Mentora Privacy & Personal Data Protection Policy

How Mentora collects, uses and protects your personal data.

Draft for lawyer review. This policy describes Mentora’s privacy and personal-data-protection practices for an independent Cameroonian company operating from Limbe.

  • Independent legal entity
  • Draft for lawyer review
  • Limbe, South-West Region

Important legal note

Cameroon adopted Law No. 2024/017 of 23 December 2024 relating to the protection of personal data. This draft is for lawyer review against that law, its implementing instruments and other applicable requirements.

1.

Who we are

Mentora is an independent company duly registered in Cameroon, with its head office in Limbe, South-West Region. It operates a technology-enabled tutoring marketplace and is not operated by EduTech Mega PLC.

2.

Data we collect

Depending on use, Mentora may collect:

  • identity and profile data;
  • contact details;
  • age or date of birth where needed for safeguarding;
  • Parent/Guardian and Learner information;
  • Tutor qualifications and experience;
  • verification and background-check status;
  • Booking details;
  • pricing and transaction information;
  • payment and payout details;
  • Platform communications;
  • ratings and reviews;
  • complaints and disputes;
  • safety reports and submitted evidence;
  • device, browser, IP and security information;
  • cookie and analytics data.
3.

Why we use data

Mentora processes data to:

  • create and manage accounts;
  • verify Tutors;
  • conduct required background checks;
  • facilitate matching and Bookings;
  • process payments and payouts;
  • communicate with Users;
  • operate online and home-tutoring workflows;
  • provide safety and safeguarding;
  • investigate complaints and disputes;
  • prevent fraud and abuse;
  • secure and improve the Platform;
  • provide support;
  • comply with law;
  • establish, exercise or defend legal claims.
4.

Children and minors

Mentora applies heightened safeguards to information concerning minors. A Parent/Guardian must provide or authorize information where required.

Mentora may process minor information where necessary for the requested service, safeguarding, Booking administration, dispute resolution, fraud prevention or legal compliance.

5.

Tutor verification

Mentora may process identity, qualification, professional and criminal-background verification information to protect Users and satisfy Tutor verification requirements.

Where a competent authority or provider performs verification, Mentora may retain the result or verification status rather than unnecessary underlying records where appropriate and lawful.

6.

Payments

Payment transactions may be handled by designated payment providers. Mentora may receive transaction status, references, amounts and payout information necessary to administer payments.

Users should not send payment-card details through ordinary support communications.

7.

Communications and evidence

Mentora may retain Platform communications, Booking records, timestamps, check-in records and dispute materials when reasonably necessary for safety, safeguarding, dispute resolution, fraud prevention, legal compliance and Platform administration.

8.

Third-party providers

Mentora relies on third-party providers for certain payment processing, hosting, communications, analytics, security, technology, verification and other Platform functions.

9.

Sharing data

Mentora may share information with:

  • relevant Tutors, Learners or Parents for a Booking;
  • payment and technology providers;
  • verification providers;
  • professional advisers;
  • insurers where applicable;
  • competent authorities where required or appropriate;
  • other lawful recipients.

Mentora will not disclose data for unrelated purposes merely because it was collected.

10.

International transfers

Where data is transferred, hosted or accessed outside Cameroon, Mentora will apply safeguards and legal requirements applicable to such transfers.

The final policy should identify actual providers and countries once the technical architecture is finalized.

11.

Retention

Mentora retains data only as long as reasonably necessary for the purpose collected, contractual or operational needs, safeguarding, disputes, fraud prevention, accounting, legal claims, regulatory requirements and statutory retention periods.

Exact retention periods should be confirmed before launch.

12.

Security

Mentora applies reasonable technical and organizational measures designed to protect personal data, including access controls, authentication, encryption where appropriate, logging, backups, permissions, monitoring and confidentiality obligations.

13.

Incidents

Mentora maintains procedures to identify, contain, investigate and respond to personal-data and security incidents and will make legally required notifications.

14.

Cookies

Mentora may use cookies, local storage, SDKs and similar technologies for authentication, security, preferences, analytics, performance and functionality.

Where consent is required, it will be obtained through the relevant mechanism.

15.

Individual rights

Subject to applicable law and exceptions, individuals may have rights to:

  • access their personal data;
  • correct or update their personal data;
  • delete their personal data;
  • object to processing;
  • restrict processing;
  • withdraw consent where consent is the legal basis;
  • portability where applicable;
  • other rights recognized by applicable law.
16.

Privacy requests

Mentora may verify the identity of a requester before releasing, correcting or deleting information. A person cannot obtain another person’s information merely by requesting it.

17.

Parent/Guardian requests

A Parent/Guardian may make appropriate requests concerning a minor where authorized by law. Mentora may request reasonable evidence of parental or guardianship authority.

18.

Marketing

Service communications necessary to operate an account or Booking may be sent. Marketing communications will follow applicable law and consent or opt-out requirements.

19.

Policy changes

Mentora may update this Policy when processing practices, technology, legal obligations or services change. Material changes will be communicated appropriately and renewed consent obtained where legally required.

20.

Contact

  • Privacy contact: [INSERT OFFICIAL PRIVACY EMAIL]
  • Head Office: Limbe, South-West Region, Cameroon.
  • Registration details: [INSERT RCCM/REGISTRATION DETAILS]
21.

Lawyer/developer completion checklist

Before launch, confirm:

  • full data inventory;
  • exact registration and company details;
  • privacy contact;
  • data-controller and processor roles;
  • actual third-party providers;
  • hosting countries;
  • international transfers;
  • retention periods;
  • cookie and analytics tools;
  • user-rights workflow;
  • child and minor data workflow;
  • background-check data handling;
  • breach-response workflow;
  • security controls;
  • applicable regulator and notification procedures.