Effective as of June 29, 2022.
We at Mensch Capital Partners (together with its affiliated companies – “Mensch”, “we”, “us” or “our”) put great efforts in communicating our privacy practices and in making sure that the information we process is safe and properly used.
The activities described above are the “Services” to which this Policy applies. Please note that this Policy does NOT cover our privacy practices regarding specific services offered by Mensch, which have separate privacy policies and notices.
Specifically, this Policy describes our practices regarding:
You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined in Section 5 below), please avoid any interaction with us or with our Site, or submit a request to exercise your rights as further explained in Section 9 below.
We collect and generate the following types of personal data concerning our Visitors:
Site Usage Data: connectivity, technical and aggregated usage data, such as user agent, IP addresses, device information (like type, OS, device ID, browser version, locale and language settings used), connectivity data, activity logs, communication and performance logs, session recordings, issues and bugs, and the cookies and pixels installed or utilized on our Site and/or a Visitor’s device;
Prospective Customer Data: Data relating to individuals who are employed or engaged by our prospective business customers, which we may collect in the following ways –
We collect such data either automatically, through your interaction with us or with our Site, or through third-party services, social media, analytics tools, events we organize or participate in, and other business initiatives.
We use Visitors’ personal data as necessary for the following purposes and in reliance on the following legal basis:
Site Usage Data
Prospective Customer Data
We do not sell your personal information for the intents and purposes of the California
Consumer Privacy Act (CCPA).
If you reside or are using the Site in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us), your acceptance of this Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy. If you wish to revoke such consent, please contact us at firstname.lastname@example.org.
We and our authorized Service Providers (defined in Section 5 below) maintain, store and process personal data in the United States of America, the EU, the UK, Israel, Japan and other locations, as reasonably necessary for the proper performance and delivery of our Site and its Services, or as may be required by law.
While privacy laws may vary between jurisdictions, Mensch, its affiliates, and Service Providers engaged in processing hereunder, are each committed to protect personal data in accordance with this Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection – regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
To the extent we transfer Visitors’ personal data originating from the European Economic Area (EEA), the UK or Switzerland elsewhere, we rely on appropriate data transfer mechanisms as established under applicable law, such as the standard contractual clauses adopted by the EU, the UK or Switzerland. You are entitled to request a copy of the standard contractual clauses used in these cases, and may do so by e-mailing email@example.com.
We retain Visitors’ personal data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Site and offerings; in order to comply with our legal and contractual obligations; to pursue our legitimate business purposes; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at firstname.lastname@example.org.
We may share your data with certain third parties, including law enforcement agencies, our Service Providers and our affiliates, in accordance with this Notice and as described below:
Legal compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our Site, products, and services.
Service Providers: We may engage selected third-party companies and individuals to perform services complementary to our own. Such service providers may include hosting and server colocation services, communications and content delivery networks (CDNs), data security services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session, call or activity recording and analysis services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemail, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers”). Our Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Site and Services, and may only use the data for such limited purposes as determined in our agreements with them.
Third-party websites and services: Our Site may include links to third party websites and integrations with third party services. Such websites and third-party services, and any data you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this Policy.
We encourage you to carefully read the terms and privacy policies of such website and third party services.
Protecting rights and safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Mensch, any of our Visitors, users or customers, or any members of the general public.
Mensch affiliated companies; change of control: We may share personal data internally within our group, for the purposes described in this Policy. In addition, should Mensch or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Site.
Additional sharing: For the avoidance of doubt, Mensch may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
Cookies: Cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session – these are the “session cookies”. Some last for longer periods and are called “persistent cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Site. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.
We may engage you in service and promotional communications through e-mail, phone, SMS and notifications. We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Site, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Mensch at any time by sending an e-mail to email@example.com or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
We implement industry-standard physical, procedural and electronic security measures to secure your personal data held with us and our Service Providers, in order to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, please be aware that regardless of any security measures used, we cannot and do not guarantee that our Site will be immune from any wrongdoing, malfunctions, unlawful interceptions or access, or other kinds or abuse and misuse.
If you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as the right to know; the right to request access to, and rectification or erasure of, your personal data held with Mensch; to restrict the processing of such data and to object to its processing; to port such data; or the right to equal services and prices (each to the extent available to you under the laws that apply to you) – you may do so by contacting us at firstname.lastname@example.org.
Please note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
Please also note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any applicable legal or regulatory restrictions.
Certain data protection laws and regulations, such as the GDPR and the CCPA, typically distinguish between two main roles for parties processing personal data: the “Data Controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, “service provider”), who processes the data on behalf of the Data Controller.
Mensch is the Data Controller of its Visitors’ personal data, and assumes the responsibilities of a Data Controller, solely to the extent applicable under law and as set forth in this Notice. In such instances, our Service Providers processing such data on our behalf will assume the role of Data Processor.
Updates and Amendments: We may update and amend this Policy from time to time by posting an amended version on our Site. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us. After such notice period, all amendments shall be deemed accepted by you.
External Links: While our Site may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Site for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Policy applies only to our Site.
Our Site is not designed to attract children under the age of 16: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Site (or under the age of 13 if this is the legal requirement in your jurisdiction), we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at email@example.com.
Questions, concerns or complaints: If you have any comments or questions regarding this Policy, or if you have any concerns regarding your personal data held with us, please contact us at firstname.lastname@example.org. If you are a GDPR or UK GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority, or the UK’s Information Commissioner’s Office, as appropriate.