following technologies:

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit

  • “Log Files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. We use third party service providers to assist us in collecting and understanding Log File data.

  • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site. Clear GIFs are tiny graphics files with a unique identifier, similar in function to cookies, and are used to track the online movements of web users for our affiliate program. In contrast to cookies, which are stored on a user’s computer’s hard drive, clear GIFs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. This information is used to help improve the overall quality and experience of our Services. We may associate the information gathered by clear GIFs to a User’s Personal Information.

Who will have access to this information?

Authorized Mentor Collective system administrators may use this Visitor Information to better understand usage of the Site and implement improvements and enhancements in the future.

User Information

What types of information do we collect from users?

By registering as an authorized User, when you visit or authenticate with the Site, we may collect information that, alone or in combination with other reasonably available information, can reasonably identify or be related to a specific individual or household (“Personal Information”). This includes: Personal Information you voluntarily provide, such as when you register for and use the Services. This Personal Information may include, but is not limited to, your first and last name, your email address, your phone number, account information (such as a password or other information that helps us confirm that it is you accessing your account), and demographic or other information about your interests and preferences.

Additionally, you may provide information about a mentorship that you are participating in by performing various actions on our Site. You also provide information when you correspond by email or SMS messages, either directly with Mentor Collective or with a mentorship counterpart through a Mentor Collective email or SMS relay. You may provide information to other Users associated with your Partner when recording and uploading a video testimonial, completing your mentorship profile, or uploading a profile picture.

Information Provided By Our Partners

When Partners decide to use Mentor Collective, they provide us with the information necessary to create a mentorship program as part of an Agreement. The Partner with whom you are associated may provide your Personal Information to Mentor Collective to enable you to register for and use the Services. This Personal Information includes, but is not limited to, your first and last name, your email address, your phone number, and any other Personal Information our Partners may choose to provide.

Information Collected Automatically

Why is this information collected?

In support of our Partners, we collect demographic data, such as your first and last name, email address, and other contact information (such as telephone number) to authenticate and provide services that meet the associated Partner’s objectives. Additionally, we will aggregate your Personal Information in an anonymous manner to compile statistical and performance information related to the operation of our System (“Aggregated Anonymous Data”). Mentor Collective uses Aggregated Anonymous Data in order to create Service enhancements; provided, that such information does not incorporate any of our Partner’s data, your Personal Information, or additional data you and our Partners provide. Our use of your Personal Information and Aggregated Anonymous Data is strictly limited to the extent necessary to perform the Services for our Partners.

We may use information about you, including Personal Information, to (1) provide necessary mentorship services, (2) provide important communications to or from your mentorship counterpart(s), (3) process your registration with our Services, (4) provide you with information from your associated Partner, (5) improve the Services and products, and (6) communicate with you regarding your use of the Services and changes to our policies. We use the Personal Information we collect to:

  • Aggregate Anonymous Data to help improve our product and Services.

  • Match you with a mentee or mentor that we believe will be the best fit for you.

  • Put you in contact with your mentee or mentor through SMS or email.

  • Communicate with you over email and SMS to send automated reminders and provide opportunities for you to give us feedback on the program. You can opt out of receiving these messages at any time through an unsubscribe link (email) or by replying ‘STOP’ to them (SMS).

We do not sell or rent Personal Information. We do not work with network advertisers, ad agencies, or advertising companies, nor do we serve targeted advertising.

We use and disclose your Personal Information only for the purposes described above and as follows:

  • To investigate a suspected violation of our Terms of Use, suspected fraud or other unlawful activity;

  • As may be required by law or by a court order, in which case, where legally permissible, we shall attempt to notify you and work with you to seek to limit the scope of the required disclosure;

  • To our third party service partners to permit them to provide features and services on our behalf. We may employ third parties to facilitate delivery of our Site and to provide certain features on our behalf, such as maintenance services, helpdesk management, email and SMS management, database management, web analytics, and improvement of our Site;

  • In the event of a reorganization, merger, sale, bankruptcy or other business change, in which case your information will remain subject to the terms of this Privacy Policy; and

  • With your consent and as permissible under applicable laws and regulations.

How long is this information stored?

We may retain the information you provide for as long as it is necessary to provide the required Services, or as otherwise permissible by law. In the event that we receive a court or other law enforcement request, including but not limited to an administrative subpoena or judicial warrant, for access to, use of, or inspection of Partner information wherever legally permissible, we will not act directly on such request, but will instead promptly refer such requests directly to the Partner. To the extent we are legally required to provide the information requested prior to or in addition to such referral, wherever legally permissible we will promptly notify the Partner of the request and of Mentor Collective’s intent to comply with the request.

We may de-identify information in accordance with applicable law, including the standards defined in the Family Educational Rights and Privacy Act (FERPA), and aggregate Personal Information and use such aggregated information, which does not identify you, to analyze the effectiveness of our Services, to improve and add features to our Services, and for other similar purposes in the future.

In addition, from time to time, we may analyze the general behavior and characteristics of Users of our Services and share aggregated information, like general user statistics, with current and prospective business partners to demonstrate the effectiveness of our Services.

We retain your information as long as you retain an active account with Mentor Collective as part of an active Agreement. Prior to termination of the Agreement and upon written request from Partner, Mentor Collective can provide Partner with a one-time, delimited file export of its data from the Services via SFTP. Within 30 days of termination, or within 14 business days of receipt of a written request from Partner, Mentor Collective will securely destroy Partner’s personally identifiable student data, including such data held in Mentor Collective’s backup systems.

By what means is this information collected?

This information is collected through the Services, through Cookies, through Log Files, through Web Beacons, and through other means as described in this Privacy Policy.

Who will have access to this information?

Mentor Collective Administrators

Authorized Mentor Collective system administrators, mentorship program operations staff, and helpdesk analysts may have access to limited specific information in order to provide required services such as troubleshooting, Partner and mentorship program support duties, and resolving mentorship-related questions.

Authorized Partner Administrators

When a Partner decides to use Mentor Collective as part of an Agreement, they provide us with information necessary to create a Partner account(s) for organization administrators or staff users. Such Partner administrators may have access to mentorship and Personal Information in order to provide support services, answer questions, and assess the status of the Partner’s mentorship program. This information is used only for the Partner’s internal purposes. Authorized Partner administrators may also provide us with information when they contact us with questions, for troubleshooting, or other Partner support-related requests.

Mentor Collective Users

By agreeing to participate in a mentorship program either as a mentor or mentee, you may be asked to share information about your preferences and experiences in order for Mentor Collective to match you with a mentorship counterpart. Your mentorship counterpart will have access to the Personal Information that you decide to share.

How is user information protected?

Our written information security program is aligned within applicable industry standards as related to the products and services we provide. As such, security measures to maintain the confidentiality, security, and integrity of the information you provide to us have been deployed. These security measures, both technical and procedural, are continuously being monitored, tested, evaluated, and improved.

We deploy commercially reasonable security precautions intended to protect against unauthorized access to any of this information. We store data in secure server and cloud-based environments that use firewalls, VPNs, event logging, and other industry-standard protections in an effort to monitor and prevent access from outside intruders. We also encrypt data in transit and at rest, require unique account credentials, and limit data access. Not all security risks are reasonably foreseeable, however, and Mentor Collective is not responsible for the consequences of security incidents that are not reasonably foreseeable and not reasonably within its control.

How are users informed if our privacy policy changes, including changes to how the information will be used?

On an annual basis, this Site has the right to make changes or additions to this policy at any time. The most recent version of the Privacy Policy is reflected by updating the “Last Updated” date at the top of this Privacy Policy. Changes will become effective when posted. We will notify you of material changes to the Privacy Policy on our Site and/or by email, and make additional efforts to notify Partners of material changes that impact the treatment of data collected through our Services. If you do not agree to changes to this Privacy Policy, you may not continue to use this Site.

California Consumer Privacy Act (“CCPA”)

In accordance with the CCPA, this section is intended to inform California residents of (1) the Personal Information that we collect and how we disclose that information, and (2) the privacy rights California residents may have relating to their Personal Information and how those rights can be exercised.

California Privacy Rights

To the extent provided for by the CCPA and subject to applicable exceptions and exclusions, California residents have the following privacy rights in relation to the Personal Information we collect:

  • The right to know what Personal Information we have collected and how we have used and disclosed that Personal Information.

  • The right to request deletion of your Personal Information.

  • The right to opt out of the sale of your Personal Information.

  • The right to be free from discrimination for the exercise of your privacy rights.

Additionally, under California Civil Code Section 1798.83, California residents may have the right to request the categories of Personal Information we disclosed to third parties for their direct marketing purposes in the year preceding the request, the names and addresses of such third parties, and, in certain circumstances, examples of the products or services marketed by such third parties.

We do not sell your personal data, so we do not offer or require an opt-out to the sale of personal data. For a description of the personal data we collect please see ‘What Types of Information do we Collect from Users?’ section within this Privacy Policy.


In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a request to know or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information for verification. If we cannot verify your identity, we will not provide or delete your Personal Information.

Authorized Agents

You may submit a request to know or a request to delete your Personal Information through an authorized agent. If you do so, we may require the agent to present signed written permission to act on your behalf and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

Do Not Track

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

How can I remove my information?

If you wish to close your account with one of our Services, please send your request via email at and we will remove your Personal Information from the active databases for the Service(s) you request. Please let us know which Service(s) you wish to close and send your request using an email account that you have registered with Mentor Collective under your name.

Requests to change your email or SMS preferences or unsubscribe from all emails or SMS may not be made through this email address, but rather must be submitted through one of the existing Services. Even if your account is closed, information may remain in backup or archive records and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, account recovery or if required by law. All retained data will continue to be subject to this Privacy Policy.

How can users with questions about our privacy policy contact someone?

If you have questions or comments about this Privacy Policy, or would like to access it in a different format, please contact us via email at Alternatively, you can mail your request to: 294 Washington St., Suite 607, Boston MA, 02108