Privacy Policy

Welcome to Nominee! We’re glad you’re here.

At Nominee (referred to as “Nominee”, “we”, or “us”), we understand that you want transparency about how we process your personal data. This Privacy Policy contains information about your privacy and your rights. We encourage you to read our Privacy Policy and our Terms and Conditions before you use Nominee.

This Privacy Policy applies to your use of Nominee and related services at https://gonominee.com, to our use of social media, and to the communications you may have with us from time to time (together, the “Services”). Under the General Data Protection Regulation (“GDPR”), Nominee is a data controller for the Services.

If you have any concerns or inquiries regarding the processing of your personal data, do not hesitate to contact us. You can email us at team@gonominee.com.

Key Definitions

In this Privacy Policy, the following terms when used with a capital letter have the meaning explained below:

“Users” means individuals who are subscribed to the Nominee platform, either as Mentors or Mentees.

“Mentee” means a user of Nominee which uses our Services to connect with Mentors. 

“Mentor” means an individual who is providing Mentees with mentorship sessions through the Nominee platform.

Personal Data and Cookies

This Privacy Policy applies to personal data. We consider that “personal data” means any information which allows us to identify you directly or indirectly, including using “cookies” and other electronic data. Some information may not be personal on its own but may become personal data if associated with or if the sum of the information allows us to identify you. 

A “cookie”  is information that a website puts on your hard disk so that the website can remember something about you at a later time. In this Privacy Policy, when we refer to “cookies”, we include other technologies with similar purposes, such as pixels, tags, or beacons. If you are looking for more information on cookies, you can refer to websites such as http://www.cookiecentral.com and https://www.allaboutcookies.org.

This Privacy Policy is for transparency purposes and some of the data that we identify in this Privacy Policy as personal data may not be protected as personal data under applicable laws. For instance, business contact information is excluded under some privacy laws but is considered personal data under the GDPR.

When does this Privacy Policy not apply?

If you click through to links to third party websites, applications, or services from our Services, this Privacy Policy does not apply to the processing of personal data by such external services. It is always a good idea to read their privacy policies to understand what they do with your personal data.

What types of personal data do we collect?

We collect personal data to offer our Services and perform analytics. Depending on the jurisdiction you are in, we use different legal bases to process your data. In Canada and the United States, we rely on your consent. If you are in the European Union, we rely on different legal bases to justify our processing of your personal data, such as consent, the performance of a contract, and our legitimate interests. These legal bases may not be valid under all jurisdictions and are indicative. Each time consent is a legal basis, you can withdraw your consent at any time.

We have set out below, in a table format, a description of all the ways we use your personal data and which of the legal bases we rely on to do so.We have also identified what our legitimate interests are, as appropriate.

Electronic Data

We Collect:

  • IP address

  • device type

  • operating system and Internet browser type

  • screen resolution

  • operating system name and version

  • device manufacturer and model

  • language

  • plug-ins

  • add-ons

  • location/ time zone information

  • language

  • geolocation

  • device type

  • operating system and Internet

Purposes and Legal Basis:

This information is collected automatically by our Services to function effectively, to fix bugs, or ensure the security of our Services. For instance, we may collect the language of your browser so that we present you with the right linguistic version of the Services. Geolocation and time zone allows us to offer you tutoring session schedules based on your time zone. 

We collect electronic data based on our legitimate interest to make our Services functional and secure.

Usage and Performance Data

We collect:

  • Time spent on the Services

  • Pages visited

  • Links clicked

  • Language preferences

  • Pages that led or referred you to the Services

Purposes and Legal Basis:

We collect this information to understand the usage of our Services, whether there are bugs, and generally, to improve our Services.

Usage data do not allow us to determine your identity and are generally provided as aggregated data or by reference to an anonymous identifier. 

We collect usage and performance data based on your consent.

Communication Data

We collect: 

  • email addresses 

  • publicly available information

  • email content

  • logs of live chats

  • mentees’ booking message to mentors

Purposes and Legal Basis:

If you communicate with us by email, on social media, or by any other means, we collect the personal data that you share with us, such as your email address and the content of your communication. 

If you communicate with us using social media, we will have access to your publicly available information.

We can also access the booking messages sent from Mentees to Mentors, for instance, to resolve a claim concerning the mentorship session. 

We collect communication data based on consent.

User Profile Information

When Mentees and/or Mentors make a profile, we collect: 

  • Profile picture

  • Full name

  • Pronouns

  • Email address

  • Phone number

  • Location

  • Experience

  • Areas of expertise

  • Areas of interest

  • Linked social media accounts

Purposes and Legal Basis:

We collect this information to build a profile so that we can help to match you with relevant Mentors/Mentees based on complementary needs and interests.

We collect this data based on consent.

Login Credentials

  • You can log in to our Services using your email and password.

Purposes and Legal Basis:

We require an email and password for you to login into the Services. 

We collect this data based on consent.

Interactions Between Mentees and Mentors

Nominee can see all booking requests, and information associated with bookings, such as:

  • The booking message

  • When the booking was created

Purposes and Legal Basis:

We can access these categories of information between Mentors and Mentees so that we can investigate claims about the Services and verify the quality of the Services.

We collect this data to perform our contractual obligations.

Marketing Data

We collect: 

  • Email 

  • Consent to receiving emails

Purposes and Legal Basis:

We collect marketing data so that we can send you newsletters and marketing communications.

If you consent to receive our newsletters, we will regularly send newsletters announcing new mentors, features, promotions, requests, and important Nominee information.

You can unsubscribe at any time directly in the emails or by contacting us.

We collect marketing data based on consent.

Financial Information

We collect financial data relating to your purchases:

  • Date of purchase, amount, method of payment, history of purchases, time of purchase, and details about the nature of the transaction.

Purposes and Legal Basis:

We require payment information to allow our payment processor Memberspace to process payments. 

Memberspace also uses the Identification Data that you provide with your Financial Information to conduct verifications to prevent fraud and money laundering. Memberspace is certified PCI DSS Level 1.

We collect this data to perform our contractual obligations.

Identification Data

  • We collect personal data when you fill out forms to communicate with us.

Purposes and Legal Basis:

If you communicate with us by email, on social media, or by any other means, such as by filling out a form on our Website, we collect the personal data that you share with us, such as your email address and the content of your communication. If you communicate with us using social media, we will have access to your publicly available information.

We collect this data based on consent.

Social Media Data

  • Publicly available information.

If you follow us or interact with us on social media, we may process your personal data for marketing or advertising purposes, subject to applicable laws, including those on consent.

We collect this data based on our legitimate interests as part of our direct marketing strategy.

What cookies do you use and why?

We use cookies for our Services to function as intended, to conduct marketing, to provide functionalities on our Platform, to analyze our performance, and to ensure that our Services are secure. Cookies are also useful to identify bugs and errors. We use both first-party and third-party cookies installed by partners on our Website.

We collect essential, functional, and analytics cookies. These are installed by us and third parties. We install essential cookies based on our legitimate interests, as essential cookies are required to provide you with the Services. However, we only install functional and analytics cookies based on your consent.  

Do you use Google Analytics? 

Yes, Nominee uses Google Analytics to view key metrics such as how many visitors view the website, peak hours of traffic, and response to specific marketing campaigns or press. Google Analytics is Google’s analytical tool that helps us to understand how users engage with our Services. It uses a set of cookies to collect information and report site usage statistics without allowing us to identify individual visitors. We also track paid ads on Google Analytics. 

For more information on Google Analytics, including how to opt-out from certain data collection, please visit  https://tools.google.com/dlpage/gaoptout?hl=en.

Who do you share my personal data with?

We share your personal data with third parties for a number of reasons including to (1) to provide you with the Services (2) to provide IT support, (3) to process payments, (4) to send emails, and communicate with you, (5) to market our Services, (6) to offer chat functions and videoconferencing, and (7) as required by the law. We can also share your personal data in the context of a merger and acquisition, as part of bankruptcy procedures or for other corporate requirements.

In the case of a merger or acquisition, sale of assets, corporate reorganization, bankruptcy filing, insolvency procedures, or similar circumstances, your personal data would be considered our assets and property. In these circumstances, ownership of the personal data we collected may be transferred or we may have to share some of your personal data to conclude, negotiate or discuss with third parties. We will only share what we are required to share for these specific purposes.

We are not data brokers, and we do not sell your personal data to third parties.

Where do you store my personal data?

We use Amazon Web Services (“AWS”) to host our Services and to store your personal data in the United States. However, our service providers may process your personal data internationally, including in the United States, depending on where they are located.

If you are in the European Union, we are required to ensure that appropriate safeguards are in place prior to transferring your personal data out of the European Union. We do so through standard contractual clauses, as is the case for AWS, or through other safeguards when they are available. 

How long do you retain my personal data?

We retain personal data for as long as necessary to provide you with the Services, to perform our marketing campaigns effectively or as required by applicable laws, whichever is longer. We use both persistent and session Cookies. Session cookies are deleted once you close your browser, whereas persistent cookies remain active on your device for some time. For instance, Google Analytics cookies remain installed on your device for 2 years. This allows Google Analytics to track you for analytic purposes, as well as for marketing purposes, and to provide us with aggregated data on your behavior.

How do you keep my personal data secure?

Our data centers are certified by independent auditors based on several frameworks, such as SOC 1/ISAE 3402, SOC 2, SOC 3, ISO 9001, ISO 27001, ISO 27017, and ISO 27018. Our payment processor, Memberspace, is certified PCI DSS Level 1. When we develop our Services, we refer to security best practices such as OWASP. However, securing your personal data takes teamwork. You also need to do your part, such as by keeping your credentials confidential and using secure networks, especially when you make payment.

Can I manage my cookie preferences?

You can manage your cookie preferences through your browser. However, if you turn all cookies off, you may not have access to the same functionalities as other users.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. When material changes are made to this Privacy Policy, Customers will be notified through the contact email given to us at least two weeks prior to modification taking effect. Questions about the new Privacy Policy should be addressed to team@gonominee.com.

Last Updated: October 25, 2021