Privacy Policy

Last updated: November 19, 2025

1. Data Controller

MentorSub Limited, Level 4, 114 Featherston Street, Wellington Central, Wellington 6011, New Zealand is the data controller responsible for your personal information.

2. Information We Collect

We collect information you provide directly to us, such as when you create an account, complete your profile, or contact us for support. This may include:

  • Name, email address, and location

  • Profile information including professional background and expertise

  • Messages and communications through our platform

  • Payment information (processed securely by Stripe)

  • Audio and video recordings of mentorship sessions conducted through our platform

  • Transcriptions of recorded mentorship sessions

  • Usage data and analytics (when you consent to cookies)

3. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), we process your personal data based on:

  • Contract Performance: Processing necessary to provide our mentorship platform services

  • Legitimate Interest: Platform improvements, fraud prevention, and security

  • Consent: Marketing communications and non-essential cookies (you can withdraw anytime)

  • Legal Obligation: Compliance with tax and payment regulations

4. How We Use Your Information

We use the information we collect to:

  • Provide, maintain, and improve our mentorship platform

  • Match mentors with mentees based on expertise and preferences

  • Process payments and manage subscriptions

  • Analyze mentorship interactions using artificial intelligence to generate summaries, extract action items, identify discussion topics, and track progress

  • Process voice call transcriptions and message conversations to provide insights and improve the mentorship experience

  • Send you important updates and notifications

  • Provide customer support and respond to inquiries

5. Information Sharing and Third-Party Processors

We do not sell, trade, or rent your personal information to third parties. We work with trusted service providers who process data on our behalf:

  • Stripe (USA): Payment processing - covered by EU-US Data Privacy Framework

  • SendGrid (USA): Transactional emails

  • Google Analytics (USA/Global): Website analytics (only with your cookie consent)

  • Whereby (Norway): Video conferencing and transcription services

  • OpenAI (USA): AI processing of transcriptions and messages to generate insights, summaries, and action items

  • Bugsnag (USA): Error monitoring

We may also share information with other users as part of the mentorship matching process, and when required by law or to protect our rights and safety.

6. International Data Transfers

Your data may be transferred to and processed in countries outside the EEA, including the United States. We ensure appropriate safeguards are in place through:

  • EU-US Data Privacy Framework for US-based processors

  • Standard Contractual Clauses with service providers

  • Adequacy decisions (e.g., Norway for Whereby)

7. Voice Call Recordings and Transcriptions

Recording Notice: Mentorship sessions conducted through video calls on our platform may be recorded and transcribed. By using our video call features, you consent to these recordings.

How It Works:

  • Video Calls: Sessions are conducted through Whereby, our video conferencing provider

  • Recording: Voice calls may be recorded to enable transcription and AI-powered analysis of mentorship sessions

  • Transcription: Whereby generates text transcriptions of the audio from recorded sessions

  • Storage: Transcriptions are stored securely in our database and are accessible to session participants (mentor and mentee)

Why We Record and Transcribe:

  • To provide participants with a written record of their mentorship discussions

  • To enable AI-powered analysis that generates session summaries and extracts key action items

  • To help track mentorship progress and commitments over time

  • To improve the quality of mentorship experiences on our platform

Admin Access and Security:

  • Restricted Access: MentorSub administrators have limited access to recordings and transcriptions

  • Logged Activity: All admin access to sensitive data (recordings, transcriptions, messages) is logged and audited

  • Purpose Limitation: Admin access only occurs for legitimate purposes including:

    • Investigating reported abuse or policy violations

    • Providing technical support and debugging issues

    • Responding to legal requests or obligations

    • Ensuring platform security and preventing fraud

Data Deletion: Recordings, transcriptions, and AI-generated insights are permanently deleted when you delete your account. Individual deletion of specific recordings or transcriptions is not currently available, but all data is removed when you exercise your right to erasure by deleting your account.

8. Artificial Intelligence and Data Processing

We use artificial intelligence (AI) technology to enhance your mentorship experience and provide valuable insights from your interactions.

What We Process with AI:

  • Session Transcriptions: Text transcriptions from recorded video calls are analyzed by AI

  • Message Conversations: Text messages exchanged between mentors and mentees may be analyzed

  • Combined Analysis: Both transcriptions and messages are processed together to provide comprehensive insights

How AI Processing Works:

  • Transcriptions and messages are sent to OpenAI's services for processing

  • AI analyzes the content to generate summaries, identify discussion topics, extract action items, and track commitments

  • Generated insights are stored in your account and visible to both mentor and mentee

  • We do not use your data to train third-party AI models

  • OpenAI processes data according to their data processing agreement and does not retain your data for model training

Purpose of AI Analysis:

  • Progress Tracking: Help mentors and mentees track goals and commitments over time

  • Action Items: Automatically extract and organize action items from discussions

  • Session Summaries: Generate concise summaries of mentorship sessions

  • Topic Identification: Identify key topics and themes in mentorship conversations

  • Insights: Provide recommendations and insights to improve mentorship outcomes

Data Protection: All data sent to AI services is transmitted securely using encryption. We have data processing agreements in place with our AI providers to ensure your information is handled in accordance with applicable privacy laws.

Access Controls: Access to your transcriptions, messages, and AI-generated insights by MentorSub staff is strictly controlled, logged, and only occurs when necessary for the purposes stated above (investigating abuse, technical support, legal compliance, or security).

Data Deletion: AI-generated insights are permanently deleted when you delete your account.

9. Cookies and Tracking

We use essential cookies for authentication and platform functionality. We also use non-essential cookies for analytics with your consent:

  • Essential cookies: Required for login and core functionality (no consent needed)

  • Analytics cookies: Google Analytics for understanding site usage (requires consent)

You can manage your cookie preferences through the consent banner or your browser settings.

10. Data Retention

We retain your personal information for as long as necessary:

  • Account data: While your account is active plus 30 days after deletion

  • Messages: While your account is active

  • Voice call recordings and transcriptions: While your account is active; deleted when you delete your account

  • AI-generated insights: Retained as part of your mentorship records; deleted when you delete your account

  • Payment records: 7 years (legal requirement for tax purposes)

  • Analytics data: Up to 26 months

11. Data Security

We implement appropriate technical and organizational security measures to protect your personal information:

  • Encrypted data transmission (HTTPS/TLS) and storage

  • Role-based access controls limiting who can access sensitive data

  • Comprehensive audit logging of all administrative access to recordings, transcriptions, and messages

  • Regular security assessments and monitoring

  • Strict internal policies limiting data access to authorized personnel for legitimate purposes only

Internal Access Policy: Our employees and administrators can only access your recordings, transcriptions, and messages when necessary for investigating reported abuse, providing technical support, responding to legal obligations, or maintaining platform security. All such access is logged and subject to regular audit.

However, no internet transmission or electronic storage is completely secure, and we cannot guarantee absolute security.

12. Your Privacy Rights

You have the following rights regarding your personal data:

  • Right to Access: View and download your personal information

  • Right to Rectification: Update inaccurate or incomplete data

  • Right to Erasure: Delete your account and all associated data including recordings, transcriptions, messages, and AI-generated insights

  • Right to Data Portability: Export your data in a machine-readable format

  • Right to Object: Opt-out of certain data processing

  • Right to Restrict Processing: Limit how we use your data

  • Right to Withdraw Consent: Withdraw cookie consent or marketing preferences anytime

To exercise these rights, visit your account settings or contact us at support@mentorsub.com.

EEA residents: You have the right to lodge a complaint with your local supervisory authority if you believe your data protection rights have been violated.

13. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of any significant changes by posting the new policy on this page and updating the “Last updated” date.

14. Contact Us

If you have any questions about this privacy policy, please contact us at support@mentorsub.com