Privacy Policy

Last Updated: 3 February 2021

Your privacy is important to us. This Privacy Policy applies to all products and services offered by 100mentors Single Member PC (“100mentors”, “we”, “us”, “our”, and our subsidiaries or affiliates) a private company, registered in Greece, whose registered office is situated at Pl. Kornarou 31, Heraklion Crete, (email: [email protected]) via our website www.100mentors.com (“Website”), mobile application (“Mobile App”) and web application (‘’Web App’’) (together, the “Platform”) or any of our other products or services that link to this Privacy Policy that we may provide now or in the future via the Platform (collectively, the “Services ”) or when you otherwise interact with us or other users via the Services. For the purpose of the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), we, acting as the Data Controller, will only collect, use, and share your personal data in accordance with this Privacy Policy.

“You” may be one of these Users:

“Student” (i.e. User who was invited to use the Services by an Educator or 100mentors);
“Educator’” (i.e. an adult over the age of 18, a teacher, aide, or other personnel accessing the Services, on behalf of a school, school district, or similar educational institution or any other organisation or entity);
“Mentor” (i.e. an adult over the age of 18, who individually or by representing an organization or institution or entity, has a legitimate interest to provide guidance, support, and encouragement aimed at developing the competence and character of Students);
a “User” (i.e. any user/visitor of the Website).

This Policy does not apply to websites or services or practices of companies that 100mentors doesn’t own or control, such as third-party services you might access through links or other features (e.g. social media buttons or YouTube videos) on the Services. These other services have their own privacy policies and we encourage you to review them before providing them with personal information.

By accessing the Platform and/or registering for an account on the Platform and/or by using the Services, you acknowledge that you have read, accept and agree with this Privacy Policy. If you do NOT accept and agree with this Privacy Policy, as well as with our Terms & Conditions and Cookie Policy, you have no right to use the Platform or the Services and must cease using them immediately. Please read this Privacy Policy, as it describes what personal data we collect from you, how we use that personal data and the legal basis we have to process your personal data.

If you have any questions about your privacy, send us an email: [email protected].

Definitions
Our Privacy Policy is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our users. To ensure this, we would like to first explain the terminology used. In this Privacy Policy, we use, inter alia, the following terms:
1. ‘’Personal data’’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
2. ‘’Processing’’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
3. ‘’Controller’’ means the competent authority which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
4. ‘’Processor’’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
5. ‘’Recipient’’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.
6. ‘’Personal data breach’’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
7. ‘’Third party’’ is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
8. ‘’Consent’’ of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
What Personal Data We Collect and How
We collect personal data about you through the means discussed below when we provide the Services via our Platform : i) personal data that you voluntarily provide us by using the Service (described below under Personal Data You Provide to Us) , ii) personal data collected when you access the Services through a third party social networking connection or log-in (described below under Personal Data We Collect From Social Media and Other Content Platforms), iii) personal data collected automatically as a result of your use of the Service (described below under** Personal Data collected automatically), and iv) personal data received about you from third-party sources (described below under **Personal Data from Third-Party Sources). Please note that the types and amounts of personal data collected will vary depending on the type of the User as described above (e.g. we collect minimal information from Students when they register for an account on our Service) and how they use the Platform. We need certain types of personal data so that we can provide the Services to you. If you do not provide us with such data, or ask us to delete it, you may no longer be able to access or use our Services.
1. Personal Data You Provide directly to us The personal information that you provide to us is necessary for the adequate performance of the Agreement (as described in Terms & Conditions) between you and us, for our legitimate interest in being able to provide and improve the Services, and to allow us to comply with our legal obligations. From the types of Users described above (Educators, Students, Mentors), we describe the personal data we collect and store from each type of user and we describe some additional information for Students in the “ Students Privacy” section below.
  1. Account Sign-up and Profile Information For every type of User, when he creates an account on the Services, we request from you the minimal personal information, such as User’s first name, email address and password. In particular for each type of User:
    1. If Educator, we request from you to fill in except from the above the School Name (if the School you represent uses for the first time the Platform) or a Verification Code ( if the School you represent is already in use of the Platform). All the other fields on your account form are optional.
    2. If Student, we request from you to fill in except from the above, the unique Verification Code from the Educator or 100mentors or the link via e-mail for your invitation or your parents email to obtain consent. Fields like birthday, gender, timezone, expertise, photo, career and studies may be filled by you on your own will and they are optional.
    3. If Mentor, we request from you to fill in except from the above, the current occupation and fields of expertise fields. All the other fields on your account form are optional. There are other optional fields on your account form to be filled on your own willing to provide personal data such as: your birthday date, tags of interest, your skype name, your timezone or a profile photo.
  2. Class Information: As an Educator, you may enter the class year (e.g. first grade). It is the educator choice if and what kind of information they enter here: for example, teachers could enter John S or John Smith. We recommend that the Educator provide the minimal personal data for the students in his/her class.
  3. Inviting Students to Register as Users: As an Educator, you can invite your Students to join the Services, in accordance with our Terms & Conditions (e.g. after having obtained the prior verifiable consent by Student’s parent or legal guardian) through an invitation (via a verification code or an email code ) for example by providing us their email address . We will collect and store the email you provide with these requests, and will also treat this as personal data in accordance with this Privacy Policy.
  4. Content: Educators and Mentors may upload content (text, images, photographs, videos, messages, comments, or any other kind of content) on the Services, including content that may contain personal data (including first name, last name, email address, any audio and image included within any video) that they will be stored in our Services for purposes of providing the Service and can be viewed by others, for example, on Questions or Answer Videos, according to the Platform options. Students may also upload content (text, images, photographs, videos, messages, comments, or any other kind of content) on the Services, including content that may contain the minimum personal information (including the first name, the initials of their last name, any audio and image included within any video) that they will be stored in our Services for purposes of providing the Service and can be viewed by others, for example, on Questions or Answer Videos, according to the Platform options.
  5. Messaging and Shared Content: Parts of the Services, depending of the type of User, let you interact with other users or share content, including by posting reviews and upvoting on a mentor’s profile page ( e.g after a session is completed) or answer, asking or answering questions, sending messages to students or instructors, or posting photos or other work you upload. Such shared content ( including your name or profile picture) may be publicly viewable by others depending on where it is posted. As an Educator or Mentor or Student you can send messages, alerts, and other communications (chat messages in live sessions) through the Services, including via email, notifications, and other similar means (chat in live sessions), in accordance with the use of Services and the option of the Platform, to the Students, or Educators, or Mentors or 100mentors. In this case your name and profile photo may be displayed to the person with whom you are messaging. We will store messages, including those on chat live sessions, and any content sent with the messages (e.g., photos), to provide the Services, to ensure the safeguards of the Services and to help Users to keep a log of their communications.
  6. Contact Information: As a User of the Service or as a general visitor to the Website, you may contact us in order to submit a request or a question or ask for customer support and technical assistance via email or otherwise, providing us with your personal data, such as a name, email address, or any other personal data and information included in the content of the contact. In this case, the personal data collected are not further used to market to the individual beyond providing the Services requested or responding to the requests or improving the Services.
  7. Any reviews that you submit about the Services or other Users: When a User provides feedback to another User (depending on the type of each User and the part of the Service) such as replying to a video question, like or upvoting a video or a text question/answer or a profile , or participating in live sessions, or answering in chat or reviewing his interaction with another User (e.g. Educator or Students may review a Mentor after a live session), we store the feedback in the Services for purposes of providing the Service. The User’s review along with the User’s name may be displayed on the platform and be publicly viewable by others depending on where it is posted (e.g. Students or Educators reviews about Mentors are posted on Mentor’s profile and may be publicly available if the profile of the Mentor is public).
  8. Testimonials: We may collect certain personal data (such as your name, photo, and/or video) if you choose to give us a testimonial. We post testimonials on our Service which may contain this personal data in the testimonial. By offering us your testimonials, we obtain your consent to post this content publicly. To request removal of your personal data from our testimonials, please contact us at [email protected].
2. Personal Data We Collect From Social Media and Other Content Platforms
  If you access the Services through a third party social networking connection or log-in e.g. Facebook, Google, LinkedIn and/or other OAuth providers (individually, a “ Social Networking Service’’), you may allow us to have access to and store certain account information and personal data from your profile in the Social Networking Services that you have configured to be made available to third parties in this manner. This can include your name, gender, profile picture, your “likes” and check-ins, location, birthday and your list of friends, depending on your settings on such services.If you do not wish to have this information shared, do not use a social networking connection to access the Services. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings.
3. Personal Data Collected Automatically
  When you use our Services or access our Platform, personal data are collected automatically. We may use a variety of technologies, including cookies and similar tools, to assist in collecting in accordance with applicable laws this personal data, relating mostly to the Services you use and how you use them .This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the Service. The technologies and the personal data we automatically collect include:
  1. Server log information and Website. Like most online services, when you use our Services or our Website, even if you have not created an account or logged in, we automatically collect and analyze personal data in our server logs such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs or device events such as crashes) referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, the date and time you used the Services, error logs, and other similar information.
  2. Mobile Applications, Device data and Software. When you use a 100mentors mobile application or software, we automatically receive certain information about the mobile phone, tablet, or computer used to access the application or software, including device identifiers, IP address, operating system, version, device type, device brand, device settings, file and software names and types, battery and signal strength, Internet service provider, browser type, domain name, the unique application number and other similar information, whether and when you install or uninstall or update the app, when you open the application, date and time of use, and how you use the app. Additionally, we may receive application state and crash log information which will help us debug and improve the 100mentorsApp.
  3. Cookies and other similar technologies. We may use cookies or similar technologies to gather information regarding the date and time of your visit and/or the information for which you searched and which you viewed and/or to identify your browser or device. A cookie is a small file of letters and numbers that does not contain any personal data, and that we store on your browser or the hard drive of your device. A cookie can contain information, such as a user ID or preferences, which the Services use to personalize content, track the pages you’ve visited or to save your password so you do not have to re-enter it each time you visit our Services. We do not track your personal data through cookies, unless you choose to provide this information to us giving your consent to our use of cookies when you first visit our Services by agreeing to the Cookies Policy of the Services or by continuing to navigate on our Services despite a clear and visible notice on our Services that we use cookies. If you change your mind, simply delete the cookies on your device (please refer to the software provider’s documentation) and you will be asked again if you agree or disagree with our use of cookies when you visit our Services next. You can also adjust your browser settings to receive a message every time a cookie is installed on your computer or to prevent their installation altogether. Although rejection of cookies will not interfere with your ability to interact with some of our Services, you will need to accept cookies if you choose to enter areas of our Services that require registration or login. Certain other functions and/or services might be unavailable to you if you reject cookies altogether. For more information about Cookies, please read our Cookie Policy.
  4. Google Analytics. We currently use Google Analytics. Google Analytics collects personal data anonymously and reports website trends without identifying individual visitors. Analytics uses its own cookie to track visitor interactions. Website owners can view a variety of reports about how visitors interact with their website, so they can improve their website and how people find it. You can prevent Google Analytics from collecting this information by installing the Google opt-out browser add-on: https://tools.google.com/dlpage/gaoptout . However, if you block all cookies you may not be allowed access to all or parts of our Site, and some functions and features of the Site and/or the Services may not work properly. Please see the following links for more information about Google Analytics: https://www.google.com/privacy.html and https://www.google.com/analytics/tos.html.
  5. Local storage. We may also use, collect, and store personal data locally on your device using mechanisms such as browser web storage (including HTML5) and application data caches. Like many services, 100mentors uses these technologies to analyze trends, gather demographic information, understand your engagement with the 100mentors Website, administer the Services, tailor the Services for you, and to help the Service work better for you.
  6. Activity Information. We also collect aggregated information regarding your activity on our Platform (such as the amount of questions made from Students or answers offered from Mentors, your message response rate, the likes on your profile etc.). Such information may be published on your public profile on our Platform.
4. Personal Data from Third-Party Sources
  We may receive additional information, including personal data such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups or We may collect personal data from publicly available sources. We use this information to update or supplement the information you provided or we collected automatically in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, and advertising.If we receive personal data from third-parties, we will handle it in accordance with this Privacy Policy. If we directly combine information we receive from other third-parties with personal information that we collect through the Service, we will treat the combined information as personal data and handle it in accordance with this Privacy Policy.
5. Special category personal data
  We do not collect data which is, by its nature, particularly sensitive [e.g. genetic data, biometric data, data revealing racial or ethnic origin, political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, criminal background or trade union membership,data that may facilitate identity theft or payment fraud (like social security files, financial account numbers, credit card details and government identification numbers)] unless it is volunteered by you. Ιn any case, and if you disclose this data to us voluntarily, it is at our disposal to erase them from the Platform.

Why and How We Are Legally Permitted to Process Your Data

For Students, please read additionally the Term 7 of this Privacy Policy.
For Users who access the Platform and/or register to create an account on the Platform and/or use the Services under the force of a separate agreement between 100mentors and an institution (educational or not) and/or a company and/or other legal entity aligned to them, please read additionally the Term 4.1. of the Privacy Policy.

Depending on the purpose for which we collect your data from time to time, we need to process one or other data, which will in general be, depending on each case, as in the following table. The legal terms on which we are permitted to process your personal data also depend on the purpose for which we process them, as explained in the following table:

Purpose of Processing	Legal Basis of Processing
For the registration or to manage your registration as User of the Platform	Performance of a contract with you If you decide to become a registered user of our Platform, we need to process your data to identify you as a user of the Platform and grant you access to the Services . So we process your data because this is necessary on the Τerms & Conditions, regulating the use of the Platform, otherwise we would be unable to manage your registration.
Provide, administer and develop the Services, including to display customized content and facilitate communication with other users; Maintain and improve our products and Services	Performance of a contract with you Legitimate interest We process your data because their processing is necessary for us to provide you the Services as agreed in Terms & Conditions, otherwise we would be unable to offer you the Services. Furthermore we consider that we have a legitimate interest in maintaining and improving the Services, since we understand that the processing of these data is also beneficial for you because the purpose is to improve the user experience and provide a higher quality service.
Allow you to participate in interactive features of our Services, when you choose to do so;	Performance of a contract with you Consent We process your data because their processing is necessary for us to provide you access in the Services with interaction as agreed in Terms & Conditions, otherwise we would be unable to offer you the Services. We are legally permitted to process your data for this purpose due to the consent that you give us when you interact on your own will via the Services or when registering to the Platform in order to use its Services.
Ensure compliance with (i) applicable laws, (ii) our Terms and Conditions, and (iii) our Privacy Policy. Certain breaches that we regard as inappropriate may lead to the suspension of your account; Το investigate misuse of your account, or fraud	Performance of a contract with you Legitimate interest Legal obligation We process your data because processing is necessary for us to check if you keep your contractual obligations when using your account as agreed in Terms & Conditions. We have also legitimate interest in order to protect the Services and their use from their misuse and for some Services. It is necessary for us and we are legally obliged to ensure the safety or integrity of our users, employees, third parties, the public, or our Services. We are also legally permitted to process your data for ensuring the compliance with applicable laws.
Customer Support- Managing our relationship with you -Communicate with you about your account	Performance of a contract with you Legitimate Interest Legal Obligation We consider that it is our contractual obligation as well as we have legitimate interest in answering the requests or inquiries raised by you. We understand that the processing of these data is also beneficial to you or necessary to use the Services. When your consultation is related to the exercise of your rights on which we inform you below, or to claims on the Services, we are legally permitted to process your data for checking the compliance with the legal obligations.
Μarketing - Promotional Activities	Consent Legitimate Interest We are legally permitted to process your data for marketing purposes due to the consent that you give us when registering to the platform, or when you accept receiving customized information through multiple channels, when authorizing the sending of push notifications in your mobile device or when accepting the legal terms and conditions to participate in a promotional action. We consider that we have legitimate interest to show you customised information, or to facilitate the Services or to give you recommendations about goods or services related to our services that may interest you.
Analysis of usability, quality and engagement	Performance of a contract with you Legitimate interest Consent We process your data in terms of the analysis of usability, quality and engagement because their processing is necessary for the implementation of our agreed terms in our Terms & Conditions and/or - in case of a separate agreement between 100mentors and an institution (educational or not) and/or company and/or other legal entity under the force of which you access, register and use the Platform -, for the additional implementation of such an agreement. We consider that we have a legitimate interest in analysing the Platform usability, the User’s engagement with the Platform Services, the User’s interaction with other Users and the User's satisfaction degree, since we understand that the processing of these data is also beneficial for you (and/or the entity you represent in case of using the platform on behalf of or due to an agreement with an institution or company or other legal entity) because the purpose is to improve the user experience, provide a higher quality service and implementing Platform’s Services. We are legally permitted to process your data for analysis purposes due to the consent that you give us when accepting this policy.
Learn more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers	Legitimate interest We consider that we have a legitimate interest, since we understand that the processing of these data is also beneficial for you because the purpose is to improve the user experience and provide a higher quality service.

Your consent Where the legal basis for us processing your personal data is that you have provided your consent, you may withdraw your consent at any time. You will not suffer any detriment for withdrawing your consent. If you withdraw your consent, this will not make processing which we undertook before you withdraw your consent unlawful.
You can withdraw your consent by contacting us in our contact [email protected].

How and Where We Share Your Personal Data
1. We may share your data with third parties (recipients) under the following circumstances or as otherwise described in this Privacy Policy:
  1. With Other Users: We share certain personal data that we have about you depending of what type of User you are, with other Users if it is necessary to provide the Services or/and improve the Services for you as well as if it necessary for you to interact with other User’s during the provision of Services. This data may include things like your name, your voice or your activities on 100mentors.The data collected by you (like age or class) have been provided by you on your own will, and if additional to the ones that are mandatory for registering, may be shared too. We will not share your email address with no user, except in the case that you are a Student or an Educator using the Services under the umbrella of the same institution, business unit or programme. In this case, the email of a Student or/and an Educator who uses the Services under an institution or business unit or a customized educational programme are disclosed to the other Users (Students or/and Educators) who are registered to the Platform under the umbrella of this same institution, business unit or programme (e.g. the Students emails are visible to their Educators, the email of an Educator is visible to its colleagues from the same school). No Educator or Student profiles are made available to the general public through our Services. A Mentor may choose on his own if his profile would be available to the general public or be private through our Services. If a Student or an Educator reviews a Mentor, his review on the Mentor’s profile along with his username may be publicly available if Mentor’s profile is publicly available. If a Student asks a question to a Mentor or Educator, some personal data may also be publicly viewable by other users. Please keep in mind that information (including personal Information or Student’s personal information) or content that you voluntarily disclose to others - including to other users you interact with through the Services (such as messages you might send other users or other educators ) - can be viewed, copied, stored, and used by the people you share it with without our liability. We cannot control the actions of people with whom you choose to share information and we are not responsible for the collection, use or disclosure of such information or content by others.
  2. With third parties under a contract: If your right to access, register and use the Platform and its Services is under a separate contract agreement between 100mentors and an institution(educational or not) and/or a company and/or a business unit and/or other legal entity ( herein Contractual Party), we may share some of your data with the Contractual Party who gave you the right to access, register and use the Platform, such as your email, name, your usability data. Upon your registration to the Platform under the force of such an agreement, you consent our right to share this data with the Contractual Party.
  3. With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like financial institutions, technological service providers, service providers, providers of customer support related services, data analysis, marketing and advertising services, email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service. We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy
  4. With Analytics Services: As part of our use of third-party analytics tools like Google Analytics we share certain contact information, Account Data, System Data, Usage Data), or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner.
  5. For Marketing reasons: We may use the personal information of Mentors (voice, image, name ) to provide marketing material for 100mentors marketing promotional campaigns either to our social media platforms or other media channels since we understand that the processing of these data is also beneficial for you (and/or the entity you represent in case of using the platform on behalf of or due to an agreement with an institution or company or other legal entity) because the purpose is to facilitate the Services and improve the user experience. We are legally permitted to process your data as a Mentor for marketing purposes due to the consent that you give us when registering and accepting this policy. As a Mentor,you can withdraw your consent by contacting us in our contact [email protected]. In addition, as a Mentor you may share your personal data ( not including any other User’s data) such as your voice and name by sharing your answer as a Mentor solely to your social media accounts using the relevant feature of the Platform. No other disclosure is permitted according to Terms and Conditions.
  6. Aggregated Information and Non-Identifying Information: Notwithstanding the above, we may share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other de-identified or non-personally identifiable information (such as statistics about visitors, traffic and usage patterns), including with users, partners or the press in order to, for example, demonstrate how 100mentors is used, spot industry trends, or to provide marketing materials for 100mentors. Any aggregated information and non-personalized information shared this way will not contain any personal information.
  7. Social Media Platforms: Where permissible according to applicable law, we may share certain limited personal information with social media platforms (such as Google or Facebook) and other websites, applications or partners, to generate leads, drive traffic to our websites or otherwise market and advertise our products or services on those websites or applications (this will never include personal information of Students). These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products and services that may be of your interest. These social media platforms with which we may share your personal information are not controlled or supervised by 100mentors. Therefore, any questions regarding how your social media platform processes your personal information should be directed to such a provider.
  8. To Administer Promotions and Surveys: we may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.
  9. For Advertising: If we decide to offer advertising in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data and to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising) and undertake web analytics. Advertisers may also share with us the data they collect about you.
  10. For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
    1. Permitted or required by law;
    2. Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
    3. Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
    4. Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
    5. Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
    6. Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of 100mentors, our users, employees, members of the public, or our Services.
  11. Affiliates: We may share some or all of your personal data with our subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
    1. During a Change in Control: We may share some or all your personal data in connection with or during negotiation of any merger, financing, acquisition or dissolution(including bankruptcy), transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset (including during due diligence). If another company acquires our company, business, or assets, that company will possess the personal data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
    2. With Your Permission: with your consent, we may share data to third parties outside the scope of this Privacy Policy. 100mentors does not sell User personal data.
2. Data transfers In principle, we transfer and store the personal data that we collect about you in the countries of the European Economic Area (“EEA”). However, for service efficiency purposes, since for example some of our service providers or our users are based in countries outside of the EEA (“third countries”), we may also transfer some of your data to third countries, including the United States. The third countries may not have the same data protection laws as the EEA countries. In that case, we will protect the data as described in this Privacy Policy and ensure that the third parties agree to comply with applicable legal requirements providing adequate protection for the transfer of data and ensuring that appropriate safeguards have been put in place (especially standard contractual clauses based on the EU Model Clauses). By using the Site and the Services, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to countries outside of the EEA.
Data Security
100mentors takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and 100mentors, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact info@100mentors with any concerns.
Data Retention
We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Some of the Personal Data that we have collected may become anonymous (like questions, messages, photos) after their deletion in order to develop the Services. In some circumstances you can ask us to delete your data: see below Term 8 for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Students
1. 100mentors does not permit students under the age of 13 to create an account and does not knowingly collect personally identifying information from children under the age of 13. Students under 13 years old can only use the Services i) after taking access to the Services by a teacher or school or an “educator” who is authorized to give you access to the Services and has obtained the prior verifiable consent by your parent or legal guardian consent and ii) via their parent or legal guardian who will register to the Platform after taking access to the Services by a teacher or school or an “educator” who is authorized to give you access to the Services and has previously confirmed that he is the parent or the legal guardian of the Student. 100mentors will not ask students under age 13 for more information, as a condition of participation, than is reasonably necessary to participate in a given activity through the account of the educator or their parent. Any disclosure of personal data collected from students under the age of 13 to third parties, except to those data which are disclosed to other Users who interact with them in order to provide the Platform Services, may be used for purposes of site analytics, billing and marketing after being anonymised. If any information is disclosed to 100mentors by a Student under the age of 13 without its parent permission, that student’s parent may contact 100mentors using the contact information below to ascertain the information collected and/or to request its deletion.
2. Students between 13 and under 16 years old may create an account on your own after an invitation or giving access to the Services by a teacher or school (educator) or 100mentors who is authorized to give you access to the Services and has obtained the prior verifiable consent by your parent or legal guardian consent (for example giving you a unique student verification code or a link via email to allow you to set up your own account) . We request and collect minimal personal information to be provided from Students to register to the Services (email address/name, password, the unique code from the educator or 100mentors or the link via email). Please Students do not provide any personal data about yourself to us, other than what we request from you when you use the Services. 100mentors may collect and store question, answers and class marks provided by Students for the purpose of providing feedback to the Student and the educator or the educational institution in which the Student studies and for compiling reports. Furthermore, when a Student posts content (text, images, photographs, videos, messages, comments, links, or any other kind of content) using the Service, the information contained in the posting, including any audio and image included within any video will be stored in our Services as per the consent provided. In addition to the information entered by the Student, we automatically collect some personal data from any use of our Service as set forth in the III. Personal Data Collected Automatically section.
3. Students over the age of 16 years old: You are able to create an account giving your own consent and all the terms of this Privacy Policy apply to you.
4. Consent: In relation to the offer of online services directly to a child, GDPR indicates that the processing of the personal data of a child shall be lawful where the child is at least 16 years old. Where the child is below the age of 16 years old, such processing shall be lawful only if and to the extent that consent is given or authorised by the holder of parental responsibility over the child and can be verified taking into consideration the available technology. Consent may be obtained by 100mentors:
  1. From the Educator (Educator Consent). We require that the educator has obtained, directly from the parents, prior parental consent for their child to use 100mentors for education purposes at the school or may choose to act as the agent of the parent and consent on their behalf , if he gives access and allows students under the age of 13 to use some Services after taking access to the Services through educators account ( such as student questions) or if he gives access to the parent or legal guardian of a student under the age of 13 by sending them an invitation code or email to register to the Platform in order to use the Services ; or if he invites the students between the age of 13-16 to set up their account by sending them an invitation code; or additionally
  2. Directly from the parent (Parent Consent). We may obtain parental additional consent directly from a student’s parent if a student between the ages of 13-16 creates his or her own account, after the student has received the unique verification code or we may confirm directly from the parent its consent if this parent has registered to the Platform in order to give access to his child under the age of the 13.
5. We will not retain a student’s personal data for any longer than is necessary for educational purposes or legal obligations, or to provide the Services for which we receive or collect the student’s personal data.
Rights of the data subject
1. Right of confirmation. You have the right to obtain from us the confirmation as to whether or not personal data concerning you are being processed.
2. Right of access. You have the right to obtain from us free information about your personal data stored at any time and a copy of this information.
3. Right to rectification. You have the right to obtain from us the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the ability to change or alter any incomplete or inaccurate data we hold about you. In any case, please take into account that, by actively making your personal data available to us through any procedure, such data should be true and accurate and you should notify us any change or modification of your data. Please remember that, as a general rule, you must provide us only with your own data, not with those of third parties, other than to the extent otherwise permitted in this Privacy Policy.
4. Right to erasure (Right to be forgotten)
  You have the right to obtain from us the erasure of personal data concerning you where one of the following grounds applies, as long as your personal data are no longer necessary for the purpose for which we need to keep processing them, as we have explained above, or when we are no longer legally permitted to process them:
  1. The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  2. You withdraw consent to which the processing is based, and where there is no other legal ground for the processing.
  3. You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR.
  4. The personal data have been unlawfully processed.
  5. The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  6. The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
5. Right of restriction of processing
  You have the right to obtain from us restriction of processing where one of the following applies:
  1. Right of restriction of processing You have the right to obtain from us restriction of processing where one of the following applies:
    1. The accuracy of the personal data is contested by you for a period enabling the controller to verify the accuracy of the personal data.
    2. The processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead.
    3. We no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.
    4. You have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
6. Right to data portability
  You have the right to receive the personal data concerning you which was provided to us in a structured, commonly used and machine-readable format. You have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
7. Right to object
  You have the right granted to object, on grounds relating to you particular situation, at any time, to processing of personal data concerning you , which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.We shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If we processes personal data for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing. In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you by the 100mentors for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8. Automated individual decision-making, including profiling
  You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between us or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on yours explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, 100mentors shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of us to express our point of view and contest the decision.
9. Right to withdraw data protection consent
  You have the right to withdraw your consent to processing your personal data at any time.
10. You have the right to make a complaint to the relevant data protection supervisory authority in Greece or to seek a remedy through the courts if you believe that your rights have been breached. If you wish to exercise any of the abovementioned rights, you may, at any time, contact us in our contact information: [email protected].
Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
Changes to our Privacy Policy
Any changes we may make to our Privacy Notice in the future will be posted on this page. Where appropriate, we will notify you or seek your consent. Please check back frequently to see any updates or changes to our Privacy Policy. Unless stated otherwise, modifications will become effective on the day they are posted. As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.
How To Contact Us
If you have any questions or comments about this Privacy Policy, or if you would like us to update the personal data we have about you or your preferences or exercise any of your rights, please contact us by:
1. Emailing us at [email protected]
2. Sending us your communication to our Marketing Team at 100mentors, Pl. Kornarou 31, Heraklion Crete, Greece